IN THE SUPERIOR COURT OF THE VIRGIN ISIANDS FILED September 22, 2020 TAMARA CHARLES CLERK OHNE COURT IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. AND ST. JOHN ******************************** 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, ) ) Defendant. ) Case No. ST-20-CV-155 GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS' REPLY BRIEF IN SUPPORT OF MOTION TO INTERVENE The Government of the United States Virgin Islands ("Government"), by and through its undersigned counsel, hereby submits this Reply Brief in support of its motion for an order permitting the Government to intervene in this action as of right pursuant to V.I. R. Civ. P. 24(a) or else by leave pursuant to V.I. R. Civ. P. 24(b). The Government states in further support of its motion as follows. PRELIMINARY STATEMENT The Government moves to intervene in this action by Plaintiff Ghislaine Maxwell seeking indemnification and advancement of legal expenses from Defendants the Estate of Jeffrey E. Epstein and its Co-Executors—Darren K. Indyke and Richard D. Kahn—on two distinct but closely related grounds. First, the Government has an interest in preserving Epstein Estate funds to satisfy a judgment in its pending action against Defendants alleging that Epstein and others EFTA02822271