Court Records
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
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-10577-L1L-DCF
JOINT STIPULATION AND }PROPOSED] ORDER STAYING ACTION Pt
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 Jane Doe 1000 ("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.
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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
BOLES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
([Phone Redacted]
[Email Redacted]
Attorneys for Plaintiff
TROUTMAN SANDERS LLP
By: /s/ Bennet J. Moskowitz
Bennet J. Moskowitz
875 Third Avenue
New York, NY 10022
([Phone Redacted]
[Email Redacted]
Attorneys for Defendants
Date: June 15 2020
New York, New York
2
The parties are directed to submit a joint status report
no later than 8/14/2020.
Ala& ortra-c---
HON. DEBRA G. FREEMAN
United States Magistrate Judge
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