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Record

Draft: efta02846263

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

Vii,

Plaintiff,

v.

DARREN K. INDYKE AND RICHARD D. KAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET, CORPORATION, FINANCIAL TRUST COMPANY, INC., NES, LLC,

Defendants.

Case No. 1:19-cv-07625-AIN

ORDER ON PLAINTIFF'S ANONYMITY

IT IS HEREBY ORDERED that any person subject to this Order, including the parties to this action and their respective counsel of record, shall adhere to the following terms:

  • 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.
    1. 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 Defendants on matters related to this action; and the recipients of such information shall not disclose it to any other persons.
    1. 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, that prevents such person from 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.
    1. 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.

    1. The parties may seek to modify or amend this Order at any time upon motion to the Court or by stipulation.

SO ORDERED.

Date: New York, New York Alison J. Nathan

United States District Judge

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

VE,

Plaintiff;

v.

DARREN K. ENDYKE AND RICHARD D. KAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET, CORPORATION, FINANCIAL TRUST COMPANY, INC., NES, LLC,

Defendants.

Case No. 1:19-cv-07625-AJN

JOINT STIPULATION FOR ORDER ON PLAINTIFF'S ANONYMITY

Plaintiff, VE ("Plaintiff"), jointly with Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (incorrectly named herein as "Joint Personal Representatives" of the Estate of Jeffrey E. Epstein), Nine East 71st Street, Corporation, Financial Trust Company, Inc., and NES, LLC ("Defendants"), through undersigned counsel for Plaintiff, hereby respectfully submit the following Stipulation and (Proposed) Order to Plaintiffs Motion For Leave To Proceed Anonymously (DE 4).

The parties have reached an agreement on a form Anonymity Order, which includes the condition that a Non-Disclosure Agreement be signed by any non-party provided with the identity of Plaintiff.

The parties respectfully request the Court enter the attached (proposed) Order and Agreed Non-Disclosure Agreement.

Dated: December 4, 2019 New York, New York

Respectfully Submitted,

POTT1NGER, LLC

Brittany N.

Stanley J. Pottinger 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954)424-2820

Fax: (954)-524-2822 Email: ecflepllc.com brad®eplIc.com brittany®eplIc.com

Attorneys for Plaintiff (ADMISSION PRO HAC VICE)

Draft: efta02846263

Other records

Prepared source

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Vii, Plaintiff, v. DARREN K. INDYKE AND RICHARD D. KAHN AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st STREET, CORPORATION, FINANCIAL TRUST COMPANY, INC., NES, LLC, Defendants. Case No. 1:19-cv-07625-AIN ORDER ON PLAINTIFF'S ANONYMITY IT IS HEREBY ORDERED that any person subject to this Order, including the parties to this action and their respective counsel of record, shall adhere to the following terms: - I. Within three (3) days of entry of this Order, Counsel of Record for Plaintiff shall disc…