Joinder To Emergency Order Filed By Epstein Victims In Virgin Islands

IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST THOMAS AND ST JOHN IN THE MATTER OF THE ESTATE OF JEFFREY E EPSTEIN PROBATE NO ST 19 PB 80 deceased REPLY JOINDER IN FURTHER SUPPORT OF EMERGENCY MOTION 1 This firm was retained by nearly two dozen women who were sexually abused by Jeffiey E Epstein ( Epstein ) to puisue claims against the Estate of Jeffrey B Epstein ( Estate ) and we file this reply joinder in fuither suppon of the motion of the Government of the United States Viigin Islands (‘ Government ) to immediately fieeze all assets, all accounts and cease all payments until a new plan is agieed upon to ensme that the money in the Estate goes exclusively to sexual abuse victims of Epstein 2 The Estate's opposition confiims that this Comt should grant the Goveinment’s emeigency motion The Estate oife1s no explanation whatsoeve1l as to how the Estate has squandeied $205 million in thiee months with less than $50 million2 compensating sexual abuse Victims The Estate merely argues (at p 1) that it has to maintain assets which is gxossly inadequate to explain what happened heie It is significantly different to submit statements versus there being an actual approval by the Attorney Geneial No one, including, upon information and 1 This includes the absurd claim for the eiosion of hundreds of millions of dollars by the Estate 5 boasting 'As one example, during the months of September November 2020, the Co Executors incurred approximately $4 800 per month for landscaping services on the Estate 5 7 500 acre New Mexico ranch (See Fifth Quarterly Accounting Schedule D at 10 (invoice from Aspen Landscaping LLC) Those services entailed mowing pinning wateiing removing tumbleweed, and general clean up and maintenance, all which were necessary to maintain the property and address the danger of wildfires ‘ (See Estate Opposition at n 10) 7 The Estate s claim that $57 million has been distributed by the fund is at odds with its December 30, 2020 financial accounting filed with the Court belief, the Attorney General has approved the more than $200 million decrease in value that shockingly occurred over the last three months of 2020 3 If the Estate keeps up at this rate the Estate will be worth zero in a few months This is an emergency Given that the Victims Compensation Program (”VCP") is not compensating Victims for the f01eseeable future, it is very likely that this entire Estate will be worth nothing before another victim gets compensated and there are dozens of Victims that remain Worse, some Victims will not be settling theii cases with the VCP In New York State, it will take yeais for some of these cases to be resolved and by then, given the Estate's cunent eiosion rate, there will certainly be nothing left Thus, the Estate is fOICing Victims to accept whatevel the VCP offers which also is cont1a1y t0 the Estate 5 p1 omises (at least 25 million dollars to remain in a set aside fund fox Victims who do not choose to accept the VCP offeis) 4 As such, it is completely untme that the Government and sexual abuse Victims will not be haimed by the Couit's denial of the 1equested relief Celtainly, having no money to compensate sexual abuse Victims so that the Estate can do whatever is happening with the money is not in the public inteiest The Estate's doomsday hypothesis of a "paxade 0f honibles" if the Estate is frozen cannot be wmse than the status quo where the victims are left out in the cold while its professionals continue to be paid with the Estate s assets 5 The Estate claims there is not an "emergency" its lawyers and piofessionals continue to be paid millions of dollars each month but for the sexual abuse survivors, if the Court does not intervene and freeze the Estate's assets now it will be too late The temporary hold on the Estate that the Government seeks is the same temporary hold that the Estate has put on the survivors Why should the Estate 8 lawyers and professionals continue to bill (and profit) millions of dollars while there is a temporary hold on compensating sexual abuse survivors? 6 It is repulsive that the Estate wants to keep eroding its assets, including with its own professional fees while survivors are forced to wait and hope that there is money left for them The only parties not being paid by the Estate at present are the sexual abuse victims This is not the way it was supposed to be, it should not be allowed to continue, and it should be stopped immediately The Estate has breached its promises to survivors and the Attorney General It brought this entirely upon itself It is also concerning that the Co Executors of the Estate are alleged to have participated in various acts of what some Victims endured The ones who assisted in the abuse as alleged cannot be in any position to claim that they are looking out for the Victims best interests This is another issue that needs to be addressed and requires an immediate freeze on the Estate’s assets 7 Despite all of this, the Estate's opposition somehow claims that it is meeting its duties to the sexual abuse victims yet neaily every single Victim has suppmted the Government 5 motion to freeze the Estate The erosion rate is unsustainable and unacceptable and if the Estate truly caied about Victims, it would engage in a piocess to remedy the untenable status quo As previously set forth, this firm is willing and able to have a discussion, but until there is a much improved plan moving forward, the Estate must be frozen for the protection of all involved, including the Estate and its creditors, especially the sexual abuse Victims Dated February 22 2021 Respectfully submitted WESTFALL LAW PLLC 5032 Ancho ay Suite 8 Christiansted V100820 VI Office (340) 227 0017 MERSON LAW PLLC Jordan K Merson, Admitted Pro Hac Vice Jesse Mautner, Admitted Pro Hac Vice Attorney for Sexual Abuse Claimants 950 Third Avenue 18th Floor New York New York 10155 (212) 603 9100