Marjorie Whalen
PersonRelationship Network
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.
2021.03.29%20Response%20to%20Order.pdf
This document is a legal brief filed on March 29, 2021, by the Co-Executors of the Estate of Jeffrey Epstein (Darren K. Indyke and Richard D. Kahn) in the Superior Court of the Virgin Islands. The brief argues against designating Ghislaine Maxwell's lawsuit for legal fee indemnification as 'complex' litigation and opposes consolidating it with a separate government 'CICO action' (Case No. ST-2020-CV-00014). The Executors contend that Maxwell's case is a simple single-issue dispute, whereas the CICO action involves complex allegations of a multi-decade criminal enterprise.
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.
2022.12.20%20Motion%20-%20Motion.pdf
This document is a legal motion filed on December 20, 2022, in the Superior Court of the Virgin Islands by the Co-Executors of the Jeffrey Epstein Estate (Darren Indyke and Richard Kahn). They are moving to withdraw a previous motion for attorneys' fees because a resolution was reached in a related case (Govt of USVI v. Epstein Estate et al., ST-2020-CV-00014). The document includes a certificate of service listing government officials and attorneys served with this motion.
2022.03.17-2%20Exhibit%202.pdf
This document is 'Government Exhibit 2' filed in the Superior Court of the Virgin Islands on March 17, 2022. It is a detailed legal billing record totaling $112,216.90 for the Estate of Jeffrey E. Epstein, listing work performed by attorneys (Weiner, Heymann, Kroblin, etc.) to oppose the Virgin Islands Government's motions to intervene and freeze estate assets. The document includes the Government's specific objections to these fees, often citing 'Duplication', 'Block Billing', or 'Unrelated Activity' (specifically referencing the Epstein Victims Compensation Program/Fund).
2022.03.17%20%20Notice%20-%20Notice%20to%20the%20Court.pdf
This document is an opposition brief filed by the Government of the U.S. Virgin Islands against the Epstein Estate's request for over $112,000 in attorneys' fees. The Government argues that the Estate is not a 'prevailing party' because the underlying court orders were not final judgments, and that the requested hourly rates (up to $1,315/hr) are excessive compared to the local standard of $350/hr. The filing also references the Government's broader CICO lawsuit alleging Epstein used his VI businesses to transport and abuse victims on Little St. James Island.
2022.03.04%20Motion%20-%20Motion.pdf
This document is a Motion for Award of Attorneys' Fees filed by the Co-Executors of the Estate of Jeffrey Epstein in the Superior Court of the Virgin Islands. The Co-Executors are requesting $112,216.90 in fees incurred while successfully defending against the Government of the Virgin Islands' (GVI) attempts to intervene in the probate action and freeze estate assets. The document details the history of the GVI's failed motions, the complex nature of the estate, the funding of the Victims' Compensation Program ($121 million+), and justifies the legal fees based on the attorneys' experience and standard rates.
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.
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.
| Date | Type | From | To | Amount | Description | Actions |
|---|---|---|---|---|---|---|
| 2020-01-01 | Received | Estate of Jeffrey... | Marjorie Whalen | $7,623.00 | Total Labor fees. | View |
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