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 alleged victims. PARTIES AND JURISDICTION 2. Plaintiff Ghislaine Maxwell is an adult citizen of the United States. 3. Jeffrey E. Epstein was a resident of the Virgin Islands. The Estate of Jeffrey E. Epstein was created following Epstein's death and is domiciled in the Virgin Islands. 4. Defendant Darrell K. Indyke is an Executor of the Estate. S. Defendant Richard D. Kahn is an Executor of the Estate. 6. Defendant NES, LLC. is a limited liability company organized under the laws of the State of Nen York on or about August 13. 1998. 7. This Court has jurisdiction iaer matter oursannt to 4 V.I.C. $ 74. • .'•-t i • :.roar . .' j :.• ••••:••• • NES I .C. Ncv. JECil:" inc.. and l.. st. Whi1c v.tis rcsp.wt;ibic for ;tannin:4 Epstein's properties, including properties located in Ne York. Paris, Florida. New \lexico. and the U.S. Virgin Islands. I I. During the course of their relationship. including while Maxwell was in Epstein's employ. Epstein promised Maxwell that he would support her financially. EFTA00094891 CIVIL CASE NO.: Page 3 of 10 12. Epstein made these promises to Maxwell repeatedly, both in writing and in conversation. 13. Epstein restated these promises when Maxwell was in the process of leaving Epstein's employ to start a new business of her own. 14. Epstein assured Maxwell that even if her business ventures failed he would support her financially. IS. In approximately 2001, Maxwell began transitioning to a more limited employment role for Epstein and his affiliated businesses. In approximately 2004, Maxwell received a typewritten letter from Epstein with a handwritten note asking Maxwell to remain in Epstein:s employ and promising that no matter what Maxwell chose to do. Epstein would always support Niax‘Nell .t • . IM. stern \tlavxdi and ty.lv.ine:•d lees and sewernem costs incuvreti in conn,:i:ti:o lam, suit Wed H, Stath Ransome against Epstein in 2017 (Jaw Doe 43 v. Epstein. et 01.. I7-cv-00616-JOK 19. Consistent with his repeated promises. Epstein also paid Maxwell's legal bills incurred in connection with a civil suit filed by gainst Epstein in 2009. EFTA00094892 CIVIL CASE NO.: Page 4 of 10 20. Epstein's promise is further evidenced by the fact that Epstein indemnified and advanced legal fees and expenses for a number of other employees in other various lawsuits relating to Epstein, his affiliated businesses, and his alleged victims. 21. Indyke, in his capacity as an Executor of the Estate, also made assurances to Maxwell that Maxwell's legal fees and obligations would be reimbursed by Epstein and the Estate, and that Maxwell's legal fees and expenses would be paid going forward. 22. Indyke told Maxwell that her legal fees would be paid because she would not have incurred any legal expenses but for Epstein's alleged misconduct, and that Epstein's promises would be honored. 23. Epstein was found dead on AtIIILISi 10. 2019 in NO\ York. 14. rin IS. :`.0!() Lid> ke and Ktilr, riled a 2r.! ;.• : ,)1 iast :rsoncd securii, •_r' saft :E nur. •..ati ..... . 27. Maxv1/4ell is entitled to ind..mmilication and advancement of expenses incurred by reason of her employment relationship with Epstein and his affiliated businesses. including attorneys' fees, as well as security costs and costs of finding safe accommodation, all of which are ongoing, extensive, and directly related to the pending suits, proceedings. and investigations EFTA00094893 CIVIL CASE NO.: Page 5 of 10 concerning Epstein's alleged misconduct. These expenses will be ongoing due to the extensive global coverage and interest in these events and proceedings. 28. By letter dated November 22, 2019, Maxwell submitted a claim to the Estate, addressed to Indyke and Kahn, requesting that the Estate honor its obligation to provide indemnification as requested in this action. 29. The Estate has not honored or even formally responded to Maxwell's claim. 30. Maxwell was compelled to file this Complaint because the Estate has not honored her claim for indemnification as requested in this action. 31. Given that Maxwell was forced to seek judicial intervention to vindicate her right to indemnification by the Estate. she is entitled to recover the reasonable tees incurred in this action to :li.tt right. r.hat he prior en,ployment rdationship v. WI him and .31tdiated business . 