Case 1:19-cv-10474-NRB

Document 29

Filed 04/09/20

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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

MARIA FARMER,

Plaintiff,

V.

Case No. 1:19-cv-10474-NRB

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

Defendants.

## JOINT STIPULATION AND [PROPOSED] ORDER STAYING ACTION

WHEREAS independent claims administration experts are designing and 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 Maria Farmer (“Plaintiff,” and together with Defendants Darren K. Indyke and Richard D. Kahn, 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 (1) Plaintiff ceases her participation in the Program or (2) Plaintiff’s participation in the Program is no longer a possibility; and

WHEREAS should Plaintiff resolve her claims against Decedent 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:

1. The captioned action is hereby stayed pending further Order of the Court.

Case 1:19-cv-10474-NRB

Document 29

Filed 04/09/20

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2. After the lifting of the stay, if any, Defendants may file their motion to dismiss Plaintiff’s Amended Complaint without the need for a pre-motion conference, as set forth in the Court’s April 2, 2020 Order (ECF No. 27); and the Parties will confer on a briefing schedule for Defendants’ motion in which no more than sixty (60) days elapse from the filing of Defendants’ motion to the filing of Defendants’ reply.

Dated: April 9, 2020
New York, New York

Respectfully submitted,
BOIES SCHILLER FLEXNER LLP

By: /s/ Sigrid S. McCawley
Sigrid S. McCawley
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
Email: smccawley@bsfllp.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

<signature>
HON. NAOMI REICE BUCHWALD
United States District Judge

Date: April 10, 2020
New York, New York

New York, New York HON. NAOMI REICE BUCHWALD

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