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IN THE SUPERIOR CO RT
OF THE VIRGIN ISLANDS
FILED
May 01, 2020
TAMARA CHARLES IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
CLERK OF THE COURT DISTRICT OF ST. THOMAS & ST. JOHN
****************************
GHISLAINE MAXWELL, )
) CIVIL NO. ST-20-CV-155
Plaintiff, )
)
)
v. )
)
ESTATE OF JEFFREY E. EPSTEIN, DARREN )
K. INDYKE, in his capacity as EXECUTOR OF )
THE ESTATE OF JEFFREY E. EPSTEIN, )
RICHARD D. KAHN, in his capacity as )
EXECUTOR OF THE ESTATE OF JEFFREY )
E. EPSTEIN, and NES, LLC, a New York )
Limited Liability Company, )
)
Defendants. )
_________________________________________ )
MOTION TO DISMISS
& INCORPORATED MEMORANDUM OF LAW
COME NOW, DARREN K. INDYKE and RICHARD D. KAHN, by and though
their undersigned counsel, in their capacity as Co-Executors of the Estate of Jeffrey E. Epstein
(the “Estate”), and on behalf of the Estate and NES, LLC (“NES”), an entity administered in
probate by the Co-Executors as part of the Estate, and hereby move for an order pursuant to
V.I. R. Civ. P. 12(b)(6) dismissing the Complaint in this action filed by Plaintiff Ghislaine
[…]