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Case 1:19-cv-10476-PGG-DCF Document 51 Filed 06/12/20 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
TERESA HELM,
Plaintiff,
v. Case No. 1:19-cv-10476-PGG-DCF
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 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 Teresa Helm (“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 for sixty (60) days while Plaintiff participates in the Program; and
WHEREAS should Plaintiff resolve her claims against Decedent via the Program,
Plaintiff will 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, both as to discovery and to the resolution of
any pending motions, for sixty (60) days from the date of entry of this Order.
42498340v1
Case 1:19-cv-10476-PGG-DCF Document 51 Filed 06/12/20 Page 2 of 2
2. After the expiration of the stay, if any, the Parties will confer on a schedule for the
remaining discovery in this action.
Dated: June 12, 2020
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