IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN CIVIL CASE NO.: ‘51t 3DS . )56 GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN. DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. 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. 18f103 ):101213dflS COMPLAINT Plaintiff GHISLAINE MAXWELL (-Maxwell.), through her undersigned attorneys. by ‘‘a) of her Complaint against Defendants is STA OF JEI FREY I.. LPSTLIN (the "Estate"). DARREN K. INDYKE. in his capacity as Executor of the LSTATI. Of- JEFFREY E. EPSTEIN ("Indykel. RICHARD D. KAHN, in his capacity as Executor or the ESTATE OF JEFFREY E. EPSTEIN (-Kahn"), and NES. LI_C, a New York Limited Liabilit Company ("NES, LLC.), alkgcs as follows: NATURE OF THIS ACTION I. This is an action for indemnification for and advancement of the attorneys' fees. security costs. costs to find safe accommodation, and all other expenses Maxwell 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 EFTA00076593