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IN THE SIJPERJOR CO URI
OF THE VIRGIN ISLANDS
FILED
August 25, 2 022 01:16 ~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.
________________________________________
MOTION TO WITHDRAW AS COUNSEL FOR PLAINTIFF
Pursuant to V.I. Supreme Court Rule 211.1.16(b) and V.I.R.Civ.P. 6-5, Quintairos,
Prieto, Wood & Boyer, P.A. and Kyle R. Waldner, Esq. (collectively, the “Firm”), hereby move
to withdraw as counsel of record for Plaintiff GHISLAINE MAXWELL. In support hereof, the
Firm states:
1. The Firm was retained as counsel for Plaintiff pursuant to a certain engagement
agreement, which required Plaintiff to timely pay the Firm’s invoices for services rendered in
this matter. The agreement also gave the Firm the right to terminate the engagement and
withdraw from this representation for non-payment of any invoice.
2. The Firm provided legal services to Plaintiff in connection with this matter and
invoiced Plaintiff for legal fees and expenses incurred. Thereafter, despite repeated requests,
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