mts le 0 Copy 3) fi filire oxy "Vio. Mayme uted Wha 4.222 She On, bow QC tet b us poveat Sorte ag tne treme te Kes peek fue, SubmitedCONL.NO. ST-CV-00185 ‘COMPLEX KAHN, n Pb capacity os ‘THE ESTATE OF JEFFREY E. EPSTEIN, and NES, LLC a Now York United Cabitty Company, Defendants PLAINTIFFS REPSONSE TO STATUS HEARING ‘histane Maxwol (rere, “Plain, ls sppeering PRO SE folowing the witraual of her Atomey Kyle RWakine. (2a Grontng Motion to Witcraw) (Doe. 80) A sas hearing was het March 17h 2028, Prosent was Plat end Ore or Barren dyke Cindyke) and FichardD. Kahn (Kahn ther capacty as Co-Exocutrs ofthe Estate of “soap Eaten (ho Esiat’ and on behalf ofthe Estato and NES, LLC (NES*) collectively, tho *Dofendent). A 60 dey dere seuings alow Plant to fd Now Coueel was proposed and socapted without cbecton. This responses fied provid the cout wih a elas updato in accordance with tis courts cretion. PRELIMINARY STATEMENT ‘This en acton fr Indemnification forthe attomaye' feos, socury cost, costs ta nd safe aocommodation ad ll other Frain has incured by reason of her por ampioyment relationship wih Jofray E. Epstein. Epstan") and his seermacs, Pending betore tis cour, n above referenced mater, are Defenders’ argurens to dims Panis cave: Co- carats Supplemental Bran Support of Woven to Dismiss (690 "SMTD”). (Oc. 26). Co-Executore apy Brion Support of Faeere entae (eee "REND (Ove. 20). Moll to Dismiss & incorporated Mernorandum of Law (908 "MTD". (Doe. 7). Ané Painire arguments why the Defendants lings fr damsel n ebove caso shuld net roval: Pllc Ge n Reaponae to Pra eiot (ove “PS?) (Doc. 38) Paints Opposition to Defendant’ Motion to Dismiss (See "POMD? (Doc. 18). The maton. (CU tes The patos Rave not yet had Rue 16 conference and discovery has not el commenced, Plait proceeding [ERO GE unis ahe continues to search for New Counsel. Paint is requesting sty 1o ge her more tine to find Now Fao ee citonsly Plans requostng mere tm to review th case fle which she rcetved and reviowed forthe frat tne een eet Att 202, (ova Exh A), Plant seeks moro ime o read the relevant law and statutes 20 sho can respond to (out ordore and ober Judi reqdrements, to frter study and reviow all court documents and relevent evisenco to ca re pe cgureria, 8, sould Pain be unable orealn Now Counesl she wl continue to represont heres PRO SE. ease re eslira more tne to beable fo do so ofecively and july. Further, Plain is requesting say whilst he ERAS Sitee Cour of Bopocl orto second Ceut: Case 22-14620-CR (e00Agpea. (S00 Ext 8), auicaod oa all xu cae vated ea surance vs une te Defers per cae mn eve ‘oso no longer en‘DIVISION OF ST. THOMAS AND ST. JOHN Fed May 16th 2028 11.30am ST-2020-CV-00185 — —_s - Ghisalne Mas Pal vw ESTATE OF JEFFREY E. EPSTEIN DARREN K. INDYKE, nhs eapacty as EXECUTOR OF THE ESTATE OF CML NO. ST-Cv00185: \TEFEREY €. EPSTEIN, RICHARO D- icAdN, i is capaclty a8 EXECUTOR OF COMPLEX THe ESTATE OF JEFFREY E.CPSTEN, ‘and NES, LLC @ Now York Limited apity Company, Defendants PLAINTIFF'S REPSONSE TO STATUS HEARING ‘Ghislaine Maxwell (herlnaer, "Plaintiff, Is appearing PRO SE folowing the wihrawal of her Attorney Kye RW Bese Seaning Monto Withérew) (006. £0). A sta hearing washes March 17h 2023, Posen was Plan and Se aren inves (lndy") and Richard D. Kahn (Kahn) in ther capacty as Co-Exocutors ofthe Estate of “dcnoy Epson te "Esat’) end on behalf ofthe Estate and NES, LLC (NES")colecvey the ‘Defendant’. A 60 day aot emdinge to elow Pai td New Counsel wes rovused and accpted witout objection Tie reepoaee it ‘lod fo provide the cour wih a satus update In accordancn with = outs [PRELNINARY STATEMENT “Thisis an action for deri forthe atomeye fees, securty cots, costs tod eae accommodation and al other ‘Terenses Plan hs ncured by reason of he rox employment rletonetip wit JafreyE.Epstoi. (Epste’) and is SeeeReE ‘ponding befor bis Gout in above referenced mater, are