2021.03.29%20Response%20-%20Response.pdf

OF THE VIRGIN ISLANDS
FILED
March 29, 2021
ST-2019-PB-00080
TAMARA CHARLES
CLERK OF THE COURT
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS & ST. JOHN
***************************
IN THE MATTER OF THE ESTATE OF
JEFFREY E. EPSTEIN,
)
)
)
)
PROBATE NO. ST-19-PB-80
ACTION FOR TESTATE
Deceased. ADMINISTRATION
CO-EXECUTORS' RESPONSE TO GOVERNMENT OF THE UNITED STATES
VIRGIN ISLANDS' NOTICE OF APPEAL & PETITION FOR REVIEW OF
MAGISTRATE JUDGE'S ORDERS
Pursuant to V.I. Super. Ct. R. 322(b)(5), the Co-Executors of the Estate of Jeffrey E.
Epstein, DARREN K. INDYKE and RICHARD D. KAHN, hereby respond to the Government
of the United States Virgin Islands' ("Government") Notice of Appeal & Petition for Review of
Magistrate Judge's Orders, filed March 17, 2021 ("Petition"). 1
CO-EXECUTORS' POSITION STATEMENT
The Government's Petition is too little, too late. Judge Hermon-Percell properly denied
the Government's Motion to Intervene in these probate proceedings over thirteen (13) months ago,
a fact that the Government inexplicably fails to tell the Court in its Petition. The Government also
neglects to inform the Court that the factual basis for its Emergency Motion to Freeze All Estate
Assets and Cash on Hand (the "Emergency Motion") is no longer accurate. That motion is thus
moot.
1. The Government Lost its Motion to Intervene Over Thirteen (13) Months Ago.
The Government filed its Motion to Intervene on January 23, 2020, relying on V.I. Civ. P.
Rule 24. As explained in the Co-Executors' January 31 , 2020 opposition to that Motion, Rule 24
While the Government cites V.I. Supr. Ct. R. 322.1 (b) in support of its Petition, that Rule has been repealed.

Estate of Jeffrey E. Epstein
Response to Notice of Appeal
Probate No. ST-19-PB-80
Page 2 of 5
is inapplicable to these probate proceedings, which are instead governed by Title 15 of the Virgin
Islands Code and the Virgin Islands Rules for Probate and Fiduciary Proceedings. 2 On February
4, 2020, the Magistrate Judge expressly denied the Motion to Intervene from the bench:
THE COURT: "[B]efore me I have a motion from the People, the Government to
intervene as a claimant intervenor in the matter and I'm going to deny that — the
Motion to Intervene. You're here as a claimant. And I'm assuming that you will
file your formal creditors claim."
(Official Transcript of Proceedings at 98:8-14, attached as Exhibit B) (emphasis supplied).
There was no uncertainty about the Magistrate Judge's February 4, 2020 ruling, and no
excuse for the Government to delay any appeal from it. Rather, the Government elected not to do
so. It strains credulity to now believe that the Government was unaware of that ruling and had to
await the Magistrate Judge's Order dated February 26, 2021 to realize that the Court denied its
Motion to Intervene more than one (1) year earlier. 3
Even if the Court ignored the Government's extraordinary delay in filing its Petition, its
application lacks merit. As the Magistrate Judge noted on February 4, 2020, the Government —
a civil litigant against the Estate in the CICO lawsuit entitled Gov 't US Virgin Islands v. Estate
of Jeffrey Epstein, et al., No. ST-2020-CV-144 — is in no different position than those asserting
claims against the Estate. The Magistrate Judge explained that situation to the Government:
"ASSISTANT ATTORNEY GENERAL ARIEL SMITH: I just have one
procedural question, Your Honor. To the extent that you've denied the
Government's Motion to Intervene, how would we file any response to — cause
2. The Co-Executors' Opposition to Motion to Intervene is attached as Exhibit A.
3. The Magistrate Judge 's Order expressly notes "the Court's denial of said Motion [to Intervene] at the February
4, 2020 hearing." See February 26, 2021 Order at fn. 1.
4. Contrary to the Government's representation (Petition at 2 fn . 2), the Court has not granted the Government leave
to fi le its Second Amended Complaint in the CICO action.

