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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
Rule 1 of the Virgin Islands Probate and Fiduciary Rules states that, "[w]here no procedural provision is included herein, procedures set forth in the Virgin Islands Rules of Civil Procedure may be adapted by the court as appropriate." In this regard, Rule 90 of the Virgin Islands Rules of Civil Procedure evinces a clear intent in favor
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
Rule 1 of the Virgin Islands Probate and Fiduciary Rules states that, "[w]here no procedural provision is included herein, procedures set forth in the Virgin Islands Rules of Civil Procedure may be adapted by the court as appropriate." In this regard, Rule 90 of the Virgin Islands Rules of Civil Procedure evinces a clear intent in favor
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
Rule 1 of the Virgin islands Probate and Fiduciary Rules states that, "iwihere no procedural provision is included herein, procedures set forth in the Virgin Islands Rules of Civil Procedure may be adapted by the court as appropriate." In this regard, Rule 90 of the Virgin Islands Rules of Civil Procedure evinces a clear intent in favor
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
Rule I of the Virgin Islands Probate and Fiduciary Rules states that, "[w]here no procedural provision is included herein, procedures set forth in the Virgin Islands Rules of Civil Procedure may be adapted by the court as appropriate." In this regard, Rule 90 of the Virgin Islands Rules of Civil Procedure evinces a clear intent in favor
Entities connected to both Darren Indyke and the Virgin Islands Rules of Civil Procedure

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
LOCATIONSuperior Court
ORGANIZATIONV.I.C.
ORGANIZATION
United States Department of Justice
ORGANIZATION