IN THE SITEIUOR COURT OF THE VIRGIN ISIANDS FILED March 04, 2022 95:36 PH 51-2 02 1-RV-0 0 005 TAMARA CHARLES CLERK OF THE COURT IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. AND ST. JOHN ********************************* IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN, Deceased. CASE NO: ST-2021-RV00005 Originating Case No: ST-2019-00080 MOTION FOR AWARD OF ATTORNEYS' FEES AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT THEREOF COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Epstein Estate"), DARREN K. INDYKE and RICHARD D. KAHN (the "Co-Executors"), and hereby move this Honorable Court pursuant to 5 V.I.C. § 541 for an award of attorneys' fees incurred by the Co-Executors in their successful opposition to the Government of the Virgin Islands' (the "GVI") Motion to Intervene in the Probate Action pursuant to Rule 24 of the Virgin Islands Rules of Civil Procedure, filed January 23, 2020 (the "GVI Motion to Intervene") and the GVI's Emergency Motion to Immediately Freeze All Assets and Cash on Hand, filed February 4, 2021 (the "GVI Motion to Freeze Assets" and, together with the GVI Motion to Intervene, the "GVI Motions") and the GVI's Appeal and Petition for Review of Magistrate Judge's Orders, filed March 17, 2021 and decided by the Court on February 4, 2022 (the "GVI Appeal"). Counsels' affidavits in support of this motion are submitted herewith. The Co-Executors prevailed on the GVI Motions before the Magistrate Judge and on the GVI Appeal before this Court. In defending against those applications, the Co-Executors incurred $112,216.90 in attorneys' fees. The attorneys' fees sought are fair and reasonable, supported by contemporaneous time entries, and reflect the actual time and labor involved in dealing with the far-reaching implications of the GVI Motions, developing a strategy for EFTA02821599