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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
and design and implement the Protocol, the Co-Executors propose engaging the services of independent, nationally recognized experts in this field: Jordana H. Feldman, Kenneth R. Feinberg and Camille S. Biros, whose credentials are discussed in Section D below. The Protocol developed by these experts, with input f
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
and design and implement the Protocol, the Co-Executors propose engaging the services of independent, nationally recognized experts in this field: Jordana H. Feldman, Kenneth R. Feinberg and Camille S. Biros, whose credentials are discussed in Section D below. The Protocol developed by these experts, with input f
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
and design and implement the Protocol, the Co-Executors propose engaging the services of independent, nationally recognized experts in this field: Jordana H. Feldman, Kenneth R. Feinberg and Camille S. Biros, whose credentials are discussed in Section D below. The Protocol developed by these experts, with input f
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
and design and implement the Protocol, the Co-Executors propose engaging the services of independent, nationally recognized experts in this field: Jordana H. Feldman, Kenneth R. Feinberg and Camille S. Biros, whose credentials are discussed in Section D below. The Protocol developed by these experts, with input f
the above witnesses, there are several others who can attest to seeing =with Epstein and Maxwell during this timeframe. These individuals include: Darren EFTA00068555 Epstein Victims' Compensation Program Attn: Jordana H. Feldman, Administrator August 28, 2020 Page 5 Ind ke an' ar pstem. Addi
e courage and strength to stop returning his calls. That is when Epstein's advances ceased. But then, on October 20, 2003, Epstein had his attorney Darren Indyke send- Fedex envelope containing a letter from his office in New York to her home in Newport Beach, CA. (see TM3Q-W2NJ — 61). bas a strong recollect
his office in New York to her home in Newport Beach, CA. (see TM3Q-W2NJ — 61). bas a strong recollection that this was the correspondence from Mr. Indyke demanding that she repay Epstein for back rent for her old apartment in New York. At this point, Epstein was clearly upset that had stopped commun
PANISH SHEA & BOYLE It August 28, 2020 CONFIDENTIAL SETTLEMENT COMMUNICATIONS Epstein Victims' Compensation Program Attn: Jordana H. Feldman. Administrator Washington, D.C. Re: Epstein VCP Claim Submission Claim ID: TM3Q-W2NJ (J Dear Ms. Feldman: We are submitting this confidential le
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
Page: EFTA00018905 →the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorab
Page: EFTA00018905 →and design and implement the Protocol, the Co-Executors propose engaging the services of independent, nationally recognized experts in this field: Jordana H. Feldman, Kenneth R. Feinberg and Camille S. Biros, whose credentials are discussed in Section D below. The Protocol developed by these experts, with input f
Page: EFTA00018910 →Entities connected to both Darren Indyke and Jordana H. Feldman

Jeffrey Epstein
PERSON
Richard Kahn
PERSON
Woody Allen
PERSON
Prince Andrew
PERSONHyperion Air
ORGANIZATION
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
U.S. Virgin Islands
LOCATIONMartin Weinberg
PERSON
New York
LOCATION
Sarah Ferguson
PERSON
Virginia Giuffre
PERSONthe State of New York
LOCATIONSouthern District
LOCATION
Colorado
LOCATION
St. John
LOCATION
St. Croix
LOCATION
Denver
LOCATIONSuperior Court
ORGANIZATIONFeldman
PERSON