34. Nlay.vell reasonably and justitiably relied on Epstein's promises and put her trust in Epstein that he would fulfill his promises. 35. As such. Maxwell elected to leave Epstein's employ to pursue her own business ventures because she trusted that Epstein would continue to support her financially. EFTA00094894 CIVIL CASE NO.: Page 6 of 10 36. The Estate has failed to uphold Epstein's promise to indemnify and advance expenses incurred by reason of Maxwell's employment relationship with Epstein and his affiliated businesses. 37. Maxwell's reliance on the Estate's promises was a substantial factor in causing Maxwell harm as alleged herein. 38. For the foregoing reasons, Maxwell is entitled to indemnification and advancement from the Estate of expenses incurred by reason of her employment relationship with Epstein and his affiliated businesses. COLN.'" T1,"O Indetmlification (Common LUNN 39. Plaintiff repeats and realleges the roregying of this Complaint as though or .1.UN I thC:r husim:sses. EFTA00094895 CIVIL CASE NO.: Page 7 of 10 42. The suits, proceedings, and/or investigations for which Maxwell seeks indemnification were instituted against Maxwell solely because she was an employee of Epstein and his affiliated businesses. 43. Maxwell incurred these legal fees and expenses as a direct result of Epstein's acts and/or omissions. 44. For the foregoing reasons. Maxwell is entitled to indemnification and advancement from the Estate of expenses incurred by reason of her employment relationship with Epstein and his affiliated businesses. COUNT TI-IREE Indeinnitication (NES. Lik and (Miter Entities) 45. Plaintiff r:pcats and .,ealk,Jes the allev tions or this coinpluint a, .,how i t ; :•111,. set ihrth . !It's Heurred pet".:>(JIWI. estif4otit,:i; expenses b. reason of her employment relationship with NES. 49. Upon infommtion and belief, as of September 2006. Defendant Kahn 11 as the Comptroller of NES, LLC. EFTA00094896 CIVIL CASE NO.: Page 8 of 10 50. By letter dated November 22, 2019, Maxwell requested indemnification from NES, LLC for the legal fees, personal security costs, and other expenses incurred by reason of her employment relationship with NES, LLC, among other entities, and never received a response. 51. By the same letter dated November 22. 2019, Maxwell requested copies of documents setting forth applicable indemnification and/or advancement rights and policies, including any operating agreements for NES. LLC. and never received a response. P. Maxwell was also employed by several of Epstein's other entities, including. but not limited to, the C.O.U.Q. Foundation, New York Strategy Group, JEGE LLC, JEGE Inc.. and LSJ, LLC. 53. Upon information and belief, the corporate organizational documents or these other entities pro% riy!,.. of indcznHt Maxwell l'or inf.-IA:T.:A by r:nson or her Ii : a:'. .:1 HI' the :.\•\,.i, enritied a-4 adv...n: mcilt ftem LLC. and•or Fstrat. Ap:2mies incosTcci ;ler eniplomtnr, with NES. !.LC. Epstein. andur an\ of his other entitle: With %%bon) Maxwell c as affiliated or employed. EFTA00094897 CIVIL CASE NO.: Page 9 of 10 PRAYER FOR RELIEF WHEREFORE, Maxwell respectfully requests that this Court enter judgment in her favor and against the Estate and grant her the following relief: A. an Order declaring that Maxwell is entitled to indemnification and advancement from the Estate and/or NES, LLC the reasonable attorneys' fees and expenses she has incurred by reason of her employment relationship with Epstein, NES. LLC, and his other affiliated businesses, including attorneys' fees incurred in connection with any threatened, pending. or completed suit. proceeding. or investigation relating thereto, security costs and costs of finding safe accommodation incurred as a result thereof, and all other expenses Maxwell has reasonably incurred and will incur in the future by reason of her prior employment relationship ‘‘ ith Epstein. NES, LLC, and his other :Affiliated Ntisinc.:•,:s: • lOterc•ii . '- • ti:-1 ' ;:tit:re;t: ?chi !;!: and retie. \;•hic:i co.C;! f t qui!..:„ or as this Court mis”. them just and proper. EFTA00094898 CIVIL CASE NO.: Page 10 of 10 Dated: March 12 , 2020 QUINTAIROS, PRIETO, WOOD & BOYER, P.A. Attorne s EFTA00094899