UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶
JANE DOE,¶
Plaintiff¶
v.¶
DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN,¶
Defendants.¶
Case No. 19 Civ. 8673¶
JOINT STIPULATION AND IPROPOSEDI 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:¶
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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.
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- 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.
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- 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 agreement, in a form agreed to by the parties and attached to this Order as Exhibit A, that prevents such person from disclosing Plaintiff's identity to any other persons. Defendants must maintain a list of all such persons to whom Plaintiffs identity is disclosed and copies of the executed non-disclosure agreements, all of which are subject to in camera inspection.
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- 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 Plaintiffs identity.
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- 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®kaplanhecker.com kmagun®kaplanhecker.com aconlon@kaplanhecker.com¶
Attorneys for Plaintiff-Jane Doe¶
SO ORDERED.¶
Date: New York, New York g: 51&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. lndyke and Richard D. Kahn, Co-Executors of the Estate of Jeffley E. Epstein.¶
HON. DEBRA FREEMAN United States Magistrate Judge¶