Extraction Summary

7
People
5
Organizations
2
Locations
2
Events
4
Relationships
3
Quotes

Document Information

Type: Legal document (joint stipulation and proposed order)
File Size: 26 KB
Summary

This is a Joint Stipulation and Proposed Order filed in the US District Court (SDNY) on June 12, 2020, in the case of Jane Doe 1000 v. The Estate of Jeffrey Epstein. The parties agreed to stay (pause) the lawsuit for 60 days to allow the Plaintiff to participate in the Epstein Victims' Compensation Program, a non-adversarial alternative for resolving sexual abuse claims. If the claim is resolved through the program, the Plaintiff agrees to discontinue the legal action with prejudice.

People (7)

Name Role Context
Jane Doe 1000 Plaintiff
Victim seeking compensation through 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; claims of sexual abuse are being made against him
Sigrid McCawley Attorney
Attorney for Plaintiff; Partner at Boies, Schiller & Flexner LLP
Bennet J. Moskowitz Attorney
Attorney for Defendants; Partner at Troutman Sanders LLP
Debra C. Freeman Judge
Hon. United States Magistrate Judge (Signature line provided for order)

Organizations (5)

Name Type Context
United States District Court Southern District of New York
Venue of the legal action
Estate of Jeffrey Edward Epstein
Represented by Indyke and Kahn
Epstein Victims’ Compensation Program
Non-adversarial alternative to litigation for resolving claims
Boies, Schiller & Flexner LLP
Representing the Plaintiff
Troutman Sanders LLP
Representing the Defendants

Timeline (2 events)

2020-06-12
Filing of Joint Stipulation and Proposed Order Staying Action
New York, New York
2020-06-12
Proposed stay of action for 60 days to allow participation in Compensation Program
SDNY
Jane Doe 1000 Estate of Jeffrey Epstein

Locations (2)

Location Context
Location of the court and filing location
Address for Sigrid McCawley

Relationships (4)

Jane Doe 1000 Accuser/Accused Jeffrey Edward Epstein
Plaintiff bringing sexual abuse claims against Decedent
Executor of the Estate of Jeffrey Edward Epstein
Executor of the Estate of Jeffrey Edward Epstein
Sigrid McCawley Legal Counsel Jane Doe 1000
Attorneys for Plaintiff

Key Quotes (3)

"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"
Source
061.pdf
Quote #1
"Plaintiff will promptly discontinue this action with prejudice."
Source
061.pdf
Quote #2
"The captioned action is hereby stayed, both as to discovery and to the resolution of any pending motions, for sixty (60) days from the date of entry of this Order."
Source
061.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (2,245 characters)

Case 1:19-cv-10577-LJL-DCF Document 61 Filed 06/12/20 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE 1000,
Plaintiff,
v.
DARREN K. INDYKE and RICHARD D. KAHN
in their capacities as the executors of the ESTATE
OF JEFFREY EDWARD EPSTEIN,
Defendants.
Case No. 1:19-cv-10577-LJL-DCF
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 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. The captioned action is hereby stayed, both as to discovery and to the resolution of
any pending motions, for sixty (60) days from the date of entry of this Order.
42498352v1
Case 1:19-cv-10577-LJL-DCF Document 61 Filed 06/12/20 Page 2 of 2
2. After the expiration of the stay, if any, the Parties will confer on a schedule for the
remaining discovery in this action.
Dated: June 12, 2020
New York, New York
Respectfully submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
Sigrid McCawley
401 E. Las Olas Blvd. Suite 1200
Fort Lauderdale, FL, 33301
(954) 377 4223
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
Attorneys for Defendants
Date: __________________, 2020
New York, New York
______________________________
HON. DEBRA C. FREEMAN
United States Magistrate Judge
2
42498352v1

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