Estate of Jeffrey E. Epstein
Response to Notice of Appeal
Probate No. ST-19-PB-80
Page 3 of 5
we decided to file the Motion To Intervene in order to be able to file the opposition 5
which has not been formally filed. It was just filed as an attachment.
THE COURT: You come in as claimant, right, so you would be presented before
the Court."
Exh. B (February 4, 2020 Hrg. Tr.) at 100: 8-19 ( emphasis supplied). Despite Judge Hermon-Percell 's direction, the Government never filed a claim in these probate proceedings. 6 As the
Magistrate Judge made clear, filing a claim is a prerequisite to pursuing relief in a probate
proceeding.
For the reasons detailed by the Co-Executors in their opposition to the Motion to Intervene,
the Government is required in these probate proceedings to proceed pursuant to the Probate
Division's rules, just as any other claimant would.
2. The Government's Emergency Motion is Moot.
The Government filed its Emergency Motion on February 3, 2021 based on its contention
that the Estate had breached its commitment to fund the EVCP. However, the EVCP is once again
fully funded and has been operating as it had since its implementation. 7 The Government's
application is therefore moot.
ADDITIONAL ISSUES PRESENTED FOR REVIEW
1. Whether the Government's more-than-thirteen (13) months' delay in appealing from the
Magistrate Judge's denial of its Motion to Intervene renders its Petition untimely.
5. See Government's Opposition to Estate's Motion for Establishment of a Voluntary Claims Resolution Program,
filed January 20, 2020, in which the Government — alone among all others appearing in these probate
proceedings — opposed the Co-Executors' effort to establish the Epstein Victims' Compensation Program
("EVCP"), a widely-heralded alternative dispute resolution process to compensate those claiming sexual abuse
by Mr. Epstein. The Magistrate Judge ultimately approved the EVCP by Order dated June 2, 2020.
6 The Government's assertions that it acts "as a claimant" and "has a claim against the Estate" (Petition at 3) are
belied by its refusal to file such a claim.
7. See March 12, 2021 EVCP Press Release ("Epstein Victims' Compensation Program to Resume Issuance of
Compensation Offers"), attached as Exhibit C.

Estate of Jeffrey E. Epstein
Response to Notice of Appeal
Probate No. ST-19-PB-80
Page 4 of 5
2. Whether the Government's failure to file a claim in these probate proceedings provides an
additional ground for the Magistrate Judge's ruling that the Government lacked standing
to assert its now-moot Emergency Motion to Immediately Freeze All Estate Assets and
Cash on Hand.
Dated: March 29, 2021
Respectfully,
/s/ Christopher Allen Kroblin
CHRISTOPHER ALLEN KROBLIN, ESQ.
SHARI N. D' ANDRADE, ESQ.
MARJORIE WHALEN, ESQ.
V.I. Bar Nos. 966, 1221 & R2019
KELLERHALS FERGUSON KROBLIN PLLC
Royal Palms Professional Building
9053 Estate Thomas, Suite 101
St. Thomas, V.I. 00802
Telephone: (340) 779-2564
Facsimile: (888) 316-9269
Email: ckroblin@kellfer.com
sdandrade@kellfer.com
mwhalen@kellfer.com

