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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JANE DOE 17,

Plaintiffs,

V.

Case No. 1:19-cv-09610-PAE

DARREN K. INDYKE AND RICHARD D. KHAN, AS JOINT PERSONAL REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN NINE EAST 71st STREET CORPORATION, LAUREL, INC., FINANCIAL TRUST COMPANY, INC., NES LLC, MAPLE, INC., LSJE, LLC, HBRK ASSOCIATES, INC., NAUTILUS, INC., CYPRESS, INC., and JEGE, INC.,

Defendants.

JOINT STIPULATION FOR
ORDER ON PLAINTIFFS’ ANONYMITY

Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (named herein as “Joint Personal Representatives of the Estate of Jeffrey E. Epstein”); Nine East 71st Street Corporation; Laurel, Inc.; Financial Trust Company, Inc.; NES LLC; Maple, Inc.; LSJE, LLC; HBRK Associates, Inc.; Nautilus, Inc.; Cypress, Inc.; and JEGE, Inc. (together, “Defendants”), jointly with Plaintiff Jane Doe 17 (“Plaintiff”), through counsel for Defendants, respectfully submit this stipulation (the “Stipulation”) together with the attached proposed Order on Plaintiff’s Motion For Leave to Proceed Anonymously (ECF #24).

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Dated: December 10, 2019
New York, New York

Respectfully submitted,

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 Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein; Nine East 71st Street Corporation; Laurel, Inc.; Financial Trust Company, Inc.; NES LLC; Maple, Inc.; LSJE, LLC; HBRK Associates, Inc.; Nautilus, Inc.; Cypress, Inc.; and JEGE, Inc.

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JANE DOE 17,
 Plaintiff,

v.

DARREN K. INDYKE AND
RICHARD D. KHAN, AS JOINT
PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN
NINE EAST 71st STREET CORPORATION,
LAUREL, INC., FINANCIAL TRUST COMPANY,
INC., NES LLC, MAPLE, INC., LSJE, LLC,
HBRK ASSOCIATES, INC., NAUTILUS, INC.,
CYPRESS, INC., and JEGE, INC.,
 Defendants.

Case No. 1:19-cv-09610-PAE

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:

1. 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 Defendants on matters related to 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 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 camerainspection.

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

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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.

SO ORDERED.

Date: <empty> New York, New York

HON. PAUL A. ENGELMAYER
United States District Judge

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JANE DOE 17,
 Plaintiff,

v.

DARREN K. INDYKE AND
RICHARD D. KHAN, AS JOINT
PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN
NINE EAST 71st STREET CORPORATION,
LAUREL, INC., FINANCIAL TRUST COMPANY, INC.,
NES LLC, MAPLE, INC., LSJE, LLC,
HBRK ASSOCIATES, INC., NAUTILUS, INC.,
CYPRESS, INC., and JEGE, INC.,
 Defendants.

Case No.: 1:19-cv-09610-PAE

NON-DISCLOSURE AGREEMENT

I,_____, acknowledge that I understand that the identity of the Plaintiff in this action is confidential. I agree that: (1) I will hold in confidence Plaintiff’s identity; (2) I will use Plaintiff’s identity only in connection with this litigation; 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]: <empty>

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court-records/Doe 17 v. Indyke, No. 119-cv-09610 (S.D.N.Y. 2019)/029.pdf
{"year":"2019","court":"S.D.N.Y","people":["darren indyke","richard kahn","jeffrey epstein","bennett moskowitz","paul a. engelmayer"]}