From: Sent: To: Cc: Subject Attachments: Tracking: Monday, February 10, 202010:19 AM Chris roblin Denise George 02-10-2020 Letter to Christopher Kroblin (Estate of Jeffrey E. Epstein) 02-10-2020 Letter to Christopher Kroblin (Estate of Jeffrey E. Epstein).pdf Recipient Delivery Read Chris Kroblin Denise George Good Morning Attorney Kroblin: Delivered: 2/1012020 10:19AM Read: 2/1012020 10:21 AM Attached please find letter dated February 10, 2020 from Attorney General Denise George. Thank you. KINDEST REGARDS, Executive Assistant to the Attorney General Virgin Islands Department of Justke Office of the Attorney General Live Your Life With Purpose: Count your blessings, not your problems, and you will realize how beautiful your lift truly is. EFTA00087391
THE UNITED STATES VIRGIN ISLANDS DEPARTMENT OF JUSTICE OFFICE OF THE ATTORNEY GENERAL February 10, 2020 Christopher Allen Kroblin, Esq. K elle halc Fermi nn Krohlin Pr RE: Estate of Jeffrey E. Epstein Dear Attorney Kroblin: It was good to meet with you on Friday as we discussed matters involving the Estate of Jeffrey Epstein ("Estate"). As we discussed briefly, Judge Carolyn Hermon-Percell requested that the Attorney General's Office and the Estate confer on the issues related to a victims' compensation fund ("Fund"). I write to begin that dialogue by laying out in detail my concerns about and recommendations for the Fund. I expect and certainly understand why some victims will want an expedited process that provides compensation — however incomplete for the harm done to them. However, to be credible and to comport with the law and policies of the Virgin Islands, that process must also be fair, just, and independent. The Fund, as proposed by the Estate, does not meet those standards. Among the issues raised in the Government's opposition to the Fund were four critical issues. Frist, the Fund must set aside sufficient funds to pay claims of victims who may come forward in the future or may proceed through civil litigation. Particularly given the nature of the trauma suffered by these victims, many of whom were children when they were trafficked, there needs to be sufficient time and alternate venues available to victims. While some victims have stepped forward now, others may require more time and support. To make the Fund truly voluntary, the Estate must preserve assets for those who choose not to participate in it. Otherwise, many victims will be coerced into the process, believing that the Fund provides the only chance to ensure that their claims are paid. To the extent that additional victims do not seek or obtain funding, those funds can support organizations that advocate for or support victims of human trafficking - a far more meaningful and appropriate use of an Estate so tied to its fundcr's criminal activities. Second, public policy does not permit the Estate to require broad third-party releases from victims in exchange for compensation. These releases serve no permissible purpose and will only silence victims and prevent them from seeking accountability and recovery from other individuals and EFTA00087392
Christopher Allen Kroblin, Esq. February 10, 2020 Page 2 entities that participated in, facilitated, or covered up Jeffrey Epstein's crimes. I understand that, after I raised this issue, the Epstein Fund has now offered to remove those broad releases from its protocol. That is a positive step, but the commitment must be made binding. Third, the Epstein Estate, whose executors arc directly associated with entities that are defendants in the Government's lawsuit and which allegedly facilitated or participated in Epstein's criminal activity, should play no role in choosing a claims administrator or in designing a compensation program. While the Estate has indicated that the program administrator will have full authority to evaluate and set claim amounts, the fact that the administrators were chosen by, advised by and would be paid handsomely by the Estate creates an unavoidable appearance of impropriety. To ensure the integrity and credibility of the process, the Estate must disavow any role in the process, and allow the victims and the Attorney Genera], with the Court's approval, to collectively select an appropriate administrator. Further, payments to the administrator, now disclosed to be up to $200,000 per month, with $1.7 million for just two months of work to the attorney who designed the Fund, as well as administrative staffing and other business expenses that could amount to millions, are excessive and disproportionate to the nature of the case and anticipated number of victims. The costs to run the Fund should be capped at a reasonable amount that ensures that the Estate's assets will not be unnecessarily and unreasonably dissipated. Fourth, the Epstein Estate must commit not only to a providing compensation, but cooperating with law enforcement. Otherwise, the Fund's primary purpose can be seen as limiting the Estate's exposure, protecting Epstein's associates, paying for victims' silence and avoiding further public exposure. That is a debt owed not only to Epstein's victims, but to all those who may avoid becoming victims of other sexual predators in the future. Specifically, an acceptable, fair and appropriate victims' program fund would have to be consistent with these principles and include the following commitments from the Estatc: 1. The Estate must provide a complete inventory and accounting of the assets that are held by the Estate, 1953 Trust and by Jeffrey Epstein or any other entities that he owned or controlled, whether or not a part of the probate. The Estate in good faith should be open and honest with the victims, the Court and the Government regarding the assets of the estate and the value of each asset as Virgin Islands probate law requires. The victims should not be asked to evaluate appropriate compensation, nor can the Government blindly release funds from its criminal activity liens without knowing the true nature and total value of Epstein's assets. 2. The Estate must agree to set aside a sufficient fixed fund prior to the close of the probate proceedings to compensate victims who do not accept payment from the Fund or do not come forward within the probate claims period of the Estate. In the event that such victims do not come forward or obtain judgments, the balance of the fund would be donated, through cypres, to organizations providing support to victims of human trafficking, sexual exploitation and sexual assault. The timing for payments must be centered on victims' relief, not deadlines dictated by the probate process. EFTA00087393