Estate of Jeffrey E. Epstein
Response to Notice of Appeal
Probate No. ST-19-PB-80
Page 5 of 5
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that the Position Statement contained in the foregoing Co Executors' Response to Government of the United States Virgin Islands' Notice of Appeal and
Petition for Review of Magistrate Judge's Orders complies with the word-count requirements of
V.I. Super. Ct. R. 322(b)(5) (780 words) and that a true and correct copy of this Response was
served via the electronic filing system to:
John H. Benham, Esq.
Law Office of John H. Benham, P.C.
john@benhamlawvi.com
Douglas B. Chanco, Esq.
Chanco Schiffer P.C.
doug@csfirm.com
Richard Bourne-Vanneck, Esq.
Law Offices of Richard P. Bourne-Vanneck, Esq.
richard@rpbvlawoffices.com
Kevin F. D'Amour, Esq.
Esq.Gaylin Vogel, Esq.
Law Offices of Kevin F. D'Amour, P.C.
kevin.damour@comcast.net
gaylin.vogel@comcast.net
Melody D. Westfall, Esq.
Westfall Law PLLC
mwestfall@westfalllaw.com
Denise N. George, Esq.
Ariel M. Smith, Esq.
Carol Thomas-Jacobs, Esq.
Virgin Islands Department of Justice
denise.george@doj.vi.gov
ariel.smith@doj.vi.gov
carol.jacobs@doj.vi.gov
A. Jeffrey Weiss, Esq.
A.J. Weiss & Associates
jeffweiss@weisslaw-vi.net
Sean Foster, Esq.
Marjorie Rawls Roberts, P.C.
sean@marjorierobertspc.com
John K. Dema, Esq.
Law Offices of John K. Dema
jdema@demalaw.com
Rosalie Simmonds Ballentine,
Rosalie Simmonds Ballentine, P.C.
roselaw@viaccess.net
Sigrid Stone McCawley, Esq.
David Boies, Esq.
Joshua I. Schiller, Esq.
Boies Schiller Flexner LLP
smmcawley@bsfllp.com
dboies@bsfllp.com
jlschiller@bsfllp.com
J. Russell B. Pate, Esq.
The Pate Law Firm
pate@sunlawvi.com
/s/ Christopher Allen Kroblin

OF THE VIRGIN ISLANDS
FILED
March 29, 2021
ST-2019-PB-00080
TAMARA CHARLES
CLERK OF THE COURT
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS & ST. JOHN
********************************
IN THE MATTER OF THE ESTATE OF
JEFFREY E. EPSTEIN,
)
)
)
)
PROBATE NO. ST-19-PB-80
ACTION FOR TESTATE
ADMINISTRATION
Deceased.
OPPOSITION TO
GOVERNMENT'S MOTION TO INTERVENE (CORRECTED BRIEF)1
COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"),
DARREN K. INDYKE AND RICHARD D. KAHN, by and through KELLERHALS FERGUSON
KROBLIN PLLC, and hereby oppose the Motion to Intervene filed by the Government of the Virgin
Islands (the "GVI"). Because the GVI's Motion to Intervene is flawed both substantively and
procedurally, the Court should deny that application.
I. The Proposed Intervention Serves No Proper Purpose
The GVI asserts that its intervention in this probate proceeding is, in part, required "to
ensure that the administration of the Estate conforms to the laws of the Virgin Islands." (Motion
to Intervene at 1.) That is nonsense: under Virgin Islands law, it is the Court's charge — not the
GVI's — to oversee the proper administration of estates and ensure their compliance with Virgin
Islands law.
The Superior Court has original jurisdiction "to supervise and administer estates and
fiduciary relations." 4 V.I.C. § 76(a).
"[T]he Superior Court 'has jurisdiction and the power to administer justice
in all matters relating to the affairs of decedents, ... to try and determine all
questions, legal or equitable, arising between any or all of the parties to any
1 This Corrected Brief in Opposition is filed in place of the Opposition to the Government's Motion to Intervene,
filed in this Court on behalf of the Co-Executors on Friday, January 31, 2020.
Exhibit A

