Co-Executors Response to USVI Probate Appeal and Freeze Motion

CO-EXECUTORS' RESPONSE TO USVI PROBATE APPEAL Matter of the Estate of Jeffrey E. Epstein, Deceased Probate No. ST-2019-PB-00080 Filed: March 29, 2021 This response was filed by Darren K. Indyke and Richard D. Kahn, the co-executors of the Epstein estate, opposing the Virgin Islands government's notice of appeal and petition for review. The co-executors argued that the government had waited too long to challenge the denial of intervention and that the emergency motion to freeze all estate assets no longer rested on accurate facts. The filing states that the government had previously sought to intervene in January 2020 and that the probate court had denied that request from the bench in February 2020. The co-executors' position was that the government was not a probate intervenor but could pursue its interests through creditor-claim procedures and the separate civil action it had already filed against the estate and related entities. The response is valuable as an estate-property record because it shows how the estate resisted direct government control over probate administration. It frames the asset-freeze demand as unnecessary and moot, while emphasizing the ongoing voluntary claims resolution program and the estate's existing obligations to claimants and the court. The document also preserves the adversarial posture between the territorial government and the estate managers. The government wanted stronger safeguards against asset movement; the co-executors argued that probate rules, existing court supervision, and other litigation channels were sufficient. That disagreement helps explain later disputes over fees, settlement, estate liquidity, and how Epstein-linked assets would be preserved or distributed. Source: DOJ Epstein Library / V.I. Superior Court Available at: https://www.justice.gov/epstein/files/Court%20Records/Matter%20of%20the%20Estate%20of%20Jeffrey%20E.%20Epstein%2C%20Deceased%2C%20No.%20ST-21-RV-00005%20%28V.I.%20Super.%20Ct.%202021%29/EFTA02821574.pdf