# FILED TAMARA CHARLES CLERK OF ME COURT # EXHIBIT Palms Professional Building, 9053 Estate Suite 101, St. Villard, VI. 00802 340.779.2564 Telephone | 1.888.316.9269 Fax | [www.kellfer.com](http://www.kellfer.com) September 15, 2020 **By E-Filing** Honorable Carolyn P. Hermon-Percell Superior Court of the U.S. Virgin Islands Magistrate Division Barbell Plaza South St. U.S. Virgin Islands **Re: Estate of Jeffrey E. Epstein** Probate No. ST-19-PB-80 Dear Magistrate Hermon-Percell: We write on behalf of the Estate in response to the Government's September 10, 2020 letter. The Government's letter, as well as the Government's August 18, 2020 letter, is yet further confirmation that the Attorney General is improperly usurping the roles of the Court and the Co-Executors in this probate proceeding. Although the Attorney General's liens are invalid, she is unfairly making use of the fact that there is no assigned judge in that case to rule on the Co-Executors' motions to vacate those liens and dismiss that action. Just as Your Honor directed the Attorney General in February 2020 to lift her liens to allow the Estate to operate, the Court should do so again here, where the Attorney General is crippling the administration of the Estate. The Attorney General's suggestion in her August 18 Letter{sup}`1` that the Co-Executors seek to conceal information about the administration of the Estate is not only unfounded, unfair, and misleading, it is squarely at odds with reality. By making those accusations, the Attorney General not only suggests that the Government is entitled to such information -- it is not -- but also pretends that the Government does not already have that information and that the Co-Executors are improperly seeking to withhold it. That is false: the Attorney General has issued two subpoenas, purportedly as a discovery tool in the Government's ongoing investigation, to FirstBank for records of the Estate's operating account. The first subpoena, served in February 2020, covered the period from 1998 through February 2020. The second subpoena, served in June 2020, called for all records of every transaction conducted from the Estate's operating account from February 1, 2020 through June 30, 2020. Putting aside whether those subpoenas, issued without notice to the Estate, comport with the legitimate exercise of the Government's authority under CICO, they provide the Government with the very information it complains to the Court it needs to release funds for administration of the Estate. The Estate has confirmed that FirstBank produced records for every transaction, of every size, conducted by the Estate from that account through June 30, 2020. For example, the Attorney General, having received and reviewed such records, required FirstBank to provide additional --- {sup}`1` To the extent the Attorney General served her August 18 letter on counsel for the Estate, we are not aware of that service and were not aware of that letter until the Attorney General attached it to her September 10 filing. That is the only reason the Estate did not previously respond to the Attorney General's August 18 letter. Icrrnon-Pcrecll I P. Carolyn Honorable to Letter 2020 15, September 2 Page described were which 2020 June through May period the during transactions 37 for information Attorney the which for transactions These Offset." "ACH as statements account the on generically two \$1,000, than less involving transactions 16 included information additional such required General 37 the of all for detail requested the provided FirstBank \$60. as little as for were which of transactions for information needs she that suggestion General's Attorney the Thus, transactions. by transaction every about information has General Attorney the since disingenuous, is \$5,000 above penny. the to down Estate the criminal Epstein's in participants "protect to trying is Estate the that argues also General Attorney The and of employees former and current certain indemnifying is Estate the because simply enterprise" Attorney The suit. General's Attorney the in defendants more or one of behalf on professionals discovery stay to motion -pending long a has Estate the that fact the Despite backwards. it has General that for plan discovery a adopted not has action that in Court the and suit, General's Attorney the in and individuals of swath a to subpoenas wide-ranging serve to continues General Attorney the matter, and employees former and current as well as action that in defendants certain including entities, accusations false) (and serious leveling for penchant General's Attorney the Given professionals. financial any that belief apparent her and Epstein, Mr. with associated individual any against many act, criminal a constitutes somehow entities various his or Epstein Mr. by conducted transaction counsel. afford cannot Many counsel. need they that determined have employees former and current which representation, legal for fees legal for indemnification requested understandably have many And agency enforcement law government a that troubling deeply is It afford. cannot otherwise they -less scope a of face the in representation legal for opportunity the individuals affording that contends concealment. of act an constitutes investigation enforcement law transactions financial "structured" Indyke -Executor Co that suggestion General's Attorney the Finally, only not is Court the to letter a in accusation baseless a such make To libelous. and false absolutely is an betrays it officer, enforcement law highest Territory's the of unbecoming and unprofessional them prevent to intended -Executors Co the intimidate to General Attorney the by effort ongoing to General Attorney the directed expressly Court the While duties. duciary fi their out carrying from the so, doing in duties duciary fi their exercise and Estate the administer to -Executors Co the permit instructions. Court's the ignoring on intent appears General Attorney to Court the ask urgently we 2020, 9, September and 14 August dated letters our in forth set As Attorney the for Order an issue to alternatively, or matter, this resolve to videoconference a schedule Estate's the in requested amount the in account FirstBank Estate's the on ens li the release to General harm. irreparable suffering of verge the on is Estate The General. Attorney the with correspondence submitted, Respectfully A/C Kroblin -Executors Co the for Counsel record of Counsel cc: