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IN THE SUPERIOR COURT
OFTHE VIRGIN ISLANDS
FILED
September 28, 2020
TAMARA CHARLES IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
CLERK OF THE COURT DIVISION OF ST. THOMAS & ST. JOHN
*********************************
GHISLAINE MAXWELL,
Plaintiff,
v.
ESTATE OF JEFFREY E. EPSTEIN,
DARREN K. INDYKE, in his capacity as CIVIL NO. ST-20-CV-155
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.
CO-EXECUTORS’ REPLY BRIEF IN SUPPORT OF MOTION TO DISMISS
DARREN K. INDYKE and RICHARD D. KAHN, by and through 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, respectfully submit this Reply Brief in further support of their
Motion to Dismiss the Complaint filed in this action on May 1, 2020 (the “Motion to Dismiss”).
I. MAXWELL’S CLAIM FOR COMMON LAW INDEMNIFICATION IS UNRIPE
AND SHOULD BE DISMISSED.
Maxwell initially filed her Complaint prematurely in violation of 15 V.I.C. § 606(a).
(Motion to Dismiss at 1–2, 4–6.) After forcing the Co-Executors to file the Motion to Dismiss,
Maxwell implicitly conceded her error and, on June 1, 2020, jointly moved with the Co-Executors
for a stay of this action until the re
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