EFTA02732307
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Case 1:19-cv-10479-ALC-DCF Document 43 Filed 06/13/20 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK v. DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN, Defendants. Case No. 1:19-cv-10479-ALC-DCF JOINT STIPULATION AND FPROPOSED1 ORDER STAYING ACTION Pic WHEREAS independent claims administration experts have designed and are implementing the Epstein Victims' Compensation Program (the "Program") to resolve sexual abuse claims against decedent Jeffrey E. Epstein ("Decedent") in a non-adversarial alternative to litigation; and WHEREAS Plaintiff ("Plaintiff " and together with Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, the "Parties"), seeks to participate in the Program; and WHEREAS the Parties seek to preserve their resources and judicial economy by staying this action for sixty (60) days while Plaintiff participates in the Program; and WHEREAS should Plaintiff resolve her claims against Decedent via the Program, Plaintiff will promptly discontinue this action with prejudice. IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for the Parties, that: 1. The captioned action is hereby stayed, both as to discovery and to the resolution of any pending motions, for sixty (60) days from the date of entry of this Order. 42498365v1 EFTA02732307 Case 1:19-cv-10479-ALC-DCF Document 45 Filed 06/13/20 Page 2 of 2 2. After the expiration of the stay, if any, the Parties will confer on a schedule for the remaining discovery in this action. Dated: June 12, 2020 Respectfully submitted, New York, New York BOWS, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 (954) 377 4223 smccawley@bsfIlp.com Attorneys for Plaintiff TROUTMAN SANDERS LLP By: Is/ Bennet J. Moskowitz Bennet J. Moskowitz 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com Attorneys for Defendants Date: Iune 15 2020 New York, New York 2 The parties are directed to submit a joint status report by 8/14/2020. HON. DEBRA C-. FREEMAN United States Magistrate Judge 42498365v1 EFTA02732308