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Case 1:19-cv-11869-MKV-DCF                 Document 28-1        Filed 04/15/20       Page 1 of 20




                  IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
                        DIVISION OF ST. THOMAS & ST. JOHN
                              ********************************
IN THE MATTER OF THE ESTATE OF
JEFFREY E. EPSTEIN,
                                                      )
                                                      )
                                                      )
                                                              PROBATE NO. ST-19-PB-80              -..  '

                               Deceased.              )       ACTION FOR TEST ATE
                                                              ADMINISTRATION


            CO-EXECUTORS' STATUS REPORT ON CONTINUING
    EFFORTS TO ESTABLISH VOLUNTARY COMPENSATION PROGRAM AND
                        REQUEST FOR RULING

               Come now the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate").

DARREN K. INDYKE and RICHARD D. KAHN. and provide the Court with this Status Report

on their continuing efforts to establish an independent and voluntary claims resolution program

(the "Program") for purposes of resolving sexual abuse claims again.st Jeffrey E. Epstein. deceased.

               If the Program fails to launch, it will be an extraordinary lost opportunity for

eligible claimants to receive compensation and voluntarily resolve their claims of sexual abuse

against Mr. Epstein through a confidential, non-adversarial alternative to litigation. And there will

be only one culprit: the Attorney General of the Virgin Islands. Despite weeks of negotiation with

the Attorney General's representatives -    who prefer to file misleading "status reports" with the

Court rather than engage in actual, good-faith discussions -·· the Co-Executors are no closer than

before to having the Attorney General lift her liens on the Estate's accounts so that the Prog

[…]

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