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Case 1:19-cv-11869-MKV-DCF Document 32 Filed 06/12/20 Page 1 of 2

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

ANASTASIA DOE,

Plaintiff,
v. Case No. 1:19-cv-11869-MKV-DCF
DARREN K. INDYKE AND RICHARD D.
KAHN, AS CO-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 Anastasia 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.

42501282v1
Case 1:19-cv-11869-MKV-DCF Document 32 Filed 06/12/20 Page 2 of 2

2. After the lifting of the stay, if any, the Parties will confer on a schedule for the

remaining discovery in this action.

Dated: June 12, 2020 Respectfully submi

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