IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS a C DIVISION OF ST. THOMAS & ST. JOHN O Py HHRKKKEKEREERERERER EER EREEREEREEK IN THE MATTER OF THE ESTATE OF ) | PROBATE NO. ST-19-PB-80 JEFFREY E. EPSTEIN, ) ) ACTION FOR TESTATE Deceased. } ADMINISTRATION ) _ ) REQUEST FOR IMMEDIATE HEARING OR CONFERENCE REGARDING EXPEDITED MOTION FOR EST. Vi LAIMS 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, deceased. 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

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Estate of Jeffrey E. Epstein Probate No. ST-19-PB-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

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Estate of Jeffrey E. Epstein Probate No. ST-19-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. Il. 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

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Probate No, ST-19-PB-80 Estate of Jeffrey E. Epstein Page 4 Request for Immediate Hearing or Conference 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 “t/ 4 * CHRISTOPHER ALLEN KROBLIN, ESQ. ANDREW W. HEYMANN, ESQ. WILLIAM L, BLUM, ESQ. SHARIN. D’ANDRADE, ESQ. MARJORIE WHALEN, ESQ. V.L Bar Nos. 136, 966, 1221 & R2019 LC t. Thomas, Telephone: Facsimile: Email: EFTA00100677

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Estate of Jeffrey E. Epstein Probate No. ST-19-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. iil H. Benham, P.C. Douglas B. Chanco, Esq. ChancoSchiffer P.C. A. Jeffrey Weiss, Esq. A.J. Weiss & Associates Vv 2 Richard P. Bourne-Vanneck, Esq. Sean Foster, Esq. ee = Roberts, P.C. St. Thomas, VI 00804 95703462_1 EFTA00100678

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FOR IMMEDIATE RELEASE November 14,2019 Administrator Jordana H. Feldman Announces Proposed Establishment of the Epstein Victims’ Compensation Program Jordana (“Jordy”) H. Feldman, Kenneth R. Feinberg and Camille S. Biros today announced that the Co-Executors of the Estateof Jeffrey E. Epstein (“Estate”) have filed documents in the Superior Courtof the U.S. Virgin Islands, secking expedited approval from the Court for the establis hment ofa voluntary claims resolution programthatwill allow eligible individuals the opportunity to resolve theirsexual 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 fashioning similar claims programs — will lead the design of the program, including developing criteria and requirements forthe evaluation and determination of eligibility and compensation, and the accompanying claims process. Ms. Feldman, Mr. Feinberg and Ms. Biros will draft the programprotocoland will afford interested parties, including potential claimants and/or their legal representatives, an opportunity to provide input onthe protocol prior to its finalization. They expect that, once approved by the Court, the program will start accepting claims in approximately 90 days. “This important program will offer victims the opportunity to obtain long-overdue compensation, to be heardand treated with the compassion, dignity and respect they deserve, and to achieve some measure of justice and validation that has eluded them forso many years. The claims resolution process will be fair, prompt, and non-adversarial, and will provide victims with a meaning ful altemative to years of protracted civil litigation and its associated costs, risks and uncertainties,” said Ms. Feldman. Ms. Biros added that “participation in the program will be entirely voluntary and willnot affect any rights theclaimant may have unless and until sheaccepts the compensation determination and signs a litigation release. Allclaimants will be afforded an opportunity to meet confidentially with the Administrator, if they so desire, in order to provide any information that may bear upon the evaluation of their claims.” Ms. Feldman, who recently served as Deputy Special Master of the September | Ith Victim Compensation Fund, the litigation- altemative programadministeredby the U.S. Department of Justice that compensates victims who havebecome sick or died as a result of their September | 1th-related exposure, will also administer the new program. Ms. Feldman will, in the role of Administrator, have complete autonomy and decision-making authority over program operations and claimdeterminations, and the Estate will have no authority to modify orreject Ms. Feldman’s decisions on any basis oras to any claim. Mr. Feinberg, the nation’s leading expert in fashioning effective dispute resolution altematives, and his colleague, Ms. Biros, will partner with Ms. Feldman in the deve lopment and implementation of the program, lending theirextensive expertise to that process. Mr. Feinberg added, “Weare pleased to have been asked to implement this important program, and are eager to begin designing it so that claimants will have a forum where their suffering is acknowledged and their claims are promptly and appropriately compensated.” Regarding Ms. Feldman he said, “Jordy brings not only a wealth of experience fromher long -time work with the 9/11 community, butalso aprofound senseofempathy for victims and a deepcommitment to ensuring fairness in process and outcome.” Once approved, the program will operate and maintain a website thatprovides general information about the program, including the Protocol, Frequently Asked Questions, information aboutclaims filing deadlines and a registration process fornew complaints. Contactinformation for the programwill also be available on the website. Formedia inquiries about theprogram, contact Malisa L. Haley at MLHaley(@MLHaleyConsulting.com or 877-312-3055. Malisa L. Haley Chief of Staff Esptein Victims’ Compensation Fund 877-312-3055 mihale y@mlhale vconsultine.com F) EXHIBIT EFTA00100679

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DIVISION OF ST. THOMAS & ST. JOHN REKKEKERERERKREREREREREEEEEREREEER IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS aj C " ) IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN, PROBATE NO. ST-19-PB-80 ACTION FOR TESTATE ADMINISTRATION Deceased. 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 ORDERED that a copy of this Order shall be directed to counsel of record. Dated: CAROLYN P. HERMON-PERCELL Magistrate Judge of the Superior Court of the Virgin Islands ATTEST: ESTRELLA H. GEORGE Clerk of the Court BY: Court Clerk Supervisor / / EFTA00100680