FILED¶
August 05, 2022 03:59 PH¶
51-202 0 -CV-00155¶
TAMARA CHARLES¶
CLERK OF THE COURT¶
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. AND ST. JOHN¶
CIVIL CASE NO.: ST-2020-CV-00155¶
GHISLAINE MAXWELL,¶
Plaintiff,¶
vs.¶
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,¶
Defendants.¶
JOINT NOTICE TO COURT PURSUANT TO ORDER DATED AUGUST 2, 2022¶
Plaintiff GHISLAINE MAXWELL (“Plaintiff), Defendants 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 (collectively, “Defendants”), and Proposed Intervenor GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS (“GVI”) through their respective undersigned attorneys, pursuant to this Court’s Order dated August 2, 2022, advise as follows:¶
- I. Defendants request oral argument on the motion to dismiss. Plaintiff does not waive, and expressly reserves, the right to present oral argument in connection with the motion to dismiss should the Court choose to hear the same.
-
Plaintiff and Defendants request oral argument on the motion to intervene. The GVI does not waive, and expressly reserves, the right to present oral argument in connection with the motion to intervene should the Court choose to hear the same.
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The GVI objects to any request by Defendants to file a response in opposition to the motion to intervene.
-
Plaintiff does not object to any request by Defendants to file a response in opposition to the motion to intervene.
Dated: August 5, 2022 Respectfully submitted:¶
QUINTAIROS, PRIETO, & BOYER, P.A. Attorneys for Plaintiff Ghislaine Maxwell 9300 S. Dadeland Blvd., 4’hFloor Miami, FL 33156 T: (340) 693-0230 F: (340) 693-0300¶
By: Is/ Kyle R. Waldner Kyle R. Waldner, Esq. kwaldner@vwblaw.com V.I. Bar No.: 1038¶
KELLERHALS KRoBLIN PLLC Attorneys for Defendants Estate of Jefferey E. Epstein, Darren K. lndyke in his capacity as Executor of the Estate of Jeffery E. Epstein, and NES, LLC Palms Professional Building 9053 Estate M, Suite 101 St. M, V.I. 00802 T: (340) 779-2564 F: (888) 316-9269¶
By: /s/ Kroblin Kroblin, Esq. ckroblin@kellfer.com V.I. Bar No.: 966¶
C. RHEA, P.C. Attorneys for Defendant Richard D. Kahn 1533 Appling Dr. Mt. Pleasant, S.C. 29464 T: (340) 244-8768¶
By: /s/ C. Rhea C. Rhea, Esq. grhea@rpwb.com V.I. Bar No.:¶
VIRGIN ISLANDS DEPARTMENT OF JUSTICE Attorneys for Proposed Intervenor Government of the United States Virgin Islands¶
DENISE N. ESQUIRE ATTORNEY GENERAL¶
By: /s/ Carol Carol Esq. Arid M. Esq. Assistant Attorneys General Virgin Islands Department of Justice Office of the Attorney General 34-38 Kronprindsens Gade St. M, U.S. Virgin Islands 00802 Tel: (340) 774-5666 Email:¶