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IN THE SIJPERJOR COURT
OF THE VIRGIN I LANDS
FILED
March 04, 2022 05:36 ~M IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
ST-20 2 1-RV-OOOOS
TAMARA CHARLES
CLERK OF THE COURT DIVISION OF ST. THOMAS AND ST. JOHN
*********************************
IN THE MATTER OF THE ESTATE OF CASE NO: ST-2021-RV-
JEFFREY E. EPSTEIN, 00005
Deceased. Originating Case No:
ST-2019-00080
MOTION FOR AWARD OF ATTORNEYS’ FEES AND INCORPORATED
MEMORANDUM OF LAW IN SUPPORT THEREOF
COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the “Epstein
Estate”), DARREN K. INDYKE and RICHARD D. KAHN (the “Co-Executors”), and hereby
move this Honorable Court pursuant to 5 V.I.C. § 541 for an award of attorneys’ fees incurred by
the Co-Executors in their successful opposition to the Government of the Virgin Islands’ (the
“GVI”) Motion to Intervene in the Probate Action pursuant to Rule 24 of the Virgin Islands
Rules of Civil Procedure, filed January 23, 2020 (the “GVI Motion to Intervene”) and the GVI’s
Emergency Motion to Immediately Freeze All Assets and Cash on Hand, filed February 4, 2021
(the “GVI Motion to Freeze Assets” and, together with the GVI Motion to Intervene, the “GVI
Motions”) and the GVI’s Appeal and Petition for Review of Magistrate Judge’s Orders, filed
March 17, 2021 and decided by the Court on February 4, 2022 (the “GVI Appeal”). Counsels’
affidavits in support of this motion are submitted herewith.
The Co-Executor
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