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2022.08.02%20Memorandum%20Of%20Law.pdf
This document is a Supplemental Brief filed on August 1, 2022, by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in the Superior Court of the Virgin Islands. The brief supports a Motion to Dismiss Ghislaine Maxwell's complaint seeking indemnification from the Estate. The Co-Executors argue that because Maxwell was convicted of intentional criminal acts (sex trafficking and conspiracy) in the Southern District of New York on June 29, 2022, public policy prohibits enforcing any contract or equitable doctrine that would indemnify her for the financial consequences of her crimes.
2022.08.01%20Brief.pdf
This document is a legal brief filed by Ghislaine Maxwell in the Superior Court of the Virgin Islands against the Estate of Jeffrey Epstein. Maxwell argues that Virgin Islands public policy does not prevent her from seeking indemnification (reimbursement) for legal fees and security costs incurred due to her employment with Epstein, despite her criminal conviction in New York (SDNY). She asserts claims based on contract promises, common law joint tortfeasor indemnity, and corporate indemnity laws regarding her role at NES, LLC.
2021.04.13%20Reply%20Motion.pdf
This document is a 'Plaintiff's Reply to Co-Executors' Brief' filed on April 13, 2021, in the Superior Court of the Virgin Islands by Ghislaine Maxwell's legal team. Maxwell argues that her indemnification case against the Estate of Jeffrey Epstein should not be transferred to the Complex Litigation Division nor assigned to the same judge handling the 'CICO action' (Government v. Indyke). She asserts that her case does not meet the criteria for complex litigation and shares no common facts or claims with the government's racketeering case against the executors.
2021.03.29%20Response%20to%20Order.pdf
This document is a legal brief filed on March 29, 2021, by the Co-Executors of the Estate of Jeffrey Epstein (Darren K. Indyke and Richard D. Kahn) in the Superior Court of the Virgin Islands. The brief argues against designating Ghislaine Maxwell's lawsuit for legal fee indemnification as 'complex' litigation and opposes consolidating it with a separate government 'CICO action' (Case No. ST-2020-CV-00014). The Executors contend that Maxwell's case is a simple single-issue dispute, whereas the CICO action involves complex allegations of a multi-decade criminal enterprise.
2020.09.28%20Response%20to%20Opposition.pdf
This is a Reply Brief filed by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in response to a lawsuit by Ghislaine Maxwell. Maxwell is suing the Estate and NES, LLC for indemnification (payment of her legal fees) related to her criminal and civil cases in New York. The Co-Executors argue the case should be dismissed because: 1) The claim is 'unripe' as her underlying guilt or innocence hasn't been established; 2) Public policy forbids indemnifying criminal conduct; 3) The NES Operating Agreement explicitly allows the company to decline indemnification; and 4) The Statute of Frauds bars claims based on alleged oral promises.
2020.09.22%20Exhibit%20M.pdf
This document is a legal letter filed on September 22, 2020, from the Estate of Jeffrey Epstein's legal counsel to Magistrate Judge Hermon-Percell. The letter responds to accusations by the Virgin Islands Attorney General that the Estate is concealing financial information or 'structuring' transactions to avoid scrutiny. The Estate argues that the Attorney General has already received full transparency via subpoenas to FirstBank and requests the Court order the release of liens on the Estate's accounts to prevent irreparable harm.
2020.07.30%20Stipulation%20For%20Extension%20of%20Time.pdf
This document is a legal stipulation filed on July 30, 2020, in the Superior Court of the Virgin Islands (Case ST-20-CV-155). It represents an agreement between Ghislaine Maxwell (Plaintiff) and the Government of the U.S. Virgin Islands (Proposed Intervenor) to extend the deadline for Maxwell to respond to the Government's Motion to Intervene until August 17, 2020. The document lists the Estate of Jeffrey Epstein and his executors, Darren K. Indyke and Richard D. Kahn, as defendants.
2020.07.13%20Motion%20to%20Intervene.pdf
This document is a Motion to Intervene filed by the Government of the US Virgin Islands in a civil case brought by Ghislaine Maxwell against the Estate of Jeffrey Epstein. The Government seeks to intervene to prevent Maxwell from using the Estate's assets to pay for her legal defense (indemnification), arguing that those assets should be preserved to satisfy a potential judgment in the Government's separate CICO (racketeering) lawsuit against the Estate. The document details Maxwell's evasion of subpoenas prior to her arrest, the Government's interest in the Estate's assets for victim restitution and penalties, and the allegation that Maxwell and the Estate are colluding rather than being true adversaries. While flight logs are mentioned as existing evidence of trafficking, no specific flight records are contained within this specific motion.
2022.12.20%20Motion%20-%20Motion.pdf
This document is a legal motion filed on December 20, 2022, in the Superior Court of the Virgin Islands by the Co-Executors of the Jeffrey Epstein Estate (Darren Indyke and Richard Kahn). They are moving to withdraw a previous motion for attorneys' fees because a resolution was reached in a related case (Govt of USVI v. Epstein Estate et al., ST-2020-CV-00014). The document includes a certificate of service listing government officials and attorneys served with this motion.
