Petition for probate of Jeffrey Epstein's estate, August 2019

IN THE SUPERIOR COURT OF THE VIRGIN IS DIVISION OF ST. THOMAS AND ST. JOHN 0************¶

IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN¶

PROBATE NO. ST-19-PB-¶

Copy¶

Deceased.¶

ACTION FOR TESTATE ADMINISTRATION¶

PETITION FOR PROBATE AND FOR LETTERS TESTAMENTARY¶

COME NOW Petitioners DARREN IC INDYKE and RICHARD D. KAHN, Executors¶

of the Estate of Jeffrey E. Epstein, by and through KELLERHALS FERGUSON KROBLIN PLLC, and petition this Honorable Court to grant the instant petition pursuant to V.I. CODE ANN. tit. 15, § 161 and Rule 3 of the Virgin Islands Rules for Probate and Fiduciary Proceedings. In support thereof, Petitioners state the following:¶

• 1. That Petitioners Darren K. Indyke and Richard D. Kahn (“Petitioners’) are citizens of the United States of America and residents of Florida and New York, respectively.
• 2. The original Last Will and Testament of Decedent, dated August 8, 2019, which is attached hereto, appoints Petitioners as Executors of the Estate.
• 3. The Decedent, Jeffrey E. Epstein, died testate on August 10, 2019 in New York, New York, and was domiciled in and a resident of St. Thomas, Virgin Islands at the time of his death, as supported by the copy of Certificate of Death attached hereto.’
• 4. Decedent left certain assets in trust.
• 5. The Decedent died possessed of certain property within the Territory of the U.S. Virgin Islands and within the jurisdiction of the Court as herein described:

The original death certificate, or a certified copy thereof, will be filed with the Court upon Counsel’s receipt of the same.¶

PERSONAL PROPERTY’	VALUE
Cash	56,547,773.00
Fixed Income Investments	$ 14,304,679.00
Equities	$ 112,679,138.00
Aviation Assets, Automobiles and Boats	18,551,700.00
Fine Arts, Antiques, Collectibks, Valuables & Other Personal Property	1BD subject to appraisal/valuation
Hedge Funds & Private Equity Investments	$ 194,986,301.00
10,000 shares of Maple, Inc., a U.S. Virgin Islands ration which holds title to co
	$ 55,931,000.00
10,000 shares of Cypress, Inc., a U.S. Virgin Islands Co oration which holds title to
	$ 17,246,208.00
10,000 shares of Laurel, Inc., a U.S. Virgin Islands Co oration which holds title to
	$ 12,380,209.00
999 shares of SCI JEP, a French Company which holds title to units 47 with mezzanine, 48 and 81 on the 2nd floor, units 63 and 74 on the 5th floor and units 5 and 22 (cellars) in the basement
	$ 8,672,823.00
10,000 shares of Poplar, Inc., a U.S. Virgin Islands Corporation, which holds title to Great St. ames Island
	$ 22,498,600.00
10,000 shares of Nautilus, Inc., a U.S. Virgin Islands Corporation, which holds title to Little St.lames Island
	$ 63,874,223.00
TOTAL PERSONAL PROPERTY:	$ 577,672,654.00
TOTAL ESTATE PROPERTY:	$ 577,672,654.00

² Values are subject to appraisal and/or update to their date of death valuation, which will be confirmed in verified inventory• to be filed with the Court.¶

• 6. Petitioners arc investigating potential debts and claims of the Estate and at this time they are unknown.
• 7. That the names and addresses, insofar as known to Petitioners, of the heirs and next of kin of the deceased, who would be entitled to share the estate if he had left no will; the relation of each such person to him; the proportion due each such person, and whether cach of them is an adult or an infant are as follows:

NAMES	RELATIONSHIP	CAPACITY	SHIM
Mark Epstein	Brother	Adult	100%

• 8. That Petitioners Darren K. Indyke and Richard D. Kahn be appointed Executors. They are adults of sound mind, are not convicted of any crime involving moral turpitude, and arc not judicial officers of this Honorable Court.
• 9. Although Petitioners are not residents of the Virgin Islands, they are qualified to serve as Executors pursuant to 15 V.I.C. § 235(c) because they otherwise qualify under 15 V.I.C. § 235(a) and they have appointed the law firm of Kellerhals Ferguson Kroblin PLLC, which has offices on St. Thomas, Virgin Islands, to accept service of all papers for purposes of the probate of Decedent’s estate.
• 10. The Decedent’s Last Will and Testament provides that “No bond or other security shall be required of any Executor in any jurisdiction.” See original Last Will and Testament attached hereto at Article THIRD, subsection B on page 2. Accordingly, Petitioners pray that the bond be waived pursuant to V.I. R. Prob. 3.

WHEREFORE, Petitioners pray:¶

• A. That the Estate of Jeffrey F. Epstein be entered into Probate;
• B. That a citation be issued to any heir or next of kin who has not signed a Waiver;
• C. That this Honorable Court order the issuance of a notice to creditors and claims procedure order in substantial form of that which will be separately proposed to the court forthwith;
• D. That the Last Will and Testament of Jeffrey E. Epstein, attached hereto, be admitted to Probate;
• E. That Darren K. Indyke and Richard D. Kahn be appointed Executors and Letters Testamentary be issued to them;
• F. That the bond be waived; and
• G. That the Petition be granted.

Respectfully,¶

DATED: August /5- , 2019¶

WILLIAM BLUM, ESQ., Of Counsel V.I. Bar No. 136 KELLERHALS FERGUSON KROBL1N PLLC Royal Palms Professional Building¶

Telephone Facsimile:¶

£state opeffrey Epstein Probate No. ST-19-PB-Petition for Probate and Letters Testamentary¶

VERIFICATION OF PETITION¶

I, Darren K. Indyke, Executor of the Last Will and Testament of Jeffrey E. Epstein, hereby verify I have read and do hereby certify that the statements contained in the Petition for Probate and for Letters Testamentary are accurate in so far as my knowledge and insofar as my own records show.¶

DATED: August IC , 2019 kC”\kid.,i) fkg. Darren K. Indyke¶

SUBSCRIBED AND SWORN to before me¶

this i S day of R., •.) 6. vg-I-, 2019.¶

Probate No. ST-I9-PB-¶

Estate ofJeffrey Epstein Petition for Probate and Letters Testamentary¶

VERIFICATION OF PETITION¶

I, Richard D. Kahn, Executor of the Last Will and Testament of Jeffrey E. Epstein, hereby verify I have read and do hereby certify that the statements contained in the Petition for Probate and for Letters Testamentary are accurate in so far as my knowledge and insofar as my own records show.¶

DATED: August ) 7 , 2019¶

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SUBSCRIBED AND SWORN to before me¶

this t`7+ day of /14/4 t- I4—SIF , 2019. e4gtet,,,L”:, Alva-Ad¶

MARIANNE BARNETT NOTARY PUBLIC, STATE OF NEW YORK NO. 018A6276845 Qualified In Suffolk County Term apices February 25.2021¶