IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS

DIVISION OF ST. THOMAS & ST. JOHN

***************************

IN THE MATTER OF THE ESTATE OF ) PROBATE NO. ST-19-PB-80

JEFFREY E. EPSTEIN, )
) ACTION FOR TESTATE
Deceased. ) ADMINISTRATION
__________________________________________)

CO-EXECUTORS’ STATUS REPORT ON VOLUNTARY

COMPENSATION PROGRAM AND REQUEST FOR RULING

Come now, the Co-Executors of the Estate of Jeffrey E. Epstein (the “Estate”), DARREN

K. INDYKE and RICHARD D. KAHN, and provide the Court with this Status Report on the

Epstein Victims’ Compensation Program (the “Program”), the independent and voluntary claims

resolution program established by the Co-Executors for purposes of resolving sexual abuse claims

against Jeffrey E. Epstein, deceased.

By Order dated June 2, 2020, the Court granted the Co-Executors’ Expedited Motion for

Establishment of a Voluntary Claims Resolution Program filed on November 14, 2019, and

authorized the Co-Executors to commence the Program’s operations later that month. On June 25,

2020, the Program — designed and implemented by independent, nationally recognized claims

administration experts, with input from interested parties including claimants and their

representatives — officially opened its doors to receive claims for compensation. (See press

release attached as Exhibit A hereto.) To date, forty-seven (47) claimants have submitted their

claims to the Program. Pursuant to the Program Protocol developed by the Program Administrator

in consultation with claimants’ counsel and the Co-Executors, the Program will be accepting

claims until March 25, 2021. (Id. at p. 2.)

Estate of Jeffrey E. Epstein Probate No. ST-19-PB-80
Status Report and Request for Ruling Page 2

The Attorney General of the Unites States Virgin Islands, claimants’ counsel, and the Co-

Executors have agreed that the Program Administrator is to keep the Court regularly apprised of

claims paid by the Estate pursuant to the Program:

“The Program Administrator will confidentially provide to the Attorney General’s

Office and the Virgin Islands Probate Court a monthly accounting of the aggregate
number and total value of claims paid each month but will not identify individual
claimants or claim awards.”

(Agreement Regarding Epstein Victims’ Compensation Program dated May 30, 2020, copy

attached as Exhibit B hereto at ¶ 3.) Although the Program has not yet paid any claims, it has

issued claims determinations to eight (8) individual claimants. 1

On August 3, 2020, the Program Administrator issued her first monthly report on the

Program, providing copies to the Attorney General and the Co-Executors. 2 On September 3, 2020,

the Program Administrator issued her second monthly report on the Program, again providing

copies to the Attorney General and the Co-Executors. In order to maintain the confidentiality of

the Program Administrator’s monthly reports — as agreed by the Attorney General and claimants’

counsel, given the importance of maintaining an effective, confidential (at claimants’ sole

discretion) mechanism to provide compensation to those who suffered sexual abuse at Mr.

Epstein’s hands — the Co-Executors seek the Court’s approval to submit the Program

Administrator’s monthly reports under seal.

WHEREFORE, the Co-Executors request that the Court enter an Order granting the relief

requested herein substantially in the form of the attached proposed order.

1. Pursuant to the Program Protocol, Claimants under the Program have sixty (60) days to determine whether to
accept the Program’s compensation determination offer. (Exhibit C at p. 6.)

2. On August 5, 2020, the Co-Executors provided a copy of the Program Administrator’s first monthly report to the
Special Master approved by the Court in this matter. (See Exhibit D.)
Estate of Jeffrey E. Epstein Probate No. ST-19-PB-80
Status Report and Request for Ruling Page 3

Respectfully,

Dated: September 8, 2020 /s/ Christopher Allen Kroblin

CHRISTOPHER ALLEN KROBLIN, ESQ.
SHARI N. D’ANDRADE, ESQ.
MARJORIE WHALEN, ESQ.
V.I. Bar Nos. 966, 1221 & R2019
KELLERHALS FERGUSON KROBLIN PLLC
Royal Palms Professional Building
9053 Estate Thomas, Suite 101
St. Thomas, V.I. 00802
Telephone: (340) 779-2564
Facsimile: (888) 316-9269
Email: ckroblin@kellfer.com
sdandrade@kellfer.com
mwhalen@kellfer.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 8th day of September 2020, I caused a true and exact

copy of the foregoing Status Report and Request for Ruling to be served via electronic mail

upon:

John H. Benham, Esq. A. Jeffrey Weiss, Esq.

