IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN ******************************** IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN, Deceased. PROBATE NO. ST-19-PB-80 ACTION FOR TESTATE ADMINISTRATION REQUEST FOR IMMEDIATE HEARING OR CONFERENCE REGARDING EXPEDITED MOTION FOR ESTABLISHMENT OF A VOLUNTARY CLAIMS RESOLUTION PROGRAM COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE AND RICHARD D. KAHN, and request that this Honorable Court set an immediate hearing or an in-chambers conference with regard to the pending Expedited Motion for Establishment of a Voluntary Claims Resolution Program ("Expedited Motion"), filed on November 14, 2019. Immediate Court action is needed to approve establishment of a proposed Epstein Victims' Compensation Program (the "Program") for the purpose of resolving multiple sexual abuse claims against Jeffrey E. Epstein, dereased. The grounds for the requested relief are as follows: Without the Court's immediate action, the Program cannot move forward. The independent, nationally recognized claims administration experts proposed by the Estate will not be able to design and implement the Program, to the extraordinary detriment of numerous claimants (now twenty-six different women, with more expected) who seek the fair and expeditious resolution of their claims of sexual abuse. In this matter, justice delayed will truly be justice denied. EFTA00100674 Estate offeJj5-ey E. Epstein Probate No. ST-I9-P8-80 Request for Immediate Hearing or Conference Page 2 I. FACTS IN SUPPORT OF MOTION 1. Mr. Epstein died in New York on August 10, 2019. On August 15, 2019, a Petition for Probate and for Letters Testamentary was filed with the Court. On September 6, 2019, the Court issued Letters Testamentary appointing Messrs. Indyke and Kahn to act as Co-Executors for the Estate. 2. On November 14, 2019, the Co-Executors filed the Expedited Motion seeking the Court's approval to retain three independent, nationally recognized claims administration experts — Jordana Feldman, Kenneth Feinberg and Camille Biros — to design and implement a mass tort-type program to achieve the fair and expedited resolution of sexual abuse claims filed by numerous claimants against the Estate. As noted by the Co-Executors in their Request for Ruling on Expedited Motion for Establishment of a Voluntary Claims Resolution Program, filed December 4, 2019 ("Request for Ruling"), there are now 17 separate lawsuits pending against the Estate, involving allegations by twenty-six different plaintiffs of Mr. Epstein's sexual abuse. Moreover, last month attorneys for women who have sued the Estate announced in New York federal court that "[p]otentially dozens" of additional lawsuits can be expected. See Request for Ruling Ex. A, Status Conf. Tr. (November 21, 2019), at 38:7-14. 3. Additionally, on November 14, 2019, Ms. Feldman, Mr. Feinberg and Ms. Biros publicly announced the filing of the Expedited Motion. See "Administrator Jordana M. Feldman Announces Proposed Establishment of the Epstein Victims' Compensation Program," (November 14, 2019), copy attached hereto as Exhibit A. The proposed Epstein Victims' Compensation Program has received widespread publicity in the national press, and several United States federal judges have publicly recognized the significance of that Program. EFTA00100675 Estate of Jeffrey E. Epstein Probate No. ST- I9-PB-80 Request for Immediate Hearing or Conference Page 3 4. On December 12, 2019, Ms. Feldman, Mr. Feinberg and Ms. Biros informed the Co-Executors that, without Court action on the Expedited Motion, they cannot move forward with the Program. In particular, they cannot engage critically necessary third-party vendors (e.g., information technology specialists and claims processing experts), cannot retain critical staff (including attorneys, claims evaluators and operational staff), and cannot lease or outfit space essential to house the Program's operations and staff, or perform other necessary Program-related activities. H. NEED FOR IMMEDIATE ACTION By the Expedited Motion, the Co-Executors seek the Court's authorization to use Estate funds to retain the services of the proposed Program Administrator and Program Designers — Ms. Feldman, Mr. Feinberg and Ms. Biros — and authorize the release of payments necessary to ensure the prompt and effective implementation of the Program and design of a Program protocol ("Protocol") to establish a fair, independent claims resolution process. Once the Protocol is developed and finalized — with input sought from claimants and their counsel, as well as other interested parties — the Co-Executors will submit it to the Court for approval and will seek an order to formally commence claims resolution proceedings under the Program. Without the Court's approval of the Expedited Motion, the Program simply cannot proceed. Instead, the multiple litigations in New York will move forward, at full speed and at great expense to the Estate and to claimants. Without an alternative solution in place for resolving claims, those litigations will continue and likely expand, with enormous attendant costs imposed on all parties in cases where a claimant might have alternatively participated in the Program. Out of necessity and responsibility to these parties and to the Estate, action from the Court is imperative. Time is of the essence. EFTA00100676 Estate ofJeffrey E. Epstein Request for Immediate Hearing or Conference Page 4 Accordingly, it is respectfully requested that this Honorable Court set an immediate hearing or in-chambers conference on the Expedited Motion. Respectfully, Dated: December 13, 2019 Probate No. ST-19-PB-80 CHRIST HER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ. WILLIAM I.. BLUM, ESQ. SHARI N. D'ANDRADE, ESQ. MARJORIE WHALEN, ESQ. V.I. Bar