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IN THE SUPERIOR COURT
OFTHE VIRGIN ISLANDS
FILED
September 08, 2020
TAMARA CHARLES IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
CLERK OF THE COURT DIVISION OF ST. THOMAS AND ST. JOHN
CIVIL CASE NO.: ST-20-CV-155
GHISLAINE MAXWELL,
Plaintiff,
vs.
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.
________________________________________
PLAINTIFF’S OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS
Plaintiff GHISLAINE MAXWELL (“Plaintiff”), by counsel, pursuant to V.I.R.Civ.P. 12,
hereby opposes the Motion to Dismiss1 (the “Motion to Dismiss”) filed by Defendants DARREN
K. INDYKE (“Indyke”) and RICHARD D. KAHN (“Kahn”) (collectively, the “Co-Executors”),
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”).
I. PRELIMINARY STATEMENT
Defendants’ Motion to dismiss must be denied because its primary basis is now moot and
it secondary arguments have no sufficient basis.
First, Co-Executors’ argument that Plaintiff’s claim against them is premature in
violation of 15 V.I.C § 606(a) is no longer viable. While the Co-Executors argue that they may
1
The Motion to Dismiss is cited herein by page nu
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