Law Office of John H. Benham, P.C. A.J. Weiss & Associates
P.O. Box 11720 6934 Vessup Lane
St. Thomas, VI 00801 St. Thomas, VI 00802
john@benhamlawvi.com jeffweiss@weisslaw-vi.net

Douglas B. Chanco, Esq. Sean Foster, Esq.

ChancoSchiffer P.C. Marjorie Rawls Roberts, P.C.
3355 Lenox Road, Suite 750 P.O. Box 6347
Atlanta, GA 30326 St. Thomas, VI 00804
doug@csfirm.com sean@marjorierobertspc.com

Richard Bourne-Vanneck, Esq. Kevin F. D’Amour, Esq.

Law Offices of Richard Bourne-Vanneck Gaylin Vogel, Esq.
9800 Buccaneer Mall Suite #9 5143 Palm Passage, 18b & 19b
St. Thomas, VI 00802 St. Thomas, VI 00802
richard@rpvblawoffices.com kevin.damour@comcast.net
gaylin.vogel@comcast.net
Estate of Jeffrey E. Epstein Probate No. ST-19-PB-80
Status Report and Request for Ruling Page 4

John K. Dema Melody D. Westfall, Esq.

Law Offices of John K. Dema Westfall Law PLLC
1236 Strand Street, Suite 103 5032 Anchor Way, Suite 8
St. Croix, VI Christiansted, St. Croix 00820
jdema@demalaw.com mwestfall@westfalllaw.com

Denise N. George, Esq. Rosalie Simmonds Ballentine, Esq.

Attorney General Rosalie Simmonds Ballentine, P.C.
Ariel M. Smith, Esq. P.O. Box 305396
Chief, Civil Division St. Thomas, U.S. Virgin Islands 00803
Virgin Islands Department of Justice roselaw@viaccess.net
34-38 Krondprinsdens Gade
GERS Complex, 2nd Floor J. Russell B. Esq.
St. Thomas, Virgin Islands 00804 The Pate Law Firm
denise.george@doj.vi.gov P.O. Box 370, Christiansted
ariel.smith@doj.vi.gov St. Croix, USVI 0081
pate@sunlawvi.com
Sigrid Stone McCawley, Esq.
David Boies, Esq.
Joshua I. Schiller, Esq.
BOIES SCHILLER FLEXNER LLP
55 Hudson Yards
New York, NY 10001
smccawley@bsfllp.com
bdoies@bsfllp
jschiller@bsfllp.com /s/ Christopher Allen Kroblin
 # # #

ON EMBARGO UNTIL
Thursday June 25, 2020 at 6:30am EST

CONTACT
Jeff Solnet
Jeff@PrecisionStrategies.com
561-926-0909

Renowned Claims Resolution Experts Announce Commencement of the

Epstein Victims’ Compensation Program

New York, NY – Today, individuals who were sexually abused by Jeffrey Epstein may begin the
process of filing claims with the Epstein Victims’ Compensation Program (“Epstein VCP” or
“Program”). The Epstein VCP is a voluntary, non-adversarial, confidential claims resolution program
that has been established to compensate victims-survivors and resolve their sexual abuse claims
against Jeffrey Epstein and the Epstein Estate. The Epstein VCP will operate entirely independently
of the Epstein Estate.

The Program was designed over the last several months by nationally recognized independent
claims administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana (“Jordy”) H.
Feldman (“Co-Designers”) with input from attorneys representing over 70 victims, the Attorney
General of the Virgin Islands, the Epstein Estate and other interested parties. The Program will be
administered by Ms. Feldman (the “Administrator”), the former Deputy Special Master of the
September 11th Victim Compensation Fund, the litigation-alternative program administered by the
U.S. Department of Justice that compensates victims who have become sick or died as a result of
their September 11th-related exposure.

“This Program provides victims of Jeffrey Epstein the opportunity to be heard outside the glare of
public courtroom proceedings, and to receive acknowledgment by an independent third party as to
the legitimacy of their experience and the long-term suffering it has wrought,” said Ms. Feldman.
“Treating victims with dignity and respect and providing them with appropriate compensation is
central to our work with the Program, even as we recognize that no amount of money will erase the
years of pain these victims have endured.”

“These programs are as much about offering validation as providing fair compensation,” said Mr.
Feinberg who, along with Ms. Biros, has designed and administered similar compensation programs
for the Catholic Church sexual abuse claims, the Penn State sexual abuse claims, and the
September 11th Victim Compensation Fund, among others.

