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IN THE SIJPERJOR CO URI
OF THE VIRGIN ISLANDS
FILED
August 01, 2022 06 :00 ~M
ST-20 2 0-CV-00155
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-2020-CV-00155
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 BRIEF IN RESPONSE TO COURT ORDER
Plaintiff, GHISLAINE MAXWELL (hereinafter, “Plaintiff”), pursuant to this Court’s
oral directive at the status conference held on March 9, 2022, hereby files her brief as to whether
Virgin Islands public policy bars one or more of her claims in this action.
INTRODUCTION
This is an action for indemnification for the attorneys’ fees, security costs, costs to find
safe accommodation, and all other expenses Plaintiff has incurred by reason of her prior
employment relationship with Jeffrey E. Epstein (“Epstein”) and his businesses. From
approximately 1999 through at least 2006, Maxwell was employed by Epstein and several of his
businesses, including NES LLC. In this capacity, Plaintiff was responsible for managing
Epstein’s properties in the U.S. Virgin I
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