Court Records
Case 1:19-cv-09610-PAE-DCF Document 38 Filed 01/08/20 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE 17,
Plaintiff,
v.
DARREN K. INDYKE AND RICHARD D. KAHN,
AS JOINT PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN, NINE
EAST 71st STREET CORPORATION, LAUREL.
INC., FINANCIAL TRUST COMPANY, INC.,
NES, LLC, MAPLE, INC., LSJE, LLC, HBRK
ASSOCIATES, INC., NAUTILUS, INC.,
CYPRESS, INC. and JEGE, INC.
Defendants.
Case No. 1:19-cv-09610-PAE-DCF
JOINT STIPULATION AND !PROPOSED] ORDER STAYING ACTION
WHEREAS independent claims administration experts are designing and 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 PlaintiffJane Doe 17 ("Plaintiff'• and together with Defendants Darren K.
Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, Nine East 71st
Street Corporation, Laurel, Inc., Financial Trust Company Inc., NES LLC, Maple, Inc., LSJE,
LLC, HBRK Associates, Inc., Nautilus, Inc., Cypress, Inc., and JEGE, Inc., 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 ceases her participation in the Program; and
40967362v I
EFTA02738099
Case 1:19-cv-09610-PAE-DCF Document 38 Filed 01/08/20 Page 2 of 2
WHEREAS, should Plaintiff resolve her claims against Decedent via the Program, the
Parties will thereafter promptly discontinue this action with prejudice;
WHEREAS, on December 23, 2019, Defendants moved to dismiss Plaintiff's Complaint
(ECF Nos. 34-36); and
WHEREAS Plaintiff intends to amend her Complaint (ECF No. 1);
IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned
counsel for the Parties, that: (1) the captioned action is hereby stayed pending further Order of
the Court; (2) Plaintiff has 30 days from after the lifting of the stay, if any, to amend her
Complaint; and (3) Defendants have 30 days from Plaintiff's filing of her Amended Complaint to
answer, move or otherwise respond thereto.
Dated: January 8, 2020
New York, New York
Weisman, Brodie, Starr & Margolies, P.A.
By: /s/ David H. Brodie
David H. Brodie, Esq.
Laura J. Starr, Esq
1301 N. Federal Highway
Lake Worth, FL 33460
Telephone: ([Phone Redacted]
Attorneys for Plaintiff
Date:
New York, New York
Respectfully submitted,
TROUTMAN SANDERS LLP
By: /s/ Bennet J. Moskowitz
Bennet J. Moskowitz
875 Third Avenue
New York, NY 10022
([Phone Redacted]
Attorneys for Defendants
HON. DEBRA FREEMAN
United States Magistrate Judge
40967362v I
-2-
EFTA02738100