028.pdf
142 KB
Extraction Summary
7
People
5
Organizations
3
Locations
2
Events
4
Relationships
3
Quotes
Document Information
Type:
Legal document (joint stipulation and proposed order)
File Size:
142 KB
Summary
A legal stipulation filed on April 9, 2020, in the Southern District of New York, wherein Plaintiff Maria Farmer and the Executors of Jeffrey Epstein's estate (Indyke and Kahn) agreed to stay the lawsuit. The stay was requested to allow Farmer to participate in the 'Epstein Victims’ Compensation Program,' a non-adversarial alternative for resolving sexual abuse claims against the estate.
People (7)
| Name | Role | Context |
|---|---|---|
| Maria Farmer | Plaintiff |
Victim seeking to participate in the Epstein Victims' Compensation Program
|
| Darren K. Indyke | Defendant |
Co-Executor of the Estate of Jeffrey Edward Epstein
|
| Richard D. Kahn | Defendant |
Co-Executor of the Estate of Jeffrey Edward Epstein
|
| Jeffrey Edward Epstein | Decedent |
Deceased; estate being sued for sexual abuse claims
|
| Sigrid S. McCawley | Attorney |
Counsel for Plaintiff (Boies Schiller Flexner LLP)
|
| Bennet J. Moskowitz | Attorney |
Counsel for Defendants (Troutman Sanders LLP)
|
| Naomi Reice Buchwald | Judge |
United States District Judge presiding over the case
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of New York |
Court where the case is filed
|
|
| Estate of Jeffrey Edward Epstein |
Defendant entity
|
|
| Epstein Victims’ Compensation Program |
Program designed to resolve sexual abuse claims
|
|
| Boies Schiller Flexner LLP |
Law firm representing the Plaintiff
|
|
| Troutman Sanders LLP |
Law firm representing the Defendants
|
Timeline (2 events)
2020-04-02
Court Order referenced regarding motion to dismiss
Southern District of New York
Court
2020-04-09
Filing of Joint Stipulation and Proposed Order Staying Action
Southern District of New York
Locations (3)
| Location | Context |
|---|---|
|
Location of the court and filing
|
|
|
Address of Plaintiff's attorney
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|
|
Address of Defendants' attorney
|
Relationships (4)
Plaintiff bringing sexual abuse claims against Decedent's estate
Executor of the Estate of Jeffrey Edward Epstein
Executor of the Estate of Jeffrey Edward Epstein
Attorneys for Plaintiff
Key Quotes (3)
"WHEREAS independent claims administration experts are designing and 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"Source
028.pdf
Quote #1
"Plaintiff Maria Farmer... seeks to participate in the Program"Source
028.pdf
Quote #2
"The captioned action is hereby stayed pending further Order of the Court."Source
028.pdf
Quote #3
Full Extracted Text
Complete text extracted from the document (2,449 characters)
Case 1:19-cv-10474-NRB Document 28 Filed 04/09/20 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SOUTHERN DISTRICT OF NEW YORK
MARIA FARMER,
Plaintiff,
v.
DARREN K. INDYKE and RICHARD D. KAHN
in their capacities as the executors of the ESTATE
OF JEFFREY EDWARD EPSTEIN,
in their capacities as the executors of the ESTATE
OF JEFFREY EDWARD EPSTEIN,
Defendants.
Case No. 1:19-cv-10474-NRB
JOINT STIPULATION AND [PROPOSED] ORDER STAYING ACTION
WHEREAS independent claims administration experts are designing and 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
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 Maria Farmer (“Plaintiff,” and together with Defendants Darren K.
Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, the “Parties”) seeks
to participate in the Program; and
Indyke and Richard D. Kahn, 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 unless and until (1) Plaintiff ceases her participation in the Program or (2) Plaintiff’s
participation in the Program is no longer a possibility; and
this action unless and until (1) Plaintiff ceases her participation in the Program or (2) Plaintiff’s
participation in the Program is no longer a possibility; and
WHEREAS should Plaintiff resolve her claims against Decedent via the Program, the
Parties will thereafter promptly discontinue this action with prejudice.
Parties will thereafter promptly discontinue this action with prejudice.
IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel
for the Parties, that:
for the Parties, that:
1. The captioned action is hereby stayed pending further Order of the Court.
Case 1:19-cv-10474-NRB Document 28 Filed 04/09/20 Page 2 of 2
2. After the lifting of the stay, if any, Defendants may file their motion to dismiss
Plaintiff’s Amended Complaint without the need for a pre-motion conference, as set forth
in the Court’s April 2, 2020 Order (ECF No. 27); and the Parties will confer on a briefing
schedule for Defendants’ motion in which no more than sixty (60) days elapse from the
filing of Defendants’ motion to the filing of Defendants’ reply.
Plaintiff’s Amended Complaint without the need for a pre-motion conference, as set forth
in the Court’s April 2, 2020 Order (ECF No. 27); and the Parties will confer on a briefing
schedule for Defendants’ motion in which no more than sixty (60) days elapse from the
filing of Defendants’ motion to the filing of Defendants’ reply.
Dated: April 9, 2020
New York, New York
New York, New York
Respectfully submitted,
BOIES SCHILLER FLEXNER LLP
By: /s/ Sigrid S. McCawley
Sigrid S. McCawley
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
Email: smccawley@bsfllp.com
Sigrid S. McCawley
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
Email: smccawley@bsfllp.com
Attorneys for Plaintiff
TROUTMAN SANDERS LLP
By: /s/ Bennet J. Moskowitz
Bennet J. Moskowitz
875 Third Avenue
New York, NY 10022
(212) 704-6000
bennet.moskowitz@troutman.com
Bennet J. Moskowitz
875 Third Avenue
New York, NY 10022
(212) 704-6000
bennet.moskowitz@troutman.com
Attorneys for Defendants
Date: April __, 2020
New York, New York
New York, New York
HON. NAOMI REICE BUCHWALD
United States District Judge
2
United States District Judge
2
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