EXHIBIT 16¶
March 12, 2020 TAMARA CHARLES CLERK OF THE COURT¶
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. [REDACTED] AND ST. JOHN¶
TER OF THE ESTATE ) OF JEFFREY E. EPSTEIN, ) Deceased. )¶
PROBATE NO. ST-19-PB-80-¶
ACTION FOR TESTATE ADMINISTRATION¶
[Handwritten stamps and markings]¶
CREDITOR’S CLAIM FOR UNLIQUIDATED DAMAGES¶
Claimant Jane Doe 981 presents and files this Creditor’s Claim for unliquidated damages against the Estate of Jeffrey E. Epstein (“Estate”):¶
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- Claimant’s claim for unliquidated damages arises out of Jeffrey E. Epstein’s sexual assault, sexual abuse and battery of Claimant.
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- Beginning in 2004, and continuing for years thereafter, Epstein trafficked, assaulted, and abused Claimant at his homes in New York and the U.S. Virgin Islands, causing Claimant severe physical and emotional trauma and distress.
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- Claimant has a right to money damages, whether in form of a judgment or liquidated damages, and has an equitable lien on all unencumbered assets of the Estate.
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- Claimant’s claims for sexual assault, battery and intentional infliction of emotional distress are timely. New York law provides that a plaintiff shall have at least one year from the termination of a criminal action against the same defendant to bring a civil action based on the same facts or occurrences as the criminal action. See NY CPLR § 215(8)(a). A criminal action against Epstein was terminated on August 29, 2019. A claim under Virgin Islands law is also timely under the doctrine of equitable tolling.
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- This Claim is verified by the Affidavit of Claimant, which is attached as Exhibit 1.
Creditor’s Claim for Unliquidated Damages In the Matter of the Estate of Jeffrey E. Epstein, ST-19-PB-80 Page 2¶
The Affidavit is redacted to conceal the identity of Claimant at this time.¶
- Claimant moves this Court to permit her to proceed by pseudonym at this point in the proceedings.
WHEREFORE, Claimant Jane Doe 981 asks this Court to enter judgment against the Estate in an amount sufficient to compensate her for her injuries, along with interest, attorney’s fees and punitive damages.¶
DATED: March 12, 2020¶
By:¶
CERTIFICATE OF SERVICE¶
I HEREBY CERTIFY that on March 12, 2020, I caused a true and correct copy of the foregoing document to be sent to the following via U.S. Mail and via email.¶
[REDACTED] A. Kroblin, Esq. Andrew W. Heymann, Esq. William L. Blum, Esq. Shari N. D’Andrade, Esq. Marjorie Whalen, Esq. KELLERHALS [REDACTED] KROBLIN PLLC [REDACTED] Palms Professional Building 9053 Estate [REDACTED], Suite 101 St. [REDACTED], V.I. 00802-3602¶
John K. Dema Law Offices of John, K. Dema 1236 Strand Street, Suite 103 Christiansted, VI 00820 jdema@demalaw.com¶
A. Jeffrey Weiss, Esq. A.J. Weiss & Associates 6934 Vessup Lane¶
Creditor’s Claim for Unliquidated Damages In the Matter of the Estate of Jeffrey E. Epstein, ST-19-PB-80 Page 3¶
ckroblin@kellfer.com aheymann@solblum.com wblum@solblum.com sdandrade@kellfer.com mwhalen@kellfer.com¶
Darren K. Indyke, Executor¶
Richard Kahn, Executor¶
John H. Benham, Esq. Law Office of John H. Benham, P.C. P.O. Box 11729 St. [REDACTED], VI 00801 john@benhamlawvi.com¶
Douglas B. Chanco, Esq. ChancoSchiffer P.C. 3355 Lenox Road, Suite 750 Atlanta, GA 30326 doug@csfirm.com¶
Richard Bourne-Vanneck, Esq. Law Offices of Richard Bourne-Vanneck 9800 Buccaneer Mall Suite #9 richard@rpvblawoffices.com¶
Gloria Allred, Esq. ALLRED, MAROKO & GOLDBERG 305 Broadway, Suite 607 New York, NY 10007¶
Denise N. [REDACTED], Esq. Attorney General Ariel M. [REDACTED], Esq. Chief, Civil Division Virgin Islands Department of Justice 34-38 Krondprinsdens Gade GERS Complex, 2nd Floor St. [REDACTED], VI 00804¶
Sean [REDACTED], Esq. Marjorie Rawls [REDACTED], P.C. P.O. Box 6347 St. [REDACTED], VI 00804 sean@marjorierobertspc.com¶
Kevin F. D’Amour Gaylin Vogel, Esq. 5143 Palm Passage, 18b & 19b kevin.damour@comcast.net¶
Melody D. Westfall, Esq. Westfall Law PLLC 4032 Anchor Way, Suite 8 Christiansted, VI 00820 mwestfall@westfalllaw.com¶
Mariann Meier Wang, Esq. Daniel Mullkoff, Esq. CUTI HECKER WANG LLP 305 Broadway, Suite 607 New York, NY 10007 mwang@chwllp.com dmullkoff@chwllp.com¶
Marina Leonard¶
IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. [REDACTED] AND ST. JOHN¶
IN THE MATTER OF THE ESTATE OF ) JEFFREY E. EPSTEIN. ) Deceased ) _____ )¶
PROBATE NO. ST-19-PB-80¶
AFFIDAVIT OF JANE DOE 981¶
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[REDACTED] aka Jane Doe 981, being first duly sworn on oath, depose and say:
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- I have reviewed my Creditor’s Claim for Unliquidated Damages against the Estate of Jeffrey E. Epstein in which I am identified as Jane Doe 981. The facts set forth therein are true and correct to the best of my knowledge.
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- Although unliquidated at this time, compensation for my claim is due from the Estate of Jeffrey E. Epstein. No payments have been made thereon, and no counterclaim has been filed to my knowledge.
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- I will submit a detailed Affidavit at such time as this Court permits me to proceed as Jane Doe 981. The Affidavit will present the factual details in support of my Creditor’s Claim for Unliquidated Damages in this case.
Further the Affiant sayeth not.¶
I have read the foregoing affidavit which consists of one (1) page, including this page. I swear that the foregoing affidavit is true and correct to the best of my information, knowledge, and belief. This affidavit is signed on 11 day of March 2020 in Beverly Hills, California under oath and penalty of perjury of the laws of the United States.¶
Jane Doe 981¶
_____ Jane Doe 981, Affiant/Claimant¶
[REDACTED]¶
_____ [REDACTED] Affiant/Claimant¶
A notary public or other officer completing this certificate verifies only the identity of the individual who signed the document to which this certificate is attached, and not the truthfulness, accuracy, or validity of that document.¶
State of California County of Los Angeles¶
Subscribed and sworn to (or affirmed) before me on this 11th day of March, 2020, by [redacted]¶
_____, proved to me on the basis of satisfactory evidence to be the person(s) who appeared before me.¶
(Seal)¶
Signature Kristina E. Grigorian¶