Estate of Jeffrey E. Epstein
Opposition to Government's Motion to Intervene (Corrected Brief)
Probate No. ST-19-PB-80
Page 2
proceeding, ... as to any and all matters necessary to be determined in order
to make a full, equitable, and complete disposition of the matter by such
order or decree as justice requires.' 15 V.I.C. § 161. The court is
unrestricted in its power to dispose of such cases 'as justice requires' and is
explicitly authorized to grant letters of administration, direct and control an
executor or administrator's conduct, distribute assets, and order the sale of
the deceased person's property. Id."
Ottley v. Estate of Bell, 61 V.I. 480, 489-90 (V.I. 2014). The GVI offers no explanation for why
it believes the Court is not up to that task.
Nor does the GVI explain why it waited more than five (5) months to seek to intervene in
this proceeding, which the Co-Executors commenced on August 15, 2019. That the GVI decided
two (2) weeks ago to commence civil claims and file criminal activity liens against the Estate is a
self-created emergency: the GVI has long known that Mr. Epstein (and now the Estate) owns
substantial real property in the Virgin Islands.
The GVI also purports to find a "potential conflict of interest" in the Co-Executors'
administration of the Estate, in particular in proposing to hire independent, nationally recognized
claims administration experts to design and implement the proposed Epstein Victims'
Compensation Program (the "Program"). (Motion to Intervene at 1.) 2 That purported conflict
does not exist. "The mere existence of a possible adverse interest, without more, is not sufficient
grounds for complaint in the Virgin Islands." In re Estate of Vose, 317 F.2d 281, 282, n.4 (3d Cir.
1963) (internal citations omitted). Here, the Co-Executors do not have an interest adverse to the
Estate which would prevent them from faithfully administering their fiduciary duties. Nor is there
any allegation of neglect or dereliction of their fiduciary duties. Indeed, there is absolutely no
evidence that the Co-Executors' manner and conduct in executing their office has run afoul of the
2. The GVI's baseless attack on the Program is dealt with separately in the Estate's Reply to the GVI's Opposition
to Estate's Motion for Establishment of a Voluntary Claims Resolution Program, filed Friday, January 31, 2020.

Estate of Jeffrey E. Epstein
Opposition to Government's Motion to Intervene (Corrected Brief)
Probate No. ST-19-PB-80
Page 3
standard of care required of an executor. There is, and can be, no allegation that the Co- Executors
have been unfaithful to their trust.
It cannot be a "conflict of interest" for the Co-Executors to have known Mr. Epstein during
his lifetime — if that were the case, no one could ever appoint a friend or trusted colleague as
executor of his or her estate. Nor can Messrs. Indyke's and Kahn's past and present involvement
in "various Epstein business entities" constitute a disqualifying conflict of interest. (Motion to
Intervene at 6.) That some of those entities "are alleged to share liability in [Mr.] Epstein's civil
and criminal violations in the Virgin Islands and elsewhere" (id. at 6-7) is nothing more than an
unsupported, unproven allegation — none of those business entities have ever been criminally
charged, and none have ever been found liable for Mr. Epstein's alleged conduct.
II. The Virgin Islands Code and the Probate Rules Govern, Not Rule 24
The GVI bottoms its purported right to intervene on Rule 24 of the Virgin Islands Rules of
Civil Procedure ("Rule 24"). (Motion to Intervene at 1, 3, 4, 7.) That is a false bottom: it is the
Virgin Islands Code and the Virgin Islands Rules for Probate and Fiduciary Proceedings (the
"Probate Rules") that set forth the specific steps a purported claimant must take to bring a claim
against an estate and participate in a probate proceeding. Rule 24 has no application to this
proceeding.
The exclusive procedure for pursuing a claim against an estate is set forth in Chapter 23 of
Title 15 of the Virgin Islands Code and the Probate Rules, entitled "Claims and Charge Against
the Estate." See 15 V.I.C §§ 391-430. The Probate Rules also include provisions governing a
claimant's participation in a probate proceeding. To the extent the GVI has a claim against the
Estate, it must follow these mandatory claims procedures to make that claim and participate in
these proceedings.

