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Case 1:19-cv-09610-PAE-DCF Document 38 Filed 01/08/20 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE 17,
Plaintiff,
v. Case No. 1:19-cv-09610-PAE-DCF
DARREN K. INDYKE AND RICHARD D. KAHN,
AS JOINT PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN, NINE
EAST 71st STREET CORPORATION, LAUREL,
INC., FINANCIAL TRUST COMPANY, INC.,
NES, LLC, MAPLE, INC., LSJE, LLC, HBRK
ASSOCIATES, INC., NAUTILUS, INC.,
CYPRESS, INC. and JEGE, INC.
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 Jane Doe 17 (“Plaintiff”; and together with Defendants Darren K.
Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, Nine East 71st
Street Corporation, Laurel, Inc., Financial Trust Company Inc., NES LLC, Maple, Inc., LSJE,
LLC, HBRK Associates, Inc., Nautilus, Inc., Cypress, Inc., and JEGE, Inc., 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 ceases her participation in the Program; and
40967362v1
Case 1:19-cv-09610-PAE-DCF Document 38 Filed 01/08/20 Page 2 of 2
WHEREAS, should Plaintiff resolve her claims against Decedent via the Program, the
Parties will thereafter promptly discontinue this action with prejudice;
WHEREAS, on December 23, 2019, Defendants moved to dismiss Plaintiff’s Complaint
(ECF Nos. 34-36); and
WHEREAS
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