IN THE SUPERIORCOIVT 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, LW, a New York Limited Liability Company, Defendants. PLAINTIFF'S OPPOSITION TO DEFENDANTS' MOTION TO DISMISS Plaintiff GHISLAINE MAXWELL ("Plaintiff'), by counsel, pursuant to V.I.R.Civ.P. 12, hereby opposes the Motion to Dismiss' (the "Motion to Dismiss") filed by Defendants DARREN K. INDYKE ("Indyke") and RICHARD D. KAHN ("Kahn") (collectively, the "Co-Executors"), in their capacity as Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), and on behalf of the Estate and NES, LLC ("NES"). L PRELIMINARY STATEMENT Defendants' Motion to dismiss must be denied because its primary basis is now moot and it secondary arguments have no sufficient basis. First, Co-Executors' argument that Plaintiffs claim against them is premature in violation of 15 V.I.0 § 606(a) is no longer viable. While the Co-Executors argue that they may The Motion to Dismiss is cited herein by page number as "MTD." EFTA02822253