2022.03.17%20%20Notice%20-%20Notice%20to%20the%20Court.pdf
This document is an opposition brief filed by the Government of the U.S. Virgin Islands against the Epstein Estate's request for over $112,000 in attorneys' fees. The Government argues that the Estate is not a 'prevailing party' because the underlying court orders were not final judgments, and that the requested hourly rates (up to $1,315/hr) are excessive compared to the local standard of $350/hr. The filing also references the Government's broader CICO lawsuit alleging Epstein used his VI businesses to transport and abuse victims on Little St. James Island.
2022.03.04%20Motion%20-%20Motion.pdf
This document is a Motion for Award of Attorneys' Fees filed by the Co-Executors of the Estate of Jeffrey Epstein in the Superior Court of the Virgin Islands. The Co-Executors are requesting $112,216.90 in fees incurred while successfully defending against the Government of the Virgin Islands' (GVI) attempts to intervene in the probate action and freeze estate assets. The document details the history of the GVI's failed motions, the complex nature of the estate, the funding of the Victims' Compensation Program ($121 million+), and justifies the legal fees based on the attorneys' experience and standard rates.
2021.03.29%20Response%20-%20Response.pdf
This document is a legal response filed by the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) on March 29, 2021, opposing the US Virgin Islands Government's appeal regarding their failed motion to intervene in probate proceedings. The executors argue the Government's petition is untimely as the original motion was denied over a year prior, and that the Government's emergency motion regarding estate assets is moot because the estate has replenished the Victims' Compensation Program funds. Attached exhibits include the original 2020 opposition brief and a March 2021 press release confirming the sale of Epstein's NYC and Palm Beach properties to fund the compensation program.
030.pdf
This document contains a letter from Troutman Sanders LLP to Judge Debra C. Freeman updating the court on the establishment of the Epstein Victims' Compensation Program. It attaches a Status Report filed in the Superior Court of the Virgin Islands and the detailed Protocol for the Independent Epstein Victims' Compensation Program, which outlines eligibility, claims administration, evaluation methodology, and compensation procedures for sexual abuse victims of Jeffrey Epstein.
EFTA00027979.pdf
This document contains the Petition for Probate and Letters Testamentary filed in the Superior Court of the Virgin Islands for the Estate of Jeffrey E. Epstein, stating the value of his personal property at over $577 million. It includes his Death Certificate issued by the City of New York, listing the cause of death as pending further study, and his Last Will and Testament, signed on August 8, 2019, two days before his death. The Will appoints Darren K. Indyke and Richard D. Kahn as executors and leaves the residuary estate to the trustees of The 1953 Trust.
EFTA00020959.pdf
This document is a Quitclaim Deed recorded on December 30, 2011, transferring ownership of Little St. James Island (Parcels A, B, & C) from L.S.J., LLC to Nautilus, Inc. Jeffrey Epstein signed the deed as the sole member of L.S.J., LLC and provided an affidavit stating he is also the sole beneficial owner of Nautilus, Inc., allowing for a stamp tax exemption on the transfer. The stated value for recording purposes was $6,442,100.00.
EFTA00014362.pdf
This document is a Warranty Deed recorded on January 28, 2016, confirming the sale of Great St. James Island in the US Virgin Islands from Christian Kjaer to Great St. Jim, LLC (an entity associated with Jeffrey Epstein). The purchase price was $17,500,000.00. The transaction involved significant stamp duty taxes ($612,500) and was notarized in Denmark before being recorded in St. Thomas.
EFTA00010620.pdf
This document outlines the complete FAA registration history for a Gulfstream G550 (Serial Number 5173). The chain of ownership tracks the aircraft from its manufacturer (Gulfstream) to Chevron U.S.A. (as N401HB), then to Plan D LLC (as N415LM and N212JE), and finally to N550GP LLC (as N550GP). Lawrence Visoski, known as Jeffrey Epstein's pilot, appears prominently as the Manager for both Plan D LLC and Six G Aviation LLC during the 2017-2020 ownership period, signing for flight declarations and bills of sale. The file contains specific international flight declarations, including a 2017 trip to St. Thomas (USVI) and a 2021 trip to Naples, Italy.
HOUSE_OVERSIGHT_017587.jpg
This document appears to be a biographical guest list or contact sheet, marked with a House Oversight Committee footer (HOUSE_OVERSIGHT_017587). It details high-profile individuals from technology, politics, and finance, including executives from Facebook, Microsoft, and Wordpress, as well as former government officials like Robert Rubin and aides to the Clintons and Bush administration. The list provides current roles and past affiliations for each individual.
HOUSE_OVERSIGHT_013487.jpg
This document is a page from a contact or attendee list (labeled HOUSE_OVERSIGHT_013487) containing biographical summaries of high-profile individuals in technology, finance, politics, and academia. Notable figures include Robert Rubin (former Treasury Secretary), General Stan McChrystal, and various tech CEOs and venture capitalists. The document outlines their current roles, former positions, and board memberships, likely prepared for a conference or networking event circa 2011-2013.
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