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Case 1:20-cv-02365-LJL-DCF Document 49 Filed 09/10/21 Page 1 of 1
Troutman Pepper Hamilton Sanders LLP
875 Third Avenue troutmafiii
New York, New York 10022
pepper
troutman.com
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
September 10, 2021
VIA ECF
Hon. Debra C. Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007
Re: Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as
the Executors of the Estate of Jeffrey E. Epstein, 1:20-cv-02365-LJL-DCF
Dear Judge Freeman:
We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors
of the Estate of Jeffrey E. Epstein, in the referenced action. We write jointly with Plaintiff
to report that the parties are attempting to resolve this matter extrajudicially. Accordingly,
to preserve the parties’ resources and in the interest of judicial economy, the parties
respectfully request that the Court enter a sixty-day stay of this action, through November
9, 2021. Should the parties resolve Plaintiff’s claims through settlement, they will
thereafter promptly discontinue this action with prejudice.
Respectfully submitted,
/s/ Bennet J. Moskowitz
Bennet J. Moskowitz
cc: Counsel of Record (via ECF)