Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 1 of 20 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. & ST. JOHN IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN, Deceased. ) ) ) ) ) PROBATE NO. ST-19-PB-80 ACTION FOR TESTATE ADMINISTRATION CO-EXECUTORS' STATUS REPORT ON CONTINUING EFFORTS TO ESTABLISH VOLUNTARY COMPENSATION PROGRAM AND REOUEST FOR RULING Come now the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"). DARREN K. INDYKE and RICHARD D. KAHN. and provide the Court with this Status Report on their continuing efforts to establish an independent and voluntary claims resolution program (the "Program") for purposes ofresolving sexual abuse claims against Jeffrey E. Epstein. deceased. If the Program fails to launch, it will be an extraordinary lost opportunity for eligible claimants to receive compensation and voluntarily resolve their claims of sexual abuse against Mr. Epstein through a confidential, non-adversarial alternative to litigation. And there will be only one culprit: the Attorney General of the Virgin Islands. Despite weeks of negotiation with the Attorney General's representatives who prefer to file misleading "status reports" with the Court rather than engage in actual, good-faith discussions —the Co-Executors are no closer than before to having the Attorney General lift her liens on the Estate's accounts so that the Program can receive funds essential for its operations. The Co-Executors and the Attorney General agree on one point: both now seek a ruling from the Court that will enable the Program to go forward. The Co-Executors disagree, however, on the appropriate issue before the Court. According to the Attorney General, "[her] Office seeks a ruling from this Court as to whether the Program, as proposed, should be approved, or whether additional concessions, as outlined by the Attorney General, and in the better interests EFTA02751802