The Program provides victims with an attractive alternative to litigation by offering a process that is
speedy and cost-effective. The Program also removes barriers to pursue claims in civil courts,

EXHIBIT A
including statutes of limitations and prior settlements, and applies more relaxed evidentiary
requirements.

Important features of the Program include:

1. The Program is independent of and entirely free from any interference or control by
the Epstein Estate. The Administrator has complete autonomy and decision-making
authority to determine individual claimant eligibility and compensation. The Estate has no
authority to modify or reject the Administrator’s decisions on any basis or as to any claim,
and the Estate will pay all eligible claims based on the Administrator’s determination.

2. The Program is purely voluntary; no individual claimant is required to participate. A

victim’s legal rights are not impacted unless the victim accepts the compensation offered by
the Administrator and signs a release, agreeing not to engage in any further litigation against
the Epstein Estate and related entities and/or individuals.

3. The Program is confidential. Protecting Claimant privacy is of paramount importance to

the Program. The Program will maintain strict confidentiality of all information submitted, but
will not impose any limitations on the Claimant’s ability to share information with law
enforcement, or anyone else.

“Our work with victims of Catholic Church abuse, September 11th and other similar programs has
provided us with invaluable insight into how to calculate the incalculable, and take into account the
life-long effects of trauma,” said Ms. Biros, who co-designed the Program. Mr. Feinberg added,
“The role of the Administrator is to apply a certain level of objectivity while taking into account the
specific circumstances presented by each individual claim. It is a challenging task, but one that
Jordy is uniquely qualified to undertake. Her empathetic and judicious style, and her long-time
claims experience and service to victims in the 9/11 community will serve this Program and
Epstein’s victims well.”

Beginning today, the Administrator will provide a Claim Form and other relevant Program information
to individuals who have filed a lawsuit, legal action or claim of sexual abuse against Jeffrey Epstein
and/or the Estate may begin the process of filing a claim with the Program, or have otherwise been
identified by counsel. Other individuals may also be eligible to participate in the Program by
registering on the Program website. The claims filing period will run through March 25, 2021.

The Program was initially proposed to the Probate Court of the U.S. Virgin Islands (“Probate Court”)
on November 14, 2019. The Co-Designers solicited feedback from various interested parties,
including victims’ counsel, and that feedback was incorporated into a draft protocol that was
presented to the Probate Court on February 4, 2020. The final protocol was approved by the
Probate Court on June 3, 2020.

”We are pleased to get this Program up and running after months of considered and collaborative
design. My staff is deeply sensitive to the unique circumstances involved and is committed to
processing the victims’ claims in a prompt, fair and effective manner,” said Ms. Feldman.
For more information, visit: www.epsteinvcp.com, email ClaimantServices@EpsteinVCP.com or call
the toll-free helpline at (877) 312-3055.
EXHIBIT B
 3

such finds as approved by that Court. Prior to approval by the probate Court * and with the
understanding that the Program Administrator can revisit this subject with the Attonrey General
should these funds be dissipated prior to the Probate Courtos approval of the budget the
Attorney General's Office agrees to release $4 million to pay amounts owed for the program and
-
to begin administration of the Prograrn; the Co-Executors agree rot to assert that the Attomey
General's release of such funds will act as a waiver of any ability by the Government to object
to the Prograrn's artministrative experses, including those paid with these initial funds.

9. With these shanges, for as long as the criminal activity liens remain in place, the
Attorney General's Office agrees that it will exercise its discretion under 14 \IIC 610(r) to release
sufficient frrnds from those liens to allow payment of claims awarded through tbe program as
follows: $25 million will be released 1s n slaims-payment account. Upon notice to the Attomey
General by the Adminishator that the balance of this accormt has fa1len to $10 million or less,
the Attorney General will release sufficient fimds to restore the $25 million threshold balance.
Should the value ofthese payments exceed the aggregate value of the Estate excluding the value
of Little St. James and Great St. James and the tax ircentives obtained by Mr. Epstein estimated
by the Attorney General at $73.1 million, the Attomey General and victims, counsel will confer
with each other and the Co-Executors on tm appropriate resolution to ensure that the objective of
compensating all of Mr. Epstein's victims is accomplished, including securing or releasing
additional assets for the Program. Upon completion of the program, any unusedfunds wi[ b;
retumed to the Estate, subject b any then-existing criminal activity liens.