Defendants’ arguments to clams Plant's cae: Co- aaa gees Gupnlomenta ra In Support of Motion fo Dismiss (a0 "SWTD"). (Do. 2¢).Co-Exeoutors Reply Bren Support of Fereaee lentes [eee ROMO"), (Ove. 20). Moton to Dismiss & Incoporsted Mernorandum of Law (600 "MTD". (Doo. 7). And. Faint arguments why the Defendant’ Slings for dismissal In above case should rot provalPaitifs Bren Responso 10 Gioat roe [Sue 8") (Boe. 39) Plans Oppoetton to Defendants Motion oDismis (See POM (Doe18). The maton. tty rite, Tho pao have not yet had Rue 16 conference and cscovery hes nat ye sommenced. Panis proceeding ma ‘Counc laine requeeing aay to give hor more ime to find New CR Ee Pema is cequsntng more te to revi te con le which she recelved and reviewed fr the rst ne ‘Fa tard wook Apel 3023. (see EXNDR A). Plain socks more Ome toread the revert ew nd snk 80 eh cre fequloments, to frther study an revue on dest, ‘ e eS dao efecto dca. Fue, Pin i recuesing ay ws 2 y Rope tts pana Crk Cato 22 HEZER (eo Appa) (Soe Ben) asta ee oe ce in gurata he Dfencrt peer fr cainel mt above ‘ae no longer valMaxwell v testate oF senTey ep == > ‘Reepansa io a status hearing Fage 2 of4 the powarto stay proceedings is incidents! to the power inherentin every courte cont the poston of the causes ons Fearne ceonory of tne and efor fr keaf,for counsel, and for Wigan. "Burke V. Treasure Bay Vi Cop, 2016 WL eee. 2g Wil Super. Oct 6, 2016) (cting Landis V. North American Co, 229 US. 248, 254-65 (1896). Generally, the party Saar olay uel mare outa dear case of hardship or Inequy in bing requted to go forward, theres even fr $Ssbbly tht tho tay for which he prays wil work damage to someone ese” Landi, 299 US. at 256. To hat ond, n aoeeng whotor to grant @ maton t tay, courta have considered the folowing factors: (1) whether a sty wi simply Se er wereae dial economy. (2) the balance ofarm to the partes and (9) ts long of th requested lay. Soe rrases atte Wl 2503682, a3; Choyney State Col. FeclyV, Hulsadler, 703 F.24 732, 737-98 (3d Cx. 1963" (citng Landi, Bu0 Gs at 254-55). Thea is no prejudes to the Defendants, nor have thay suggested ary forthe Cout BE to Granta Zia ndthore i ato! that the tan wl preval nthe court of Ppa! : UNITED STATES COURT OF APPEALS FOR THE SECONO CIROUT Plein ea her appeel 28th Februsry 2023. (See Appeal). (See Exhibit). Pisin has asked the Appeal court to over um her co asad co errors made by bth the government an the ia cour, several! which are fetal and whic would ret n Fer itssl of te erminal proceedings. Point 1: Al counts shouldbe dismissed pursuant to the Non Proseouton WreamortPoln 2, "Al couns are bared by statute of iniatons, Pin "Pal was denied her conautona right a rea raparal bry because a juror mado fis statomenta in Vol Ore ost ate facs that f own would have prves ‘ai dost wo temove him for cause’, Point 4 "The court constuctvely amended couns 3& 4of he indciment. Defences’, sae eeestore tis court have argued forts demise, in par, 2s Plant, "cannet be indemmiied for ifenonal wrong cong Santtcarnal conduct (Soe ROMO at pp 3-42). (Ove. 20). Te outcome of he Pains appeal oud concer various of tre ants ergumente or Semissl veld es tray would not hal waler as fe Paint woud no longer b= canst of real conduct A say Is requested for Judicial economy und such tine tht the Appeal court has ruled. PLAINTIFF SEEKING NEW COUNSEL plaints sting New Counsel es sho is awere its preferablo for ll partes tobe represented fo efienoy an for dal coarary, Prantl faces chalengee tong Now Counsel ws many pote candidate ar confcted and Pain = faci soaneRYeratal. Al earcarated people have eommuricalon challenges, as Plan does. Her stan fs not unique but {Same courts consideration, I bears noting thal Plain has no ably to write ena ra, E Mal or cll ary potential new ‘Storey th Gtont atomey prvlege. Communications wih cnt attomey piviege are permitted with etiomoys of record cee eatione wih fers raul pre approval which lends sel to potential delays for approval. Plan is seeking stay Gomme ours ine she neds, duo 1 te paricuarGhadenges olucdated, of end communicate wit potenti nw Counts. 