IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN ***************** ********* ****** IN THE MATTER OF THE ESTATE OF ) JEFFREY E. EPSTEIN, ) ) Deceased. ) ) ST-19-PB-0000080 NOTICE TO THE COURT COMES NOW, the Government of the Virgin Islands, by and through its undersigned counsel, Virgin Islands Department ofJustice, Office of the Attorney General and advise the Court of its efforts to meet, confer and cooperate with counsel for the Estate of Jeffrey E. Epstein ("Estate"), in light of the Court's oral directive related to the filed "Criminal Activity Lien Notice" and the voluntary victims compensation fund ("Fund"). The purpose of this notice is to advise the court of the Government's endeavor to work cooperatively with the victims as well as the Estate on the above concerns. Since the hearing on February 4, 2020, the Government has reached out to and met with the counsel for the Estate and counsels for victims to begin the dialogue for a fair and just resolution of the following issues: A. CRIMINAL ACTIVITY LIEN NOTICE ON ESTATE ACCOUNT By way of recent background, the Court, on Tuesday, February 4, 2020, held a hearing on all outstanding motions in this matter. On Wednesday, February 5, 2020, Shauna Betz, Legal Assistant at Kellerhauls, Ferguson Kroblin (Attorneys for the Estate) sent email correspondence to the Attorney General from Estate attorney Christopher Kroblin, Esq, objecting to the Criminal Activity Lien hold ("Lien") that„ that the Government placed on accounts at the First Bank of Puerto Rico on January 31, 2020, in the name of the "The Estate of Jeffrey E. Epstein," "Nautilus, Inc." and "Great St. Jim, LLC",. (See Exhibit 1) On February 6, 2020, the Attorney General responded by email, and offered to schedule a meeting with the Estate the following day, which EFTA00087286

Attorney Kroblin accepted. (See Exhibit 2). On Friday, February 7, 2020, the Attorney General met, in person, with Attorney Christopher Kroblin at the Office of the Attorney General. Attorney Kroblin expressed the concern that the Lien prevents the Estate from paying its expenses to maintain and preserve the Estate. The Attorney General expressed the importance of the Estate to meet its expenses for maintenance and preservation of the estate and offered, pursuant to her legal authority, to release sufficient funds to meet such expenses once the Estate identifies the expenses and the amount of funds needed. On Sunday February 9, 2020 the Attorney General followed up and memorialized that , meeting by sending an email again expressing her willingness to accommodate an immediate release of sufficient funds to pay the necessary expenses so that the executors could continue to manage, maintain and preserve estate assets, and stated that that the Attorney General's office was eagerly awaiting the listing of expenses to facilitate prompt release of funds for payment. In that same email, the Attorney General also indicated her intention to send follow-up correspondence on the victims' program fund that was briefly discussed in the Friday meeting.. (See Exhibit 3) The CICO statute grants the Attorney General the authority to release, in whole or in part, any personal or real property from the notice. 14 V.I.C. § 610 (r). As the Government's underlying CICO action is still pending, only the Attorney General may release any property or interest from the Criminal Activity Liens. This is the express command of the statute, which provides in relevant part that: The Attorney General . filing the Criminal Activity Lien Notice may release, in whole or in part, any Criminal Activity Lien Notice or may release any personal or real property or beneficial interest in it from the Criminal Activity Lien Notice upon such terms and conditions as he may determine. 14 V.I.C. § 610(r) (emphasis added). The Act thus is clear and unambiguous that where, as here, a Criminal Activity Lien Notice has commenced and attached upon the Attorney General's filing EFTA00087287

of an action and Notice, the Attorney General has sole authority to release the Liens upon such terms and conditions as she may determine to be appropriate. On Monday, February 11, 2020, at 4:26 pm, Counsel for the Estate, Christopher iCroblin, Esquire, sent an email to the Attorney General stating that it was seeking an Order from the Court because FirstBank has informed them that the hold will remain absent a court order. In that email, Estate Counsel notably did not attach by email a courtesy copy of its filed motion. (See Exhibit 4). At 4:39 p.m., the Attorney General specifically requested a copy of the motion. More than one hour later, at 5:45 p.m., Estate Counsel did provide a copy of the motion, which had been emailed to all other counsel, except counsel for the Government. (See Exhibit 5) To date, the Estate has not responded to the Attorney General's request for the listing of expenses as discussed. B. VICTIMS' COMPENSATON FUND — ALTERNATIVE On Monday, February 10, 2020, the Attorney General, as promised in her previous email, sent a four (4) page letter via email to the Estate counsel, detailing the Government's concerns with the victim's compensation fund as proposed by the Estate and setting forth alternative victim compensation program protocols and guidelines for a more fair and just program fund for Epstein victims. . (See Exhibit 6). Jordana Feldman, proposed Fund administrator, was copied on this correspondence. After the February 4, 2020 hearing, the Attorney General also had a very productive meeting with a counsel for victims. The Attorney General shared the government's program plan with said counsel, which was very well received. There are plans for further discussions and meetings with the victims and counsels in an effort to attain a more fair, impartial and just compensation program. (Exhibit 7) EFTA00087288

Respectfully submitted, DENISE N. GEORGE, ESQUIRE ATTORNEY GENERAL V REIN NI ANDS DEPARTMENTDEIIISTICE Dated: February 11, 2020 Virgin Islands Department of Justice Office of the Attorney General 34-38 Kronprindsens Cade St. Thomas U S Virgin Islands 00802 CERTIFICATE OF SERVICE IT IS HEREBY CERTIFIED that the foregoing Motion complies with the word and page requirements of V.I.R. Civ. P. 6-1(e) and, a true and correct copy of the Motion was served via regular mail, postage prepaid, with a courtesy copy sent by email to counsel of record on February I I, 2020 to: CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ., WILLIAM BLUM, ESQ. SHARI D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. KELLERHALS FERGUSON KROBLIN PLLC Email EFTA00087289

Exhibit 1 EFTA00087290