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      Case 1:19-cv-10788-GHW-DCF              Document 46       Filed 06/19/20       Page 1 of 2




                             UNITED STATES DISTRICT COURT
                            SOUTHERN DISTRICT OF NEW YORK

TEALA DAVIES,

                               Plaintiff,
                  v.                                        Case No. 1:19-10788-GHW-DCF
DARREN K. INDYKE AND RICHARD D. KAHN
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 Teala Davies (“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.


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    Case 1:19-cv-10788-GHW-DCF              Document 46          Filed 06/19/20    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 19, 2020                                 Respectfully submitted,
       New Y

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