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Case 1:19-cv-10788-GHW-DCF Document 46 Filed 06/19/20 Page 1 of 2 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
Plaintiff; 
v. 
DARREN K. INDYKE AND RICHARD D. KAHN 
AS EXECUTORS OF THE ESTATE OF JEFFREY 
E. EPSTEIN, 
Defendants. 
Case No. I :19-10788-GHW-DCF 
JOINT STIPULATION AND [PROPOSED] ORDER STAYING ACTION 
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 unless and until Plaintiff elects to resume the litigation and requests the stay be lifted; 
and 
WHEREAS should Plaintiff resolve her claims against Defendants via the Program, the 
Parties will thereafter promptly discontinue this action with prejudice. 
IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel 
for the Parties, that: 
I. The captioned action is hereby stayed pending further Order of the Court. 
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Case 1:19-cv-10788-GHW-DCF Document 46 Filed 06/19/20 Page 2 of 2 
2. After the lifting of the stay, if any, the Parties will confer on a schedule for the remaining 
discovery in this action. 
Dated: June 19, 2020 Respectfully submitted, 
New York, New York 
CUTI HECKER WANG LLP 
By: Is/ Mariann Meier Wang 
Mariann Meier Wang 
305 Broadway, Suite 607 
New York, New York 10007 
Tel: ([Phone Redacted] 
[Email Redacted] 
Attorneys for Plaintiff 
TROUTMAN SANDERS LLP 
By: /s1 Bennet Moskowitz 
Bennet J. Moskowitz 
875 Third Avenue 
New York, NY 10022 
([Phone Redacted] 
[Email Redacted] 
Attorneys for Defendants 
Date:  , 2020 
New York, New York HON. DEBRA C. FREEMAN 
United States Magistrate Judge 
2 
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