032.pdf

42501282v1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ANASTASIA DOE, Plaintiff, v. DARREN K. INDYKE AND RICHARD D. KAHN, AS CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN., Defendants. Case No. 1:19-cv-11869-MKV-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 Anastasia Doe (“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: 1.The captioned action is hereby stayed pending further Order of the Court. Case 1:19-cv-11869-MKV-DCF Document 32 Filed 06/12/20 Page 1 of 2 2 42501282v1 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 12, 2020 New York, New York Respectfully submitted, EDWARDS POTTINGER LLC By: /s/ Brad Edwards Brad Edwards 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Tel: (954) 524-2820 brad@epllc.com Attorneys for Plaintiff TROUTMAN SANDERS LLP By: /s/Bennet Moskowitz Bennet J. Moskowitz 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com Attorneys for Defendants Date: __________________, 2020 ______________________________ New York, New York HON. DEBRA C. FREEMAN United States Magistrate Judge Case 1:19-cv-11869-MKV-DCF Document 32 Filed 06/12/20 Page 2 of 2