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F 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 "Program") for purpo
(the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited
Page 8 • Before joining the Justice Department to work on the VCF, Ms. Feldman worked in the complex dispute resolution practice at the law firm Dickstein Shapiro, LLP, where she represented clients in the design, implementation and administration of complex settlements and mass claims resolution programs ar
F 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 "Program") for purpo
(the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited
Page 8 • Before joining the Justice Department to work on the VCF, Ms. Feldman worked in the complex dispute resolution practice at the law firm Dickstein Shapiro, LLP, where she represented clients in the design, implementation and administration of complex settlements and mass claims resolution programs ar
e 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 Division of the Superior Co
ious 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 officers of a
Page 8 • Before joining the Justice Department to work on the VCF, Ms. Feldman worked in the complex dispute resolution practice at the law firm Dickstein Shapiro, LLP, where she represented clients in the design, implementation and administration of complex settlements and mass claims resolution programs ar
SHMENT 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 "Program") for purpo
(the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, and move this Honorable Court for an expedited
Page 8 • Before joining the Justice Department to work on the VCF, Ms. Feldman worked in the complex dispute resolution practice at the law firm Dickstein Shapiro, LLP, where she represented clients in the design, implementation and administration of complex settlements and mass claims resolution programs ar
Entities connected to both Richard Kahn and Dickstein Shapiro

Jeffrey Epstein
PERSONDarren Indyke
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Woody Allen
PERSON
Ghislaine Maxwell
PERSON
U.S. Virgin Islands
LOCATION
Sarah Ferguson
PERSONMartin Weinberg
PERSON
New York
LOCATION
St. Croix
LOCATION
Virginia Giuffre
PERSONHyperion Air
ORGANIZATION
St. John
LOCATION
Colorado
LOCATIONSouthern District
LOCATIONSuperior Court
ORGANIZATIONthe State of New York
LOCATIONV.I.C.
ORGANIZATION
United States Department of Justice
ORGANIZATION