## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, v. Plaintiff, DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. USDC SONY DOCUMENT ELECTRONICALLY FILED D0C #: DATE FILO: /±.-P SP? Case No. 19 Civ. 8673 ## JOINT STIPULATION AND IPROPOSED1 ORDER ON PLAINTIFF'S ANONYMITY This stipulation is entered into by plaintiff Jane Doe ("Plaintiff') and defendants Darren K. Indyke and Richard D. Kahn, in their capacities as executors of the Estate of Jeffrey E. Epstein ("Defendants"). WHEREAS, Plaintiff has moved this Court for an Order permitting Plaintiff to proceed under a pseudonym in this action; IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs and Defendants, through their undersigned counsel, subject to the approval of the Court, that: - I. Within three (3) days of entry of this Order, Counsel of Record for Plaintiff shall disclose Plaintiff's identity to Counsel of Record for Defendants, in writing, - 2. Counsel of Record for Defendants may disclose Plaintiff's identity only to Defendants and any attorneys, paralegals, and clerical or other assistants working with or for Counsel of Record for Defendants on this action; and the recipients of such information shall not disclose it to any other persons. - 3. If Defendants wish to disclose Plaintiff's identity to any person not otherwise permitted to receive such information under this Order, Defendants are limited to doing so in connection with defending this action, and must require such person to first execute a non-disclosure agiv,,,tient, in a form agreed to by the parties and attached to this Order as Exhibit A, that prevents such person front disclosing Plaintiff's identity to any other persons. Defendants must maintain a list of all such persons to whom Plaintiff's identity is disclosed and copies of the executed non-disclosure agreements, all of which are subject to in camera inspection. - 4. All portions of pleadings, motions or other papers filed with the Court that disclose Plaintiff's identity shall be filed under seal with the Clerk of the Court and kept under seal until further order of the Court. The parties shall use their best efforts to minimize such sealing. Any party filing a motion or any other papers with the Court under seal shall also publicly file a redacted copy of the same, via the Court's Electronic Case Filing system, that redacts the Plaintiff's identity and text that would reveal Plaintiff's identity. - 5. The parties may seek to modify or amend this Order at any time upon motion to the Court or by stipulation. Dated: December 13, 2019 Respectfully submitted, Roberta A. Kaplan Kate L. Doniger Alexandra K. Conlon KAPLAN HECKER & FINK LLP 350 Fifth Avenue, Suite 7110 New York, New York 10118 Telephone: (212) 763-0883 Facsimile: (212) 564-0883 rkaplan@kaplanhecker.com kdoniger@kaptanhecker.com kmagun@kaplanhecker.com aconlon@kaplanhecker.cOrn Attorneys for PlaintiffJane Doe SO ORDERED. Date: /. 2-4,10f New York, New York 1; 5) 14/4 KcP Bennet J. Moskowitz TROUTMAN SANDERS LLP 875 Third Avenue New York, New York 10022 Telephone: (212) 704-6000 Bennet.Moskowitz@trouthman.com Attorneys for Defendants Darren K. indyke and Richard D. Kahn, Co-Executors of the Estate ofJeffrey E. Epstein. HON. DEBRA FREEMAN United States Magistrate Judge ## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, v. Plaintiff, Case No. 19 Civ. 8673 DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, Defendants. ## NON-DISCLOSURE AGREEMENT acknowledge that 1 understand that the name of the Plaintiff in this action is confidential. I agree that: (1) I will hold in confidence Plaintiff's identity; (2) 1 will use Plaintiff's identity only for purposes of this litigation and for no other purpose whatsoever; and (3) I will take all due precautions to prevent the unauthorized or inadvertent disclosure of Plaintiff's identity. By acknowledging these obligations under this Non-Disclosure Agreement, I understand that I am submitting myself to the jurisdiction of the United States District Court for the Southern District of New York for the purpose of any issue or dispute arising hereunder, and that my willful violation of any term of the Non-Disclosure Agreement could subject me to punishment for contempt of court. Dated: [Signature]