## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

JANE DOE 17,

Plaintiff

v.

DARREN K. 1NDYKE 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. I :19-cv-09610-PAE-DCF

## JOINT STIPULATION AND IPROPOWDIORDER STAVING 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 Plaintifflane 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

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 Plaintiffs 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: Is/ David H. Brodie

David H. Brodie, Esq.

Laura J. Starr, Esq

1301 N. Federal Highway

Lake Worth, FL 33460

Telephone: (561) 588-9500

Attorneys for Plaintiff

Date: 1/ 41/ 24

New York, New York

Respectfully submitted,

TROUTMAN SANDERS LLP

By: Is/ Bennet J. Moskowitz

Bennet J. Moskowitz

875 Third Avenue

New York, NY 10022

(212) 704-6000

Attorneys for Defendants

&Tato,

Powie As 6 HON. PAULA. ENGELMA0. ER United States District Judge