UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶
Plaintiff; v. DARREN K. INDYKE AND RICHARD D. KAHN AS EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN, Defendants.¶
Case No. I :19-10788-GHW-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 ("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:¶
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I. The captioned action is hereby stayed pending further Order of the Court.
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- After the lifting of the stay, if any, the Parties will confer on a schedule for the remaining discovery in this action.
Dated: June 19, 2020 Respectfully submitted, New York, New York¶
CUTI HECKER WANG LLP¶
By: Is/ Mariann Meier Wang¶
Mariann Meier Wang 305 Broadway, Suite 607 New York, New York 10007 Tel: (212) 620-2603 mwang@chwllp.com¶
Attorneys for Plaintiff¶
TROUTMAN SANDERS LLP¶
By: /s1 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¶