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Case 1:19-cv-10577-LJL-DCF Document 22 Filed 01/16/20 Page 1 of 5
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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 of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
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 (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 Plaintiff’s 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
Plaintiff’s Motion For Leave to Proceed Anonymously (ECF #6).
41028270
Case 1:19-cv-10577-LJL-DCF Document 22 Filed 01/16/20 Page 2 of 5
Dated: January 16, 2020 Respectfully submitted,
New York, New York
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. Indyk
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