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      Case
       Case1:19-cv-10577-LJL-DCF
             1:19-cv-10577-LJL-DCF Document
                                   Document63  Filed06/12/20
                                            61 Filed 06/15/20 Page
                                                               Page11
                                                                    ofof
                                                                       22



                              UNITED STATES DISTRICT COURT
                             SOUTHERN DISTRICT OF NEW YORK

JANE DOE 1000,

                                 Plaintiff,
                  v.                                         Case No. 1:19-cv-10577-LJL-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                               DF
        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 Jane Doe 1000 (“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.        Th

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