Ariel M. Smith
PersonRelationship Network
064-01.pdf
This document is a Notice of Entry of Order from the Superior Court of the Virgin Islands regarding the Estate of Jeffrey Epstein. The order, signed by Magistrate Judge Carolyn P. Hermon-Percell on June 2, 2020, grants the motion to establish the 'Epstein Victims' Compensation Program' and authorizes the Co-Executors to commence the program on or about June 15, 2020. It references a prior hearing on February 4, 2020, and notes that the USVI Attorney General agreed to lift liens to allow funding for the program.
2023.10.03%20Response.pdf
In this May 2023 filing to the Superior Court of the Virgin Islands, a pro se incarcerated Ghislaine Maxwell requests a 180-day stay in her civil suit for indemnification against the Estate of Jeffrey Epstein. Maxwell argues she needs time to find new counsel following her previous attorney's withdrawal, citing severe communication restrictions and lack of access to legal resources (computers, state case law) within FCI Tallahassee. She also argues the civil case should be paused pending the outcome of her criminal appeal (2nd Circuit Case 22-14626-CR) and cites a 2002 lawsuit (Shanks v. Wexner) as evidence that Epstein historically indemnified her for legal costs.
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.
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.
2022.08.02%20Memorandum%20Of%20Law.pdf
This document is a Supplemental Brief filed on August 1, 2022, by the Co-Executors of the Estate of Jeffrey Epstein (Indyke and Kahn) in the Superior Court of the Virgin Islands. The brief supports a Motion to Dismiss Ghislaine Maxwell's complaint seeking indemnification from the Estate. The Co-Executors argue that because Maxwell was convicted of intentional criminal acts (sex trafficking and conspiracy) in the Southern District of New York on June 29, 2022, public policy prohibits enforcing any contract or equitable doctrine that would indemnify her for the financial consequences of her crimes.
2022.08.01%20Brief.pdf
This document is a legal brief filed by Ghislaine Maxwell in the Superior Court of the Virgin Islands against the Estate of Jeffrey Epstein. Maxwell argues that Virgin Islands public policy does not prevent her from seeking indemnification (reimbursement) for legal fees and security costs incurred due to her employment with Epstein, despite her criminal conviction in New York (SDNY). She asserts claims based on contract promises, common law joint tortfeasor indemnity, and corporate indemnity laws regarding her role at NES, LLC.
2021.12.07%20Notice%20of%20Entry%20of%20Judgment.pdf
This document is a Notice of Entry of Order from the Superior Court of the Virgin Islands filed on December 7, 2021. It pertains to three consolidated cases involving the Government of the USVI, the Estate of Jeffrey Epstein (with Darren K. Indyke as executor), and Ghislaine Maxwell (seeking indemnification). The notice lists numerous recipients, including judges and attorneys involved in the proceedings.
2021.04.13%20Reply%20Motion.pdf
This document is a 'Plaintiff's Reply to Co-Executors' Brief' filed on April 13, 2021, in the Superior Court of the Virgin Islands by Ghislaine Maxwell's legal team. Maxwell argues that her indemnification case against the Estate of Jeffrey Epstein should not be transferred to the Complex Litigation Division nor assigned to the same judge handling the 'CICO action' (Government v. Indyke). She asserts that her case does not meet the criteria for complex litigation and shares no common facts or claims with the government's racketeering case against the executors.
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.
2021.03.17%20Notice%20of%20Entry%20of%20Judgment.pdf
A 'Notice of Entry of Order' filed on March 17, 2021, in the Superior Court of the Virgin Islands (Case ST-2020-CV-00155). The document notifies attorneys Kyle R. Waldner, Christopher A. Kroblin, and Ariel M. Smith that an order was entered in the debt case between Plaintiff Ghislaine Maxwell and the Defendants, the Estate of Jeffrey E. Epstein.
2020.07.30%20Stipulation%20For%20Extension%20of%20Time.pdf
This document is a legal stipulation filed on July 30, 2020, in the Superior Court of the Virgin Islands (Case ST-20-CV-155). It represents an agreement between Ghislaine Maxwell (Plaintiff) and the Government of the U.S. Virgin Islands (Proposed Intervenor) to extend the deadline for Maxwell to respond to the Government's Motion to Intervene until August 17, 2020. The document lists the Estate of Jeffrey Epstein and his executors, Darren K. Indyke and Richard D. Kahn, as defendants.
2020.07.13%20Motion%20to%20Intervene.pdf
This document is a Motion to Intervene filed by the Government of the US Virgin Islands in a civil case brought by Ghislaine Maxwell against the Estate of Jeffrey Epstein. The Government seeks to intervene to prevent Maxwell from using the Estate's assets to pay for her legal defense (indemnification), arguing that those assets should be preserved to satisfy a potential judgment in the Government's separate CICO (racketeering) lawsuit against the Estate. The document details Maxwell's evasion of subpoenas prior to her arrest, the Government's interest in the Estate's assets for victim restitution and penalties, and the allegation that Maxwell and the Estate are colluding rather than being true adversaries. While flight logs are mentioned as existing evidence of trafficking, no specific flight records are contained within this specific motion.
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.
2022.03.04%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.
050.pdf
This document contains a letter from Troutman Sanders LLP to Judge Debra Freeman in the SDNY, dated June 3, 2020, informing the court that the Superior Court of the Virgin Islands has officially authorized the establishment of the Epstein Victims' Compensation Program. Attached is the official Order from the USVI court (signed by Judge Hermon-Percell) granting the motion to establish the program and authorizing its commencement on June 15, 2020. The document notes that the USVI Attorney General has agreed to lift liens to allow funding for the 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.
059.pdf
This document is a legal filing from June 3, 2020, submitted by Troutman Sanders LLP to the SDNY Court. It informs Judge Freeman that the Superior Court of the U.S. Virgin Islands has officially granted the motion to establish the 'Epstein Victims' Compensation Program.' The attached exhibit is the Order from the USVI court, signed by Magistrate Judge Carolyn P. Hermon-Percell, authorizing the Co-Executors (Indyke and Kahn) to commence the program on or about June 15, 2020, following an agreement with the USVI Attorney General to lift liens to fund the program.
Representation
Notified Government that Maxwell retained him regarding subpoenas.
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