IN THE SETERJOR COURT OF Till: VIRGIN VIANDS FILED September 28, 2020 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. & ST. JOHN TAMARA CHARLES CLERK OF THE COURT CHISLAINE MAXWELL, Plaintiff, v. 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 CIVIL NO. ST-20-CV-155 Defendants. CO-EXECUTORS' REPLY BRIEF IN SUPPORT OF MOTION TO DISMISS DARREN K. INDYKE and RICHARD D. KAHN, by and through their undersigned counsel, 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"), an entity administered in probate by the CoExecutors as part of the Estate, respectfully submit this Reply Brief in further support of their Motion to Dismiss the Complaint filed in this action on May 1, 2020 (the "Motion to Dismiss"). I. MAXWELL'S CLAIM FOR COMMON LAW INDEMNIFICATION IS UNRIPE AND SHOULD BE DISMISSED. Maxwell initially filed her Complaint prematurely in violation of 15 V.I.C. § 606(a). (Motion to Dismiss at 1-2, 4-6.) After forcing the Co-Executors to file the Motion to Dismiss, Maxwell implicitly conceded her error and, on June 1, 2020, jointly moved with the Co-Executors for a stay of this action until the required one-year waiting period had passed. While the Court granted the stay on August 3, 2020, and Maxwell is no longer in violation of section 606(a), her EFTA02822306