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Case 1:20-cv-02365-LJL-DCF Document 12 Filed 07/10/20 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE,
Plaintiff,
v. Case No. 1:20-civ-02365-LJL-DCF
DARREN K. INDYKE AND RICHARD D. KAHN,
in their capacities AS EXECUTORS OF THE
ESTATE OF JEFFREY E. EPSTEIN,
Defendants.
JOINT STIPULATION AND [PROPOSED] 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 Jane Doe (“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 unless and until Plaintiff elects to resume the litigation and requests the stay be lifted;
and
WHEREAS should Plaintiff resolve her claims against Defendants 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.
108707047
Case 1:20-cv-02365-LJL-DCF Document 12 Filed 07/10/20 Page 2 of 2
2. After the lifting of the stay, if any, the Parties will confer on a schedule to answer, move,
or otherwise respond to Plaintiff’s Complaint and any motion to proceed anonymously.
Dated: July 10, 2020
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