IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN CIVIL CASE NO.: 012P'41-156. GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN, DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY F.. EPSTEIN, RICHARD D. KAHN, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, and NES, LLC. a New York Limited Liability Company, Defendants. COMPLAINT ; -;.t.;;;Nt ; 1U1103 ra :X 2 THIS.\O11/). 7. ['his i; ;in action thr indemnilleativo thr and ad\ anc n cnt of the attorneys' fees. security costs. costs to Iln. safe accommodation. and all other expenses N'lax‘‘ell has reasonably incurred and will incur by reason of her prior employment relationship with Jeffrey E. Epstein ("Epstein') and his affiliated businesses in connection with any threatened, pending, or completed EFTA00094890 CIVIL CASE NO.: Page 2 of 10 suit, proceeding, or investigation relating to Epstein, his affiliated businesses, and his al