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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
ms administration experts, the Co-Executors have worked diligently to begin formulating a comprehensive process for determination and resolution of the Sexual Abuse Claims. If approved by the Court, the Program would provide, to the fullest extent possible, victims of sexual abuse access to a confidential claim
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
ms administration experts, the Co-Executors have worked diligently to begin formulating a comprehensive process for determination and resolution of the Sexual Abuse Claims. If approved by the Court, the Program would provide, to the fullest extent possible, victims of sexual abuse access to a confidential claim
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
ed entities. For example, the Epstein Fund's design would be. in part, determined by an undefined group of "those with an interest in resolution of the Sexual Abuse Claims." Ex'r Expedited Mot. at 4-5. This group could include any number of individuals and entities, including defendants in the various lawsuits t
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
s administration experts, the Co-Executors have worked diligently to begin formulating a comprehensive pror.ecs for determination and resolution of the Sexual Abuse Claims. If approved by the Court, the Program would provide, to the fullest extent possible, victims of sexual abuse access to a confidential claim
Entities connected to both Richard Kahn and the Sexual Abuse

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