## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

JANE DOE,

v.

DARREN K. INDYKE AND RICHARD D. KAHN, in their capacities AS EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN,

Defendants.

Case No. I:20-civ-02365-LJL-DCF

## JOINT STIPULATION AND 1PROPOSEDI 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 Jane Doe ("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:

- 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 to answer, move, or otherwise respond to Plaintiff's Complaint and any motion to proceed anonymously.

Dated: July 10, 2020 Respectfully submitted, New York, New York

KAISER SAURBORN & MAIR, P.C.

By: /s/ Daniel J. Kaiser Daniel J. Kaiser, Esq. William H. Kaiser, Esq. 30 Broad Street, 37th Floor New York, New York 10004 (212) 338-9100

Attorneys for Plaintiff TROUTMAN PEPPER 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

Date: 2020

New York, New York HON. DEBRA C. FREEMAN United States Magistrate Judge