IN THE SUPERIORCOIGT OF THE VIRGIN ISLANDS FILED September 08, 2020 TAMARA CHARLES CLERK OF THE COURT IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS AND ST. JOHN DIVISION OF ST. CIVIL CASE NO.: ST-20-CV-155 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. PLAINTIFF'S OPPOSITION TO MOTION TO INTERVENE Plaintiff GHISLAINE MAXWELL ("Plaintiff), by counsel, pursuant to V.I.R.Civ.P. 24, hereby opposes the Motion to Intervene' (the "Motion to Intervene") filed by nonparty, the Government of the United States Virgin Islands (the "Government"). L PRELIMINARY STATEMENT The Motion to Intervene must be denied because it is procedurally defective and the Government has no sufficient basis to intervene in this case. The Government seeks to intervene for two reasons. First, it vaguely seeks to "ensure that the Epstein Estate's assets are not wrongfully dissipated," without articulating how it proposes to do so. GVI Mtn. at 2. Second, it asks this Court to enforce its unserved criminal CICO Subpoenas to Plaintiff and, more generally, to investigate Plaintiff in order to establish a predicate for future criminal charges I The Government Motion to Intervene is cited herein by page number as "GVI Mm." EFTA02822203