Christopher Allen Kroblin, Esq. February 10, 2020 Page 3 3. The Estate may not transfer ownership of Great St. James and Little St. James and other instrumentalities of Epstein's crimes in the Virgin Islands and must set aside a fixed sum sufficient to satisfy any potential judgment in favor of the Government of the Virgin Islands. The Government preserves its authority to enforce its laws to curtail human trafficking, sexual assaults and criminal enterprises, to hold Epstein and other violators accountable, to protect the safety and wellbeing of the Virgin Islands, to guide how victims are cared for and to protect our children—those who live here, as well as those who are brought here—from the scourge of human trafficking and sexual exploitation, now and in the future. 4. The Fund administrator and the protocol and criteria for the Fund must be chosen by Epstein's victims and the Attorney General, informed by experts in human trafficking, and/or survivors of human trafficking, and approved by the Court. The Fund administrator herself must be knowledgeable and experienced in the administration and settlement of funds for victims of crimes of human trafficking and sexual exploitation/assault of women and children. 5. Because of the existing conflicts of interest of the Estate and executors, as laid out in the Government's opposition to the Fund, there must be an absolute firewall between the Fund and the Estate. Furthermore, because of these conflicts, the Executors of the Estate should have no role at all in the Fund, including in selecting or approving the administrator, the protocol or criteria for the fund, or oversight or approval of the Fund's administration. 6. The Fund must provide full reporting on its criteria, process, awards, and expenses to the Court and the public while protecting the privacy of any claimants who choose to remain anonymous. 7. The program administrator must, in consultation with victims and non-profit or government organizations focused on human trafficking, identify a plan to adequately publicize the existence of the Fund. 8. Once a claim reaches settlement, victims will not be asked or required to release any person or entity from liability other than the Estate. 9. The Estate will set aside funds to provide counseling to any victim who wishes to discuss coming forward to the Fund or to law enforcement. The individual or entity providing such counseling will be approved by the Attorney General, victims' counsel, and the Court. The identity of all such victims will not be disclosed to the Estate. 10. Claimants will be provided with the Virgin Islands Crime Victims' Bill of Rights and be provided with contact information for the Virgin Islands Office of the Attorney General should they care to cooperate with Virgin Islands law enforcement. EFTA00087394
Christopher Allen Kroblin, Esq. February 10, 2020 Page 4 II. The Estate will agree that no records obtained in the claims or counseling process will be used against any victim or in defending any claim against the Estate or related entities or individuals. 12. Expenses of setting up and administering the Epstein Fund will be capped at a reasonable amount. This is absolutely necessary to avoid the excessive costs proposed to run the Fund, which would deplete the funds in the Estate and place significant resources from the Fund in the pockets of the Estate's associates and hand-picked administrators and attorneys. The costs of the program should be commensurate with the nature of the claims and the number of victims addressed. 13. The Estate will agree to preserve, identify, and make available to the Virgin Islands all documents (including electronically stored information and video/audio recordings) related to Epstein's criminal conduct in the Virgin Islands, and will not seek to prevent disclosure of such information, though no information that might reveal the identity of his victims will be publicly disclosed, as required by Virgin Islands law. 14. The Estate will agree to cooperate to provide information against any individuals or other entities that participated in the conduct described in the Government's complaint. 15. The Estate will waive any non-disclosure agreements signed by former employees of Epstein or related entities and will notify such employees that they arc not bound by confidentiality and are encouraged to cooperate fully and truthfully with the Attorney General and her representatives. I sincerely hope that the Estate will find these commitments to be uncontroversial and consistent with its commitment to ensure swift, fair and lawful resolution for Epstein's victims, and we look forward to talking with you about these issues and any other suggestions you may have to address the Government's concerns and interests. Sincerely, Denise N. George, Esq. Attorney General of the U.S. Virgin Islands cc. EFTA00087395
Exhibit 7 EFTA00087396

