IN HIE SI PERIOR col Ill O111IE % IRON ISIANDS FILED March 17, 2022 06:09 Pm ST-2021-RV-00005 TAMARA CR ARLES CIIRK OF 'EH t: COL RT IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS AND ST. JOHN DIVISION OF ST. IN THE MATTER OF THE ESTATE OF ) Case No. ST-2021-RV-00005 ) Originating Case No. ST-2019-PB-00080 JEFFREY E. EPSTEIN, Deceased. GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' OPPOSITION TO CO-EXECUTORS' MOTION FOR AWARD OF ATTORNEYS' FEES The Government of the United States Virgin Islands ("Government") hereby responds in opposition to the Motion for Award of Attorneys' Fees brought by the Co-Executors of the Estate of Jeffrey E. Epstein (the "Epstein Estate") (the "Epstein Estate's Motion") regarding the Government's Motion to Intervene in the Probate Action, the Government's Emergency Motion to Immediately Freeze All Assets and Cash on Hand, and the Government's Notice of Appeal and Petition for Review of Magistrate Judge's Orders. The Epstein Estate's Motion is baseless and should be denied. First, the Epstein Estate is not entitled to attorneys' fees, because the underlying orders are not "judgrnent[s]" and the Epstein Estate is not the "prevailing party". Second, even if underlying orders were judgments and the Epstein Estate was the prevailing party—both of which are not true—the Court should exercise its discretion to deny the Epstein Estate's request for attorneys' fees. Requiring the Government to pay the Epstein Estate's attorneys' fees when the Government may ultimately prevail in its claims and is acting as a law enforcement agency to protect the public is contrary to the policy behind section 541. Third, the Epstein Estate's request for over S112,000 in attorneys' fees is extremely unreasonable. EFTA02821851