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Case 1:19-cv-10474-NRB Document 29
28 Filed 04/10/20
04/09/20 Page 1 of 2
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
28 Filed 04/10/20
04/09/20 Page 2 of 2
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