Estate of Jeffrey E. Epstein
Opposition to Government's Motion to Intervene (Corrected Brief)
Probate No. ST-19-PB-80
Page 4
The Virgin Islands Code and the Probate Rules also provide the only procedure for a
creditor to present its claim against the Estate. Thus, a creditor must follow the process outlined
in 15 V.I.C. § 606(b) in order to properly file a complaint against an estate. See Ottley, supra, 61
V.I. at 493. The language of Section 606(b) is absolute: it forbids a creditor from commencing
an action against an estate until it has first presented its claim to the executors, and they have
considered and disallowed that claim. See Oat v. Sewer Enters., 46 V.I. 286, 290 (D.V.I. 2004).
While all claimants, including the GVI, may file claims with the Estate, they are subject to the
jurisdiction of the Court in this probate proceeding. See 15 V.I.C. §§ 391 and 392.3
III. The GVI Failed to Follow the Applicable Claims Procedure
Under Virgin Islands law, one who seeks to assert a claim against an estate must first
present its claim to the appointed executor or administrator of that estate. See 15 V.I.C. § 391
(requiring "[e]very executor or administrator" to publish in a local newspaper and to post a notice
"requir[ing] all persons having claims against the estate to present them, with the proper vouchers,
within six months from the date of the notice, to the executor or administrator, at a place within
this territory therein specified."). The claimant must conform to the requirements set forth in Title
15, including verification of its claim by affidavit of the claimant or someone with personal
knowledge of the relevant facts. See 15 V.I.C. § 393 ("Every claim presented to the executor or
administrator shall be verified by the affidavit of the claimant, or someone on his behalf who has
personal knowledge of the facts, to the effect that the amount claimed is justly due; that no
3. The GVI does not address how Rule 24 could apply to this probate matter, which is of course governed by the
Probate Rules. See V.I. R. PROB. 1 (providing that "[t]hese Virgin Islands Rules for Probate and Fiduciary
Proceedings shall apply in probate, guardianship, trust and other fiduciary proceedings."). While Rule 1 of the
Probate Rules permits the Court to adapt the Virgin Islands Rules of Civil Procedure "as appropriate" when "no
procedural provision is included [in the Probate Rules]," here there are express procedural provisions in the
Probate Rules that govern claims and the participation of claimants in probate proceedings.

Estate of Jeffrey E. Epstein
Opposition to Government's Motion to Intervene (Corrected Brief)
Probate No. ST-19-PB-80
Page 5
payments have been made thereon, except as stated; and that there is no just counterclaim to the
same, to the knowledge of the affiant.").
If and when such a claim is presented to an executor, the executor is then required to
examine the claim, consider it, and then either accept or reject it. 15 V.I.C. § 394 ("When a claim
is presented to the executor or administrator, as prescribed in section 393 of this title, if he is
satisfied that the claim thus presented is just, he shall indorse upon it the words 'Examined and
approved', with the date thereof, and sign the same officially, and shall pay such claim in due
course of administration. If he is not so satisfied he shall indorse thereon the words 'Examined
and rejected', with the date thereof, and sign the same officially.").
Here, the GVI failed to follow the claims procedure required by Virgin Islands law to bring
a claim against the Estate. Rather than present its claim to the Co-Executors and call on them to
review and consider it, GVI instead filed a civil action seeking damages and other relief. That is
improper. If the GVI wishes to formally appear in these proceedings, it must (like any other
creditor) follow the claims procedure set forth in 15 V.I.C. §§ 391-394: the GVI must present a
verified claim, supported by documentation, to the Co-Executors. Pursuant to the statutory
scheme, the Co-Executors are then required to assess the GVI's claim and either reject or accept
it. Only then would the GVI have standing to participate in this probate proceeding like all other
claimants. However, the Virgin Islands Legislature has mandated that an action may be
commenced against an executor only after the expiration of twelve (12) months from the date
letters testamentary are granted by this Court. Ottley, supra, 61 V.I. at 491 (quoting 15 V.I.C. §
606(a)). These "mandatory" rules apply to all claimants, including the GVI. A claimant is not
permitted to bypass the probate process enacted by the Legislature, which was designed precisely
for this purpose -- to relieve the executors from defending the estate's rights in both a civil action

