## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

v.

DARREN K. INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN,

Defendants.

Case No. I:19-cv-10479-ALC-DCF

## JOINT STIPULATION AND IPROPOSED1 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 for sixty (60) days while Plaintiff participates in the Program; and

WHEREAS should Plaintiff resolve her claims against Decedent via the Program, Plaintiff will 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, both as to discovery and to the resolution of any pending motions, for sixty (60) days from the date of entry of this Order.

- 2. After the expiration of the stay, if any, the Parties will confer on a schedule for the remaining discovery in this action.

Dated: June 12, 2020 Respectfully submitted, New York, New York

BOLES, SCHILLER & FLEXNER LLP

By: /s/ Sigrid McCawley

Sigrid McCawley 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 (954) 377 4223 smccawley@bsifip.com

Attorneys for Plaintiff

TROUTMAN SANDERS LLP

By: /s/ Bennet J. 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