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IN THE SUP.ERi OR COURT
OFTHE VIRGIN ISLANDS
FILED
July 13, 2020
TAMARA CHARLES IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
CLERK OF THE COURT DIVISION OF ST. THOMAS AND ST. JOHN
********************************
GHISLAINE MAXWELL, Case 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.
GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS'
MOTION TO INTERVENE
The Government of the United States Virgin Islands ("Government"), by and through its
undersigned counsel, hereby moves for an order permitting the Government to intervene in this
action as of right pursuant to VJ. R. Civ. P. 24(a) or else by leave pursuant to VJ. R. Civ. P.
24(b ). The Government states in support of its motion as follows.
PRELIMINARY STATEMENT
Plaintiff Ghislaine Maxwell ("Maxwell") filed this action seeking indemnification for and
advancement of expenses incurred by reason of her prior employment relationship with decedent
Jeffrey E. Epstein and his affiliated businesses "in connection with any threatened, pending, or
completed suit, proceeding, or investigation relating to Epstein, his affiliated bu
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