Case 1:19-cv-10577-LJL-DCF

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USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #: <empty>
DATE FILED: 1/24/2020

UNITED STATES DISTRICT COURT ELECTRONICALLY FILED

SOUTHERN DISTRICT OF NEW YORK DOC #:

JANE DOE 1000,

Plaintiff,

V.

Case No. 1:19-cv-10577-LGS-DCF

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

Defendants.

JOINT STIPULATION FOR
ORDER ON PLAINTIFFS' ANONYMITY

Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors ofthe Estate ofJeffrey E. Epstein (together "Defendants"), jointly with Plaintiff Jane Doe 1000 ("Plaintiff'), through counsel for Defendants, respectfully submit this stipulation (the "Stipulation") together with the attached Proposed Order on Plaintiffs Motion For Leave to Proceed Anonymously (the "Proposed Order") and accompanying Non-Disclosure Agreement (the "NDA").

The parties respectfully request the Court enter the Proposed Order and NDA to resolve Plaintiffs Motion For Leave to Proceed Anonymously (ECF #6).

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

JANE DOE 1000,
 Plaintiff,

v.

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

Case No. 1:19-cv-10577-LGS-DCF

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 ofthis Order, Counsel of Record for Plaintiff shall disclose Plaintiffs 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 ofsuch information shall not disclose it to any other persons.

3. If Defendants wish to disclose Plaintiffs 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 Plaintiffs identity to any other persons. Defendants must maintain a list ofall such persons to whom Plaintiffs identity is disclosed and copies of the executed non-disclosure agreements, all ofwhich are subject to in camera inspection.

4. All portions of pleadings, motions or other papers filed with the Court that disclose Plaintiffs identity shall be filed under seal with the Clerk ofthe 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 Plaintiffs identity and text that would reveal Plaintiffs 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: 1/24/2020
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<signature>
DEBRA FREEMAN
UNITED STATES MAGISTRATE JUDGE

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SO ORDERED.
Date: <empty>
New York, New York

Hon. Debra C. Freeman
United States Magistrate Judge
Southern District of New York

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORI(

JANE DOE 1000,
 Plaintiff,
 v.

Case No. 1:19-cv-10577-LGS-DCF

DARREN K. INDYKE and RICHARD D. KAHN,

in their capacities as the executors ofthe ESTATE OF JEFFREY EDWARD EPSTEIN,

Defendants.

NON-DISCLOSURE AGREEMENT

I,<empty>, 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 myselfto the jurisdiction ofthe United States District Court for the Southern District of New York for the purpose ofany 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:
<empty>
[Signature]

40962236
court-records/Doe 1000 v. Indyke, No. 119-cv-10577 (S.D.N.Y. 2019)/023.pdf
{"year":"2019","court":"S.D.N.Y","people":["darren indyke","richard kahn","jeffrey epstein","debra c. freeman"]}