## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

VE,

v.

DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET, CORPORATION, FINANCIAL TRUST COMPANY, INC., NES, LLC,

Defendants.

Case No. 1:19-07625-AJN-DCF

## JOINT STIPULATION AND \[PROPOSED I ORDER STAYING ACTION PP

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 VE ("Plaintiff," and together with Defendants, Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, Nine East 71st Street, Corporation, Financial Trust Company, Inc., and NES, LLC, 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.
- 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 Respectfully submitted, New York, New York

POTTINGER LLC

By: /s/ Bred Brad 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 The parties are directed to submit a joint status report no later than 8/14/2020.

Date: June 15 2020 New York, New York

HON:DEBRA-erFREEMAN Unitetl-States-Distriet3tidge Hon. Debra Freeman, U.S.M.J.