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Case 1:19-cv-10577-LJL-DCF Document 54 Filed 05/21/20 Page 1 of 13
UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
Plaintiff, CASE NO: 19-cv-10577-LJL-DCF
v.
DARREN K. INDYKE and RICHARD D. KAHN,
in their capacities as the executors of the
ESTATE OF JEFFREY EDWARD EPSTEIN,
Defendants.
_____________________________________
STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER
WHEREAS, Plaintiff Jane Doe 1000 and Defendants Darren K. Indyke and Richard D.
Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, (collectively, the “Parties” and each
individually, a “Party”) request that this Court issue a protective order pursuant to Federal Rule
of Civil Procedure 26(c) to protect the confidentiality of nonpublic and sensitive information that
they may need to disclose in connection with discovery in this action;
WHEREAS, the Parties, through counsel, agree to the following terms; and
WHEREAS, this Court finds that good cause exists for issuance of an appropriately
tailored confidentiality order governing the pretrial phase of this action;
IT IS HEREBY ORDERED that the Parties to this action, their respective agents,
employees, and attorneys, any other person in active concert or participation with any of the
Case 1:19-cv-10577-LJL-DCF Document 54 Filed 05/21/20 Page 2 of 13
foregoing, and all other persons with actual notice of this Order will adhere to the following
terms, upon pain of contempt:
1. “Producing Party” shall mean the parties to this action and any third parties
producing Confidential Information.
2. “Receiving Party” shall mean the party to this action and/or any non-party
receiving Confidential Information.
3. With respect to “Discovery Material” (i.
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