Nos. 136, 966, 1221 & R2019 01118S, Telephone: Facsimile: Email: EFTA00100677 Estate of -levy E. Epstein Probate No. ST- I9-PB-80 Request for Immediate Hearing or Conference Page 5 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 13th day of December 2019, I caused a true and exact copy of the foregoing Request for Immediate Hearing or Conference Regarding Expedited Motion for Establishment of a Voluntary Claims Resolution Program to be served via electronic mail upon: John H. Benham, Esq. H. Benham, P.C. Douglas B. Chanco, Esq. ChancoSchiffer P.C. A. Jeffrey Weiss, Esq. A.J. Weiss & Associates Richard P. Boume-Vanneck, Esq. Vanneek Sean Foster, Esq. berts, P.C. St. Thomas, VI 00804 95703162_1 EFTA00100678 FOR IMMEDIATE RELEASE AdministratorJordana H. Feldman Announces Now miler 14,2019 Proposed Establishment of the Epstein Victims' Compensation Program Jorda n a ("Jordy") H. Feldman, Kenneth It Feinberg and Camille S. Biros today announced that the Co-Executors o f the Es tate of Jeffrey E Epstein ("Es tate") have filed documents in the Superior Cou rt of the U.S. Virgin Islands, sedcing expeditedapprovalfrom the Court for the establislunent of a veto ntary claims res o lotion program that will allow eligible individuals the opportunity to resolve their sena' abuse claims against Mr. Epstein and his Estate through a confidential, non-adversarial alternative to litigation. Ms. Feldman, Mr. Feinberg and Ms. Biros — distinguished, independentclaims administration experts with extensive experience in fashioningsimilar claims programs — will lead the design of the program, including developingcriteria and requirements for the evaluationanddeterminationofeligthility and compensation, and the accompanying claims process. Ms. Feldman, Mr. Feinberg and Ms. Biros will draft the prograrnprotocoland will afford interested parties, includingpmential claimants and/or their legal representatives, an opportunity to provide input on the protocol prior to its finalintion. They expect that, once approved by the Court, the program will start accepting claims in approximately 90 days. "This inyonant program will offer victims the opportunity to obtain long-overdue compensation, to be heardandtreated with the compassion, dignity and respect theydeserve, and to achieve some measure ofjustice and validation that has eluded them for so many years. The claims resolution process will be fair, prompt, and non-adversarial, and will provide victims with a meaningful alternative to years of protracted civillitigation and its associatedcosts, risks anduncertainties," said Ms. Feldman. Ms. Biros added th at" panic ipation in the program will be entirely voluntary and will not affect any rights theclaimant may have unless and until she accepts the compensation determination and signs a litigation release. Allclahnantswillbeaffordedan opportunity to meet confidentially with the Administrator, if they so desire, in order to provide any information that may be ar upon the evaluation of their claims." Ms. Feldman, who recently served as Deputy Special M aster o f the September llth Victim CompensationFund, the litigation- alternative prognun adninistered by the U.S. Department °Mist ice that compensates victims who have becotne sick or died as a result of their September Ilth-related eyesore, will also admin ister the new program. Ms. Feldman will, in the role of Administrator, have complete autonomy and decision-making authority overprogramoperations andclaim determinations, and the Estate will have no authority to modify or reject Ms. Feldman's decisions on any basis or as to any claim. Mr. Feinberg, the nation's leading evert in fashioning effective dispute resolutionalternatives, and h is colleague, Ms. Biros, will partner with Ms. Feldman in the development and impkmentation of th e program, lending theircxt ens iveeyertise to that proems. Mr. Feinberg added, "We are pleased to have been as ked to implement this important program and are eager to begin designing it so that claimants will have a forum where their su ffering is acknowledged and theirclains are promptly and appropriately compensated." Regarding Ms. Feldman he said , "Jordy brings not only a wealth of eye rience from her long-time work with the 9/11 co innu nity, but also a profound sense o f empathy for victims and a deep commitment to ensuring fairness in process and outcome." Once approved, the prograinwill operate and maintain a website that provides general information about the program, including the Protocol, Frequently Asked Questions, information about claims filing deadlines and a reg is tenon process for new complaints. Contxt info nintio n for the program will also be available on the wcbsite. For media inquiries about theprogram, contact Malls a L Haley at MiHalevta MLHakvConsultinu.canor 877-312-3055. Malisa L Haley Chief of Staff Esptein Victims' Compensation Fund 877-312-3055 Sale vtainlakroonsultine.corn 1 9 EXHIBIT i A EFTA00100679 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS & ST. JOHN ******************************** IN THE MATTER OF THE ESTATE OF ) JEFFREY E. EPSTEIN, ) ) Deceased. ) ) PROBATE NO. ST-19-PB-80 ACTION FOR TESTATE ADMINISTRATION ORDER THIS MATTER is before the Court on the Executors' Request for Immediate Hearing or Conference Regarding Expedited Motion for Establishment of a Voluntary Claims Resolution Program. Having reviewed the Request, the Court will grant the same. Accordingly, it is hereby: ORDERED that a hearing or conference will be held in this matter on at in Dated: ORDERED that a copy of this Order shall be directed to counsel of record. ATTEST: ESTRELLA H. GEORGE Clerk of the Court BY: Court Clerk Supervisor CAROLYN P. HERMON-PERCELL Magistrate Judge of the Superior Court of the Virgin Islands EFTA00100680