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2021.03.29_Response_-_Response

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OF THE YIRGIN ISL.ANDS




March 29, 2021
ST-2019-PB-00080
   TAMARA CHARLES                  IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
'. LERK OF THE COURT                     DIVISION OF ST. THOMAS & ST. JOHN
                                              ***************************

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


                   CO-EXECUTORS' RESPONSE TO GOVERNMENT OF THE UNITED STATES
                    VIRGIN ISLANDS' NOTICE OF APPEAL & PETITION FOR REVIEW OF
                                    MAGISTRATE JUDGE'S ORDERS

                         Pursuant to V.I. Super. Ct. R. 322(b)(5), the Co-Executors of the Estate of Jeffrey E.

             Epstein, DARREN K. INDYKE and RICHARD D. ~HN, hereby respond to the Government

             of the United States Virgin Islands' ("Government") Notice of Appeal & Petition for Review of

             Magistrate Judge's Orders, filed March 17, 2021 ("Petition"). 1

                                          CO-EXECUTORS' POSITION STATEMENT

                         The Government's Petition is too little, too late. Judge Hermon-Percell properly denied

             the Government's Motion to Intervene in these probate proceedings over thirteen (13) months ago,

             a fact that the Government inexplicably fails to tell the Court in its Petition. The Government also

             neglects to inform the Court that the factual basis for its Emergency Motion to Freeze All Estate

             Assets and Cash on Hand (the "Emergency Motion") is no longer accurate. That motion is thus

             moot.

                  1. The Government Lost its

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