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N FOR ESTABLISHMENT OF A VOLUNTARY CLAIMS RESOLUTION PROGRAM %fit 0 COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited order to establish an independent and voluntary claims resolution program (the
of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Cour
the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honora
the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorab
— individuals who have designed, implemented and administered extensive mass tort programs including the September 1 I th Victim Compensation Fund, the Roman Catholic Church sex-abuse scandal, the BP Deepwater Horizon oil spill in the Gulf of Mexico, the Agent Orange toxic chemical matter, and others — would be in the b
N FOR ESTABLISHMENT OF A VOLUNTARY CLAIMS RESOLUTION PROGRAM %fit 0 COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited order to establish an independent and voluntary claims resolution program (the
of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Cour
the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honora
the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorab
— individuals who have designed, implemented and administered extensive mass tort programs including the September 1 I th Victim Compensation Fund, the Roman Catholic Church sex-abuse scandal, the BP Deepwater Horizon oil spill in the Gulf of Mexico, the Agent Orange toxic chemical matter, and others — would be in the b
effrey E. Epstein ("The Estate"), created upon Epstein's death, is domiciled in the Virgin Islands. On August 15, 2019, the Executors of The Estate, Darren K. Indyke and Richard D. Kahn, filed a Petition for Probate and Letters Testamentary which included Epstein's last will and testament with the Probate Divisio
between the Executors and the Fund. The Executors of Epstein's Estate, and also the movants for the Expedited Motion to establish the Epstein Fund, Darren K. lndyke and Rickard D. Kahn. were and are involved in various Epstein business entities that arc alleged to share liability in Epstein's civil and cr
ved in various Epstein business entities that arc alleged to share liability in Epstein's civil and criminal violations in the Virgin Islands. Both Indyke and Kahn are the Trustees of the 1953 Trust, which holds almost all of Epstein's assets. See Compl. 72 l3. Furthermore, the Executors are also offic
stein ("the Estate") was created. The Executors, Darren Indyke and Richard Kahn, filed a Petition for Pro
— individuals who have designed, implemented and administered extensive mass tort programs including the September I 1 th Victim Compensation Fund, the Roman Catholic Church sex-abuse scandal, the BP Deepwater Horizon oil spill in the Gulf of Mexico, the Agent Orange toxic chemical matter, and others — would be in the b
ED MOTION FOR ESTABLISHMENT OF A VOLUNTARY CLAIMS RESOLUTION PROGRAM COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited order to establish an independent and voluntary claims resolution program (the
of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Cour
the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honora
the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorab
— individuals who have designed, implemented and administered extensive mass tort programs including the September 1 1 th Victim Compensation Fund, the Roman Catholic Church sex-abuse scandal, the BP Deepwater Horizon oil spill in the Gulf of Mexico, the Agent Orange toxic chemical matter, and others — would be in the b
t his assets be placed in a trust, whose beneficiaries haven't been made public. His closest relative is his brother, Mark Epstein. The will named Darren Indyke and Richard Kahn, two longtime associates of Mr. Epstein, as the estate's executors who are responsible for locating his assets and distributing the
federal prosecutors into Mr. Epstein's alleged sex-trafficking enterprise, according to people familiar the matter. EFTA00069880 Lawyers for Mr. Indyke and Mr. Kahn declined to comment. Mother avenue for the women to receive compensation could open if the government tries to seize Mr. Epstein's ass
ve is his brother, Mark Epstein. The will named Darren Indyke and Richard Kahn, two longtime associates
st his estate in an orderly manner, some plaintiffs' lawyers have raised the possibility of a victim compensation fund, similar to the one set up by the Roman Catholic Church to pay victims of clergy sex abuse. Establishing such a fund at this early stage would require the consent of Mr. Epstein's estate, according to K
Entities connected to both Darren Indyke and the Roman Catholic Church

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Marc Rich
PERSONLeon Black
PERSON
Woody Allen
PERSON
Prince Andrew
PERSON
Julie K. Brown
PERSONHyperion Air
ORGANIZATION
Alan Dershowitz
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
Lawrence Krauss
PERSON
John F. Kennedy
PERSON
John Brennan
PERSON
George Mitchell
PERSON
U.S. Virgin Islands
LOCATION
Alfredo Rodriguez
PERSONMartin Weinberg
PERSON
United States
LOCATION
Joe Biden
PERSON