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028-02_3

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Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 1 of 17

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN
********************************

IN THE MATTER OF THE ESTATE OF )
JEFFREY E. EPSTEIN, ) PROBATE NO. ST-19-PB-80
)
Deceased. ) ACTION FOR TESTATE
_________________ ) ADMINISTRATION

CO-EXECUTORS' CORRECTIONS TO ATTORNEY GENERAL'S
STATUS REPORT ON VOLUNTARY COMPENSATION PROGRAM
AND RENEWED REQUEST FOR RULING

On March 24, 2020, the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"),

DARREN K. INDYKE and RICHARD D. KAHN, asked the Court to grant their Expedited

Motion for Establishment of a Voluntary Claims Resolution Program, filed November 14, 2019,

and allow the Co-Executors to move forward with that Program as carefully constructed in

consultation with claimants' counsel and leading independent claims program experts.

The Co-Executors hereby renew their request. Because the Attorney General of the Virgin

Islands has no standing in this Court to seek to re-shape the Program to suit her whims -

demanding changes that go against the considered views of the Co-Executors, recommendations

of nationally recognized experts in the field, and endorsement by multiple claimants' counsel -

the Court should reject her continued efforts to undermine the Program. As detailed below, the

Attorney General's most recent Status Report (filed April 7, 2020) substantially misrepresents the

actual state of affairs regarding the Program, and requires correction.

1. The Attorney General Misrepresents Claimants' Position Regarding
the Program's Thi

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