10. While the Estate will not be required to commig as a condition of latrnching the
Program, to preserving and providing documents to the Attomey General,s Office or releasing
individuals from non-disclosure agreements, the victims and Attomey General urge the Co-
Executors to cooperate fully with the Atiorney General's investigation and litigation.

r 3q: t- ?-s
H. balr- I
Hubbard & Reed LLP
Counsel for Co-Executor Darren K.Indyke

5 30 >o>o
E. Tomback Date
White& Case
Counsel for Co-Executor Richard D. Kahn

Carol Thomas-Jacobs Date

 -

Carol Thomas-Jacobs Date

Deputy Attorney General
V.1. Department of Justice

Bradley J. Edwards Date

Edwards Pottinger, LLC
Counsel for Victims

David Boles Date

Boies Schiller Flexner LLP
Counsel for Victims
 4

Carol Thomas-Jacobs Date

Deputy Attorney General
V.I. Department of Justice

Bradley J. Edwards Date

Edwards Pottinger, LLC
Counsel for Victims

J''j'~ a~ ~~.o
David Boies D e
Boies Schiller Flexner LLP
Counsel for Victims
EXHIBIT C
 Shari D'Andrade <s.dandrade@kellfer.com>

Status Report Exhibit D [COVER EMAIL ONLY w/o ENCLOSURE]

Weiner, Daniel H. <daniel.weiner@hugheshubbard.com> Fri, Sep 4, 2020 at 3:03 PM
To: Chris Kroblin <ckroblin@kellfer.com>, Shari D'Andrade <s.dandrade@kellfer.com>, Marjorie whalen
<mwhalen@kellfer.com>

From: Chris Kroblin <ckroblin@kellfer.com>

Sent: Wednesday, August 5, 2020 3:54 PM
To: Rosalie Simmonds Ballentine, Esq. <roselaw@viaccess.net>
Cc: Shari D'Andrade <sdandrade@kellfer.com>; Weiner, Daniel H. <daniel.weiner@hugheshubbard.com>; Andrew
Tomback <ATomback@mclaughlinstern.com>
Subject: Epstein VCP - Monthly Report

EXHIBIT D
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CAUTION: This email was sent by someone outside of the Firm.

Dear Attorney Ballentine:

We write on behalf of Darren K. Indyke and Richard D. Kahn as Co-Executors of

the Estate of Jeffrey E. Epstein.

The Program Administrator of the Epstein Victims’ Compensation Program,

Jordana Feldman, has asked that the Estate provide to the Probate Court her
attached report concerning the Program’s first month of operations. The Office of
the Attorney General of the United States Virgin Islands, claimants’ counsel and
the Co-Executors have previously agreed that such monthly reports – of which
this is the first -- are to be submitted to the Office of the Attorney General and the
Probate Court on a confidential basis. The Attorney General has already
received her copy directly from the Program Administrator; to the extent you
provide it to Judge Hermon-Percell and others at the Probate Court, we
respectfully ask on behalf of all concerned that you maintain the confidentiality of
that report.

On a related matter, we request your assistance as soon as possible in resolving

the unfortunate, continuing difficulties the Co-Executors are experiencing as the
result of the Attorney General’s refusal to allow for the regular administration of
the Estate, including its day-to-day operations and essential maintenance of Mr.
Epstein’s former residences and equipment located in the Virgin Islands, New
York City, New Mexico, Palm Beach and Paris. While the Co-Executors have
tried since July 8, 2020 to resolve this issue through provision of financial
information requested by the Office of the Attorney General, those efforts have
regrettably proved fruitless. Please let us know when you are available to discuss
this important matter.

Respectfully submitted,

Christopher Allen Kroblin

Member

KELLERHALS FERGUSON KROBLIN PLLC

Royal Palms Professional Building

9053 Estate Thomas, Suite 101

St. Thomas, VI 00802

Direct: 340.201.0955

Office: 340.779.2564 x113 (Alternate number 917-768-0806)

Fax: 888.316.9269

Email: ckroblin@kellfer.com

www.kellfer.com

Of Counsel to:

Solomon Blum Heymann LLP

40 Wall Street, 35th Floor

New York, NY 10005

Telephone: (212) 267-7600

www.solblum.com

Notice: This communication may contain privileged or other confidential information. If you are not the intended recipient, or believe that you have
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Daniel H. Weiner | Partner

Co-Chair, Litigation Department

Hughes Hubbard & Reed LLP

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