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IN THE SIJPERJOR CO URI
OF THE VIRGIN ISLANDS
FILED
October 31, 2023 04:36 PM
ST-2020-CV-00155
TAMARA CHARLES IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
CLERK OF THE COURT DIVISION OF ST. THOMAS AND ST. JOHN
*********************************
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
JEFFREY E. EPSTEIN, RICHARD D. COMPLEX
KAHN, in his capacity as EXECUTOR OF
THE ESTATE OF JEFFREY E. EPSTEIN,
and NES, LLC, a New York Limited
Liability Company,
Defendants.
CO-EXECUTORS’ REPLY IN SUPPORT OF SUPPLEMENTAL MOTION TO
DISMISS, OR ALTERNATIVELY, COMPEL PLAINTIFF TO APPEAR PRO SE
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 (collectively, “Defendants”), respectfully submit this reply in
support of their supplemental motion to dismiss for failure to prosecute, or alternatively, to compel
Plaintiff Ghislaine Maxwell (“Maxwell”) to appear pro se.
ARGUMENT
Maxwell initiated the instant action over three and a half years ago, seeking contractual
and common law indemnification of attorneys’ fees and other cos
[…]