Estate of Jeffrey E. Epstein
Opposition to Government's Motion to Intervene (Corrected Brief)
Probate No. ST-19-PB-80
Page 6
and through probate proceedings simultaneously. See Ottley, supra, 61 V.I. at 494. This process
also ensures that a claimant will not serve the executor with a summons, in an attempt to gain
priority over estate assets to the detriment of other creditors who properly follow the probate
process.
IV. Even if Rule 24 Were Applicable – It is Not – the Contingent Nature of the
GVI’s Claim Requires the Court to Deny Intervention
On January 15, 2020, the GVI filed a civil forfeiture action against the Estate in derogation
of the applicable statutory requirements set forth in the Virgin Islands Code and Probate Rules.
Even assuming the GVI’s complaint had not been filed in contravention of these mandatory claims
rules, the GVI would merely have a contingent claim — i.e., one that is entirely dependent on its
success in that separate action. "[C]ourts in this circuit that have been confronted with the issue
have consistently held that intervention pursuant to Rule 24(a)(2) is inappropriate where the
proposed intervenor’s interest is contingent upon prevailing on a tort claim in a separate action."
Gen. Star Indem. Co. v. Virgin Is. Port Auth, 224 F.R.D. 372, 375-376 (D.V.I. 2004) ("Proposed
Intervenors cannot deny that any interest they have or may have in this matter is purely contingent
upon a favorable judgment in their underlying suit .... The Court finds that such a contingent
interest is insufficient to sustain intervention of right"). Here, even assuming for the sake of
argument that Rule 24 is applicable, the Government’s contingent interest in a possible favorable
judgment in another suit is not an interest significant enough to authorize its intervention.
V. Conclusion
How and when a creditor may present a claim and participate in a probate proceeding is
governed by Title 15 of the Virgin Islands Code and the Probate Rules. If the GVI has a claim
against the Estate as alleged in its Motion to Intervene, it must follow the claims procedure set
forth in 15 V.I.C. §§ 391-394 and the Probate Rules. The rule under which the GVI seeks to

Estate of Jeffrey E. Epstein
Opposition to Government's Motion to Intervene (Corrected Brief)
Probate No. ST-19-PB-80
Page 7
intervene in this proceeding, Rule 24 of the Virgin Islands Rules of Civil Procedure, does not apply
to this probate proceeding. Because the GVI has not satisfied the requisites for its participation in
this probate proceeding, the Court should deny the GVI's Motion to Intervene.
Dated: February 3, 2020
Respectfully,
/s/ Christopher Allen Kroblin
CHRISTOPHER ALLEN KROBLIN, ESQ.
ANDREW W. HEYMANN, ESQ.
WILLIAM L. BLUM, ESQ.
SHARI N. D'ANDRADE, ESQ.
MARJORIE WHALEN, ESQ.
V.I. Bar Nos. 966, 266, 136, 1221 & R2019
KELLERHALS FERGUSON KROBLIN PLLC
Royal Palms Professional Building
9053 Estate Thomas, Suite 101
St. Thomas, V.I. 00802
Telephone: (340) 779-2564
Facsimile: (888) 316-9269
Email: ckroblin@kellfer.com
aheymann@solblum.com
wblum@solblum.com
sdandrade@kellfer.com
mwhalen@kellfer.com

Estate of Jeffrey E. Epstein
Opposition to Government's Motion to Intervene (Corrected Brief)
CERTIFICATE OF SERVICE
Probate No. ST-19-PB-80
Page 8
I HEREBY CERTIFY that on this 3rd day of February 2020, I caused a true and exact
copy of the foregoing Opposition to Government's Motion to Intervene (Corrected Brief) to
be served upon:
Via Electronic Mail by Agreement of the Parties:
John H. Benham, Esq.
Law Office of John H. Benham, P.C.
P.O. Box 11720
St. Thomas, VI 00801
john@benhamlawvi.com
Douglas B. Chanco, Esq.
ChancoSchiffer P.C.
3355 Lenox Road, Suite 750
Atlanta, GA 30326
doug@csfirm.com
A. Jeffrey Weiss, Esq.
A.J. Weiss & Associates
6934 Vessup Lane
St. Thomas, VI 00802
jeffweiss@weisslaw-vi.net
Richard P. Bourne-Vanneck, Esq.
Law Offices of Richard Bourne-Vanneck
9800 Buccaneer Mall Suite #9
St. Thomas, VI 00802
richard@rpvblawoffices.com
Sean Foster, Esq.
Marjorie Rawls Roberts, P.C.
P.O. Box 6347
St. Thomas, VI 00804
sean@marjorierobertspc.com