3Maxowll Esato of Jerey E. Epetoln ot f Response o ste hosting PRO SE REPRESENTATION into iit ht PAA bal ean Now Coli she wl conte 1 rpresnt hero. Pn i curenty caret ond ‘has been for almost the enire pendency of the above case. Plaintif, slong with all other incarcerated people, faces challenges ‘as bee scour and wih counsel duo fo dele encountered in Prison. AS notecn Pans Appesl, “From tha ay ortng wy wawol wos hadi ota contnement. By to a oa, Manvel was ee deorenatd and cninished that ott rratia rosin to esata hor own dfonge rch leet tes’ (ee Moped. p.‘2\Nbt6), Parkpaing in aa rceednge re endaros npaccbie dus ote "humans canduons sho ended. “Her condone of comers ranging fom sloop ‘each of accor to epelcounse and ecovar 1 prepare fia’, were seminal, (9 ere (ove Exit C) Plants entre neaoereton has been span whist Cord potas were paca whch added Seti Mord st ifr aoter Inmet, nuding but not med to restos on person ogal vss as Cod scion urd 295 grt was moves 0 tren ns en so scarey hove under agi oe rote Naan ena tare We sl many Inpedinshi 9nd Rafe Pain needs to overcome tobe abe fo work efectvely and sa he abeys case tne cout may be see Suprd tal Pla has no access foe camper ype any document far sour corms, pecan, ee requrrtans, va ine aoets odo research, andne constr of alto use of at rere wre on Thar hes boon no photSospyin mace avatabe fr mates since Noverber 18th, 222 n Plans ‘current plod of interceration, Access to printer is nol conelstent and random events Interfere with dally prison ife and are = aoe eros makngmoanigll paring or execon of work catenin. ure, ence under he agi cf BOP on Pa ene te nological lock hee where Praon computers, ta low logelreseech cn a cosod syst. ove Inmate ent chnhng onan 90 DOS program and adtonalreserh s conducted rough aqua gal books and Ie ara cot organ and paper wh Is veal raking noes aking hoe hearcrated bockin et period ae eign, orover Plt hes no accesso retvant Vin and aw whch se wasted sb woud have to purchase seperately. (ade Exhibit 0). Plant is respectilly requesting more time to allow her to research legal eroumene, rare opera iver 1 ha po dat sere lgal books, propare ad eats varousdocaments al wih he ntenton Fone nae cam usa economy going fonard shod she be unable tod New Counsel and contnve beer this eounPROSE, CLAIMS AGAINST NES AND OTHER ENTITIES Improper Inulin to ismiss Pant’ aime based on NES 2014 Operating Agreement, ¢ Parad ef tna Tong for Plat coased working for Epetan. (e00 Compl. p15. nd). (Doe 1) ts abridge to far to suggest. Peron tated bushessman ike Epson, sole momer of NES, wit experienced lawyers and franca acisors, would ergo the Jeeta sforded by an Operating Agreement or 16 years, fom 1998-2014 the dat the Defondans produced NES, sistrons ee ef sevng, Even Ite cout were to cre Dofendens argument, and k shoul not under New York Law tre ay conpanles enna Operating Arent xe fw LLC atic o"urarouscovios ns nia Sent Company Law) tat set rth Gofal provisions appiicabla to thelmted Hablty company“) N.Y, Lil. Usb. Co. 420. Platts souks astslonal me forovew NY Liited Uabify Compa law, and aduonal caso la evant to rguronia rosontod, and to revow Vigi sland law wilt searching fer an earler Operatng Agreement Plain believes exesResponse io status hoary Print was employed by various other enttes owned by Epetln (990 Compl 81.52) (Doc.1). Defendants suggested that ther enties Pian ead she wes employed by ony "ikaly* had indemnity, and that her claims are “oo the to eat tho, requirement fo al elements of her ciaim. (ee MTD p8 8). (Doc 7). Pai haa localod lawsuit ed in ry 2000% Urited ‘States Distt Court forth Eastom Distict of Pennsyivara,Noleon Shanks v