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Under Paragraph
Case2(F)1:19-cv-10577-LJL-DCF
of the Court's Individual Practices in Civil Cases, 55
Document available at https://nysd.uscourts.gov/honlewis-j-liman,
Filed 05/22/20 Page 1 of 13 "All
parties wishing to propose a protective order must, after receiving the Court’s permission in accordance with Paragraph 1(B), submit a
proposed protective order that conforms as closely as possible with the Court’s Model Protective Order, which is available on the Judge’s
website. Any changes must be reflected in a redline that should be filed as an exhibit to the proposed protective order." The parties are
granted permission to file a proposed protective order but shall do so in accordance with the instructions above.
SO ORDERED.
5/22/2020
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 conne
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