IN THE SUPERIOR COURT OF THE VIRGIN ISLAND DIVISION OF ST. THOMAS AND ST. JOHN ****************************** IN THE MATTER OF THE ESTATE OF JEFFREY E. EPSTEIN PROBATE NO. ST-19-PB-___ Deceased. ACTION FOR TESTATE ADMINISTRATION # PETITION FOR PROBATE AND FOR LETTERS TESTAMENTARY COME NOW Petitioners DARREN K. 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. $ ^{1} $ 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: 1 The original death certificate, or a certified copy thereof, will be filed with the Court upon Counsel's receipt of the same. EFTA00102190 Estate of Jeffrey E. Epstein Petition for Probate and Letters Testamentary Probate No. ST-19-PB- Page No. Page 2 of 4 ##
PERSONAL PROPERTY²VALUE
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, Collectibles,
Valuables&OtherTBD subject to
Personal Propertyappraisal/valuation
Hedge Funds & Private Equity Investments $ 194,986,301.00 10,000 shares of Maple, Inc., a U.S. Virgin Islands corporation which holds title to New York, NY 10021 $ 55,931,000.00 10,000 shares of Cypress, Inc., a U.S. Virgin Islands Corporation, which holds title to
Stanley, New Mexico 87056$17,246,208.00
10,000 shares of Laurel, Inc., a U.S. Virgin Islands Corporation which holds title to
Palm Beach, Florida 33480$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 $ 5^{\text{th}} $ floor and Paris, France 10,000 shares of Poplar, Inc., a U.S. Virgin Islands Corporation, which holds title to Great St. James Island St. Thomas, Virgin Islands $ 22,498,600.00 10,000 shares of Nautilus, Inc., a U.S. Virgin Islands Corporation, which holds title to Little St. James Island St. Thomas, Virgin Islands $ 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. EFTA00102191 Estate of Jeffrey E. Epstein Petition for Probate and Letters Testamentary Probate No. ST-19-PB- Page No. Page 3 of 4 6) Petitioners are 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 each of them is an adult or an infant are as follows:
NAMESRELATIONSHIPCAPACITYSHARE
Mark EpsteinBrotherAdult100%
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 are 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. EFTA00102192 Estate of Jeffrey E. Epstein Petition for Probate and Letters Testamentary Probate No. ST-19-PB- Page No. Page 4 of 4 ## WHEREFORE, Petitioners pray: A. That the Estate of Jeffrey E. 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 15, 2019 WILLIAM BLUM, ESQ., Of Counsel V. I. Bar No. 136 KELLERHALS FERGUSON KROBLIN PLLC EFTA00102193 Estate of Jeffrey Epstein Petition for Probate and Letters Testamentary Probate No. ST-19-PB- ## 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 15, 2019 Darren K. Indyke Darren K. Indyke SUBSCRIBED AND SWORN to before me this 15 day of August, 2019. EFTA00102194 Estate of Jeffrey Epstein Petition for Probate and Letters Testamentary | Probate No. | ST-19-PB- | | :--- | :--- | ## 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 15th, 2019 Audiaud D Kalm Richard D. Kahn SUBSCRIBED AND SWORN to before me this 15th day of August, 2019. Manaine Barnett MARIANNE BARNETT NOTARY PUBLIC, STATE OF NEW YORK NO. 01BA6276845 Qualified in Suffolk County Term expires February 25, 2021