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IN THE SIJPERJOR CO URT
OF THE VIRGIN I LA NDS
FILED
August 01, 2 022 04:45 eM IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
S T-20 2 0-CV-00155
TAMARA CHARLES DIVISION OF ST. THOMAS AND ST. JOHN
CLERK OF THE COURT
*********************************
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
COMPLEX
JEFFREY E. EPSTEIN, RICHARD D.
KAHN, in his capacity as EXECUTOR OF
THE ESTATE OF JEFFREY E. ESTEIN,
and NES, LLC, a New York Limited
Liability Company,
Defendants.
CO-EXECUTORS’ SUPPLEMENTAL 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 Supplemental Brief in further support of
their Motion to Dismiss the Complaint filed in this action on May 1, 2020 (the “Motion to
Dismiss”) and in accordance with this Court’s direction during the March 9, 2022 status
conference in this matter.
PRELIMINARY STATEMENT
As the Co-Executors demonstrated in their Reply Brief in Support of the Moti
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