Estate of Jeffrey E. Epstein
Opposition to Government's Motion to Intervene (Corrected Brief)
Probate No. ST-19-PB-80
Page 9
Via First-Class Mail, Postage Prepaid:
Denise N. George, Esq.
Attorney General
Ariel M. Smith, Esq.
Chief, Civil Division
Virgin Islands Department of Justice
34-38 Krondprinsdens Gade
GERS Complex, 2nd Floor
St. Thomas, Virgin Islands 00804
J. Russell B. Pate, Esq.
THE PATE LAW FIRM
P.O. Box 370, Christiansted
St. Croix, USVI 00821
Kevin F. D'Amour, Esq.
Gaylin Vogel Esq.
Kevin F. D' Amour, P.C.
5143 Palm Passage, Suite 18b & 19b
St. Thomas, V.I. 00802
John K. Dema, Esq.
Law Offices of John K. Dema
1236 Strand Street, Suite 103
Christiansted, St. Croix
U.S. Virgin Islands 00820-5008

OF THE VIRGIN ISLANDS
FILED
March 29, 2021 EDIATE RELEASE
ST-2019-PB-00080 2021
TAMARA CHARLES
CLERK OF THE COURT
CONTACT
Jeff Solnet
Press@EpsteinVCP.com
Epstein Victims' Compensation Program to
Resume Issuance of Compensation Offers
New York, NY - Today, the Epstein Victims' Compensation Program (the "Program") and its independent
Administrator, Jordana ("Jordy") H. Feldman, announced that the Program will resume the issuance of
compensation determination offers, effective immediately.
On February 4, 2021, Ms. Feldman announced the temporary suspension of compensation determination
offers due to uncertainty about the liquidity of Estate assets to fund the Program. This week, the Estate
notified Ms. Feldman that it had completed the sales of Jeffrey Epstein's New York City and Palm Beach
residences, and transferred approximately $10,000,000 to the Program to satisfy the outstanding amount of
the last replenishment request. The Estate also provided assurances to Ms. Feldman, the Probate Court of
the U.S. Virgin Islands (where Mr. Epstein's estate is being probated), and others that additional funds from
the sales of these properties will be made available to the Program to satisfy future replenishment requests
and pay eligible claims. With these developments, the Administrator has determined that there is sufficient
certainty that eligible claims can be timely and fully paid and has lifted the suspension.
"I am pleased to report that the Program can now resume full operations after this unfortunate and
unexpected month-long delay," said Ms. Feldman. "We have continued to process claims and hold
meetings with claimants in anticipation of the resolution of the Estate's liquidity issue, and will begin
issuing compensation offers immediately. I am eager to continue the important work of this Program, and
remain deeply committed to ensuring that all eligible claimants receive the compensation and validation
they deserve."
To date, the Program has received over 175 claims, far exceeding expectations, and has paid out over $67
million to eligible claimants. Although the deadline to register new claims has passed, those already found
eligible to participate in the Program have through March 25, 2021 to file their claims.
Launched on June 25, 2020, the Program is a voluntary, non-adversarial, confidential claims resolution
program that was established to provide fair and expeditious compensation to victims and resolve their
sexual abuse claims against Jeffrey Epstein and the Epstein Estate. The Program was designed by
nationally recognized independent claims administration experts Ms. Feldman, Kenneth R. Feinberg and
Camille S. Biros with input from victims' attorneys, the Attorney General of the Virgin Islands, the Epstein
Estate and other interested parties. The Program operates independently of the Epstein Estate.
For information about the Program, visit https://www.epsteinvcp.com.
Exhibit C