0 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 REOUEST FOR RULING ON 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 rule on the Expedited Motion for Establishment of a Voluntary Claims Resolution Program ("Expedited Motion") filed on November 14, 2019. The grounds for the requested relief are as follows: 1. The Expedited Motion requests that the Court enter an Order approving establishment of a proposed Epstein Victims' Compensation Program (the "Program") for the purpose of resolving multiple sexual abuse claims against Jeffrey E. Epstein, deceased. 2. The urgency for a ruling on the Expedited Motion cannot be overstated as the window of opportunity to proceed with the proposed Program will likely close without timely action by the Court. 3. As explained in the Expedited Motion, it is in the interests of justice and all parties with an interest in the Estate for independent, nationally recognized claims administration experts to design and implement a mass tort-type program, to achieve fair and expedited resolution of sexual abuse claims filed by numerous claimants in stateside EFTA00065091