Leale Weiner and Abigal Wer, defey, Epstein and J. Epstein and Co. nc and Ghisiaine Maxwell. Case No. 02-7671, Shanks") (Seo Exhibit E). The awaut wa ‘agarding the non payment fer panting the Werner fay by Shank. Plant wes ndemnid for he inveivement in he ‘Shanks sui, as she was for other suis (ee PB p.12). (Doc 38). The affmativaly demonstrates Defendants indemnying Pen for lege! cont and is Ista ca patter that supports Paints argument that sho was incemfed fora logl proceedings Iaued by reason of her employment by Epstln. Plan lao avers of new ongoing Rigaion suroundog Epstein and the Estat through which previously undisclosed ivormation continues to surlaco, and Pain is roseareing ‘otieving that contains pertnent information. As an example of new probative infomation tat has come lo Ugh, an Interview that Epstein gave In his own vote that was recently aled, Epstein is quctod s0}ng n part ofthe intrvow, "a, is {st unfair because she (Paint realy plays no role, and Ghilane was never, never ever @ apart of anyof hs stuf” etx: Filthy Rich, 25th Nov, 2022). ONCLUSION. For the reasons set forth heres Pant respectuly requests a 180 day stay of proceedings, or unl Plants Appeat is rndered or any amount of time this court deems right and proper.“! IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. THOMAS AND ST. JOHN CIVIL CASE NO.: ST-2020-CV-00155 Ghislaine Maxwell Plaintiff, vs. ESTATE OF JEFFREY E. ESPSTEIN, DARREN K. INKYKE, in his capacity as EXECUTOR OF THE ESTATE OP-JEFEREY E. EPSTEIN, RICHARD D. KAHN; in his cdpacity 2s EXECUTOR OF THE ESTATE OF JEFFREY E. EXPSTEIN, and NES, LLC, a New York Limited Liability Company, Defendants, TRANSMITTED HERE WITHIN Complete Copy of Entire file case ST-2020-CV-00155 Please signed and return, or email. LAB (oR: GHISLAINE MAXWELL DATE and TIME Superior Court of the Viegin Islands P.O, Box 70 ; ‘St. Thomas, US. Vib. 09804-0070 Paul lantdhMieduttons \ ‘EXHIBIT A | — a22-1426-CR UNITRD STATES COURT OF APPEALS TTFOR"THE “SECOND CIRCUIT EXHTRIT BPRESS STATEMENT FOR TMWEDTATE RELBASB WH. Aldalalaw.com BXHIRIT ¢‘RESPONSE TO INMATE REQUEST TO STAFF MEMBER NAME: Maxwell, Ghislaine Register Number: 02879-309 Unit: B South “hiss in response to your Inmate Request to Staff Member dated Apri!21, 2023, and received inthis office on Apr. 25, 2028. You request access to Virgin island case law for yout pending case inthe Superior Cout ofthe Virgin islands, Division of St. Thom and St. John, As rele, you request books or comprehensive computer access for research of egal relevance. Inmate access to legal materials is governed by Program Statement 1315.07, Legal Actives, Inmate, Per that Program Statement, each Warden must establish a main law ‘rary containing the materials listed in the Required Main Law Library Materials {attachment A), The Bureau is not mandated to provide state case law andlor other sate lagal materials, Pursuant to Program Statement 5268.11, Incoming Publications, you may purchase legal materials from outside the institution. EXRTRIT D a ee— ee — — Case ZO2-evOTETL:CN Document 1’ Filed 19/02/02 Page 4 of & THs fradicon Avenua, 4 FLOOF ‘ EXPIIT FCERTIFICATE OF SERVICE “This is to certify that I have served a true and correct copy of the foregoing, Plaintiff's Response to Status Kearing upon the following addresses, by placing same ina scaled envelope, bearing suiciest postage for the delivery via United States Mail Service to: Ariel M. Smith Esq. (AAG) VIRGIN ISLANDS DEPARTMENT OF JUSTICE Office of the Attorney General 34-38 Kronprindsesn Gade St. Thomae,U.S, Virgin Telends 00802 and deposited in te postal box provide for famates onthe grounds of the Federel Comectonel Institution Tllahasee, Florida 22301 on this _16°" _day of May 2023__, Litigation is deemed FILED atthe time it was delivered to prison authorities. See: Houston v. Lack, 487 US 266, 101 L Ed 24 245, 108 S C2379 (1988).