Case 1:19-cv-09610-PAE-DCF

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# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JANE DOE 17,

Plaintiff,

V.

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

DARREN K. INDYKE AND RICHARD D. KAHN, 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 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 Jane Doe 17 (“Plaintiff”; and together with 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., 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 Plaintiff ceases her participation in the Program; and

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WHEREAS, should Plaintiff resolve her claims against Decedent via the Program, the Parties will thereafter promptly discontinue this action with prejudice;

WHEREAS, on December 23, 2019, Defendants moved to dismiss Plaintiff’s Complaint (ECF Nos. 34-36); and

WHEREAS Plaintiff intends to amend her Complaint (ECF No. 1);

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; (2) Plaintiff has 30 days from after the lifting of the stay, if any, to amend her Complaint; and (3) Defendants have 30 days from Plaintiff’s filing of her Amended Complaint to answer, move or otherwise respond thereto.

Dated: January 8, 2020
New York, New York

Respectfully submitted,

Weisman, Brodie, Starr & Margolies, P.A.
By: /s/ David H. Brodie
David H. Brodie, Esq.
Laura J. Starr, Esq
1301 N. Federal Highway
Lake Worth, FL 33460
Telephone: (561) 588-9500

Attorneys for Plaintiff

TROUTMAN SANDERS LLP
By: /s/ Bennet J. Moskowitz
Bennet J. Moskowitz
875 Third Avenue
New York, NY 10022
(212) 704-6000
Attorneys for Defendants

Date: <empty>

New York, New York
HON. DEBRA FREEMAN
United States Magistrate Judge

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