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Record

Draft: efta02777665

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

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-10474-NRB

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 Plaintiff ("Plaintiff," and together with Defendants Darren K. Indyke and Richard D. Kahn, 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 (1) Plaintiff ceases her participation in the Program or (2) Plaintiff's participation in the Program is no longer a possibility; and

WHEREAS should Plaintiff resolve her claims against Decedent 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.
  1. After the lifting of the stay, if any, Defendants may file their motion to dismiss Plaintiff's Amended Complaint without the need for a pre-motion conference, as set forth in the Court's April 2, 2020 Order (ECF No. 27); and the Parties will confer on a briefing schedule for Defendants' motion in which no more than sixty (60) days elapse from the filing of Defendants' motion to the filing of Defendants' reply.

Dated: April 9, 2020 Respectfully submitted, New York, New York

BOLES SCHILLER FLEXNER LLP

By: /s/ Sigrid S. McCawley Sigrid S. McCawley 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 Email: smccawley@bsfllp.com

Attorneys for Plaintiff TROUTMAN SANDERS LLP

By: /s/ Bennet J. Moskowitz Bennet J. Moskowitz 875 Third Avenue New York, NY 10022 (212) 704-6000 bennet.moskowitz@troutman.com

Attorneys for Defendants

Date: April 2020

New York, New York HON. NAOMI REICE BUCHWALD United States District Judge

Draft: efta02777665

Other records

Prepared source

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 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-10474-NRB 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 Plaintiff ("Plaintiff," and together with Defendant…