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IN THE SIJPERJOR COURT
OF THE VIRGIN I LANDS
FILED
Ja nu ary 16, 2024 11:47 AM
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. ESTEIN,
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.
BACKGROUND AND PROCEDURAL HISTORY
Almost four years ago, Maxwell initiated this action, seeking contractual and common law
indemnification of attorneys
[…]