Andrew W. Heymann

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2022.09.08%20Notice%20of%20Entry%20of%20Judgment.pdf

A Notice of Entry of Order from the Superior Court of the Virgin Islands filed on September 8, 2022. The document concerns a debt action (Case ST-2020-CV-00155) brought by Ghislaine Maxwell against the Estate of Jeffrey Epstein, his executors (Indyke and Kahn), and NES, LLC. The notice informs the listed attorneys that an order dated September 7, 2022, has been entered into the record.

Legal notice (notice of entry of order)
2025-12-26

2022.08.09%20Notice%20Of%20Entry.pdf

This document is a Notice of Entry of Order from the Superior Court of the Virgin Islands, dated August 9, 2022. It concerns case ST-2020-CV-00155, a debt action filed by Ghislaine Maxwell against the Estate of Jeffrey E. Epstein. The notice informs legal counsel that an order was entered on that date.

Court document - notice of entry of order
2025-12-26

2020.09.28%20Response%20to%20Opposition.pdf

This is a Reply Brief filed by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in response to a lawsuit by Ghislaine Maxwell. Maxwell is suing the Estate and NES, LLC for indemnification (payment of her legal fees) related to her criminal and civil cases in New York. The Co-Executors argue the case should be dismissed because: 1) The claim is 'unripe' as her underlying guilt or innocence hasn't been established; 2) Public policy forbids indemnifying criminal conduct; 3) The NES Operating Agreement explicitly allows the company to decline indemnification; and 4) The Statute of Frauds bars claims based on alleged oral promises.

Legal brief (co-executors’ reply brief in support of motion to dismiss)
2025-12-26

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

This document is a legal response filed by the Co-Executors of Jeffrey Epstein's estate (Indyke and Kahn) on March 29, 2021, opposing the US Virgin Islands Government's appeal regarding their failed motion to intervene in probate proceedings. The executors argue the Government's petition is untimely as the original motion was denied over a year prior, and that the Government's emergency motion regarding estate assets is moot because the estate has replenished the Victims' Compensation Program funds. Attached exhibits include the original 2020 opposition brief and a March 2021 press release confirming the sale of Epstein's NYC and Palm Beach properties to fund the compensation program.

Legal filing (superior court of the virgin islands) with exhibits
2025-12-26

030.pdf

This document contains a letter from Troutman Sanders LLP to Judge Debra C. Freeman updating the court on the establishment of the Epstein Victims' Compensation Program. It attaches a Status Report filed in the Superior Court of the Virgin Islands and the detailed Protocol for the Independent Epstein Victims' Compensation Program, which outlines eligibility, claims administration, evaluation methodology, and compensation procedures for sexual abuse victims of Jeffrey Epstein.

Legal correspondence and court filing (status report and program protocol)
2025-12-26
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