050.pdf

Case 1:19-cv-10476-PGG-DCF Document 50 Filed 06/03/20 Page 1 of 1
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutman.com

Bennet J. Moskowitz
bennet.moskowitz@troutman.com

June 3, 2020

VIA ECF

Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007

Re: Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe, 1:19-cv-07772-ALC-DCF;
Lisa Doe, 1:19-cv-07773 ER-DCF; VE., 1:19-cv-07625-AJN-DCF;
Jane Doe, 1:19-cv-08673-KPF-DCF; Farmer, 1:19-cv-10475-LGS-DCF;
Helm, 1:19-cv-10476-PGG-DCF; Bryant, 1:19-cv-10479-ALC-DCF;
Jane Doe 1000, 1:19-cv-10577-LGS-DCF; Jane Doe 15, 1:19-cv-10653-PAE-DCF;
Mary Doe, 1:19-cv-10758-PAE-DCF; Davies, 1:19-cv-10788-GHW-DCF;
Anastasia Doe, 1:19-cv-11869-AJN-DCF; Jane Doe, 1:20-cv-00484-JGK-DCF

Dear Judge Freeman:

We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the
Estate of Jeffrey E. Epstein (together, the “Co-Executors”), in the above-referenced actions. We
are pleased to inform the Court that, today, the Superior Court of the United States Virgin
Islands entered an order granting the Co-Executors’ Motion to establish the Epstein Victims’
Compensation Program. A copy of the Order is attached hereto.

Respectfully submitted,

/s/ Bennet J. Moskowitz
Bennet J. Moskowitz

cc: Counsel of Record (via ECF)

EXHIBIT
Case 1:19-cv-10476-PGG-DCF Document 50-1 Filed 06/03/20 Page 1 of 3

Case 1:19-cv-10476-PGG-DCF Document 50-1 Filed 06/03/20 Page 2 of 3

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
District of St. Thomas/St. John

In the Matter of the Estate of JEFFREY E. Case Number: ST-2019-PB-00080
EPSTEIN, deceased.
Action: Administration of Testamentary
Estates

NOTICE of ENTRY
of
ORDER

To: Christopher Allen Kroblin, Esq.
Ariel M. Smith, Esq.
John H. Benham, Esq.
Kevin F. D’amour, Esq.
Douglas B. Chanco, Esq.
Kevin Boyle, Esq.
Richard P. Bourne-Vanneck, Esq.
Robert Glassman, Esq.
John K. Dema, Esq.
Denise N. George, Esq.
Melody D. Westfall, Esq.
Sean E. Foster, Esq.
Gaylin Vogel, Esq.
A. Jeffrey Weiss, Esq.

Please take notice that on June 3, 2020
a(n) ORDER
dated June 2, 2020 was entered
by the Clerk in the above-titled matter.

Dated: June 03, 2020

Tamara Charles
Clerk of the Court

By:
Edotcia Thomas-Hodge
Court Clerk

Case 1:19-cv-10476-PGG-DCF Document 50-1 Filed 06/03/20 Page 3 of 3

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
DIVISION OF ST. THOMAS AND ST. JOHN

IN THE MATTER OF THE ESTATE OF:
JEFFREY E. EPSTEIN,
deceased.
)
)
)
)
)
PROBATE NO. ST-19-PB-80
ACTION FOR TESTATE
ADMINISTRATION

ORDER

THIS MATTER is before the Court on the Co-Executors’ Status Report on Voluntary
Compensation Program and Presentation of Program Protocol filed on June 1, 2020, wherein, in
pertinent part, the Co-Executor notify that all interested parties have finalized and are in support of
the protocol for the Epstein Victims’ Compensation Program (hereinafter “the Program”). 1 The
Court having received testimony concerning the Program at the hearing held on February 4, 2020,
and having reviewed said Status Report, it is hereby

ORDERED that the Expedited Motion for Establishment of a Voluntary Claims
Resolution Program filed on November 14, 2019, is GRANTED; and it is further

ORDERED that the Co-Executors are AUTHORIZED to commence the Epstein Victims’
Compensation Program on or about June 15, 2020.

Dated: June 2, 2020

CAROLYN P. HERMON-PERCELL
Magistrate Judge of the Superior Court of the Virgin Islands

ATTEST:
TAMARA CHARLES
Clerk of the Court
By: Edotcia Thomas-Hodge
Court Clerk Supervisor 6/3/2020

CERTIFIED A TRUE COPY
DATE 6/3/2020
TAMARA CHARLES
CLERK OF THE COURT
BY [Signature]
COURT CLERK

1 At the hearing held on February 4, 2020, while the Court did not allow the Attorney General of the U.S. Virgin Islands to intervene, the Court did request the Co-Executors and the Attorney General to resolve their differences concerning the proposed compensation program, which has garnered the support of all interested parties, including claimants’ counsel. The Co-Executors now inform that “[b]ecause the need for the Program has grown increasingly urgent, and with the support of claimants’ counsel and the USVI Attorney General – and because the remaining impediments have been resolved and the interested parties have consented to the Protocol,” they and the Attorney General have reached an agreement in which the latter will promptly lift previously imposed liens to pay amounts owed for the Program and to begin funding the Program’s active operations, including payment of compensation determinations to eligible claimants. Co-Executors’ Status Report on Voluntary Compensation Program and Presentation of Program Protocol, at 6, June 1, 2020.