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      Case 1:19-cv-07625-AJN-DCF             Document 65        Filed 06/12/20      Page 1 of 2




                            UNITED STATES DISTRICT COURT
                           SOUTHERN DISTRICT OF NEW YORK

VE,

                               Plaintiff,
                  v.                                        Case No. 1:19-07625-AJN-DCF
DARREN K. INDYKE AND RICHARD D. KAHN,
AS JOINT PERSONAL REPRESENTATIVES OF
THE ESTATE OF JEFFREY E. EPSTEIN, NINE
EAST 71st STREET, CORPORATION, FINANCIAL
TRUST COMPANY, INC., NES, LLC,
                               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 VE (“Plaintiff,” and together with Defendants, Darren K. Indyke and

Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein, Nine East 71st Street,

Corporation, Financial Trust Company, Inc., and NES, LLC, the “Parties”) seeks to participate in

the Program; and

        WHEREAS the Parties seek to preserve their resources and judicial economy by staying

this action unless and until Plaintiff elects to resume the litigation and requests the stay be lifted;

and

        WHEREAS should Plaintiff resolve her claims against Defendants via the Program, the

Parties will thereafter promptly discontinue this action with prejudice.




42501382v1
     Case 1:19-cv-07625-AJN-DCF               Document 65         Filed 06/12/20   Page 2 of 2




        IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel

for the Parties, that:

        1.      The captioned action is hereby stayed pending further Order of the Court.

        2.      After the lifting of the stay, if any, the Parties will con

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