Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 1 of 17 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS AND ST. JOHN DIVISION OF ST. ******************************** IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN, Deceased. PROBATE NO. ST-19-PB-80 ACTION FOR TESTATE ADMINISTRATION CO-EXECUTORS' CORRECTIONS TO ATTORNEY GENERAL'S STATUS REPORT ON VOLUNTARY COMPENSATION PROGRAM AND RENEWED REOUEST FOR RULING On March 24, 2020, the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE and RICHARD D. KAHN, asked the Court to grant their Expedited Motion for Establishment of a Voluntary Claims Resolution Program, filed November 14, 2019, and allow the Co-Executors to move forward with that Program as carefully constructed in consultation with claimants' counsel and leading independent claims program experts. The Co-Executors hereby renew their request. Because the Attorney General of the Virgin Islands has no standing in this Court to seek to re-shape the Program to suit her whims — demanding changes that go against the considered views of the Co-Executors, recommendations of nationally recognized experts in the field, and endorsement by multiple claimants' counsel — the Court should reject her continued efforts to undermine the Program. As detailed below, the Attorney General's most recent Status Report (filed April 7, 2020) substantially misrepresents the actual state of affairs regarding the Program, and requires correction. 1. The Attorney General Misrepresents Claimants' Position Regarding the Proeram's Third-Party Release The Attorney General informs the Court that she and claimants' counsel are aligned on rejecting the third-party release (the "Release") that those claimants who elect to receive EFTA02751822