IN THE SITEIUOR COURT OF THE VIRGIN ISIANDS FILED SepterbeT 19, 2023 08:20 n 51-2020-CV-00155 IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS AND ST. JOHN DIVISION OF ST. TAMARA CHARLES CLERK OF THE COURT ********************************* 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'MOTION TO DISMISS FOR FAILURE TO PROSECUTE OR, ALTERNATIVELY, TO COMPEL HER TO APPEAR PRO SE 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 (collectively, "Defendants"), respectfully submit this motion to dismiss for failure to prosecute, pursuant to Virgin Islands Rule of Civil Procedure 41(b), or alternatively to compel Plaintiff to appear pro se so that the action may proceed so that the pending motion to dismiss can be adjudicated. PRELIMINARY STATEMENT 14411959 EFTA02822421