IN THE SITEIUOR COURT OF THE VIRGIN ISIANDS FILED August 01, 2022 04:45 PH 51-2020-CV-00155 TAMARA CHARLES CLERK OF THE COURT IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS AND ST. JOHN DIVISION OF ST. ********************************* GHISLAINE 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. ESTEIN, and NES, LLC, a New York Limited Liability Company, CIVIL NO: ST-20-CV-155 COMPLEX Defendants. CO-EXECUTORS' SUPPLEMENTAL 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 Supplemental Brief in further support of their Motion to Dismiss the Complaint filed in this action on May I, 2020 (the "Motion to Dismiss") and in accordance with this Court's direction during the March 9, 2022 status conference in this matter. PRELIMINARY STATEMENT As the Co-Executors demonstrated in their Reply Brief in Support of the Motion to Dismiss filed in this action on September 28, 2020 (the "Reply"), courts around the country hold that indemnification for individuals convicted of criminal behavior violates public policy EFTA02822372