014.pdf

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

ANASTASIA DOE,

Plaintiff,

v.

DARREN K. INDYKE AND RICHARD D. KAHN
CO-EXECUTORS OF THE ESTATE OF JEFFREY
E. EPSTEIN,

Defendant.

Case No. 1:19-cv-11869-AJN

ORDER ON PLAINTIFF’S ANONYMITY

IT IS HEREBY ORDERED that any person subject to this Order, including the parties to
this action and their respective counsel of record, shall adhere to the following terms:

1. Within three (3) days of entry of this Order, Counsel of Record for Plaintiff shall disclose
Plaintiff’s identity to Counsel of Record for Defendants, in writing.

2. Counsel of Record for Defendants may disclose Plaintiff’s identity only to Defendants and
any attorneys, paralegals, and clerical or other assistants working with or for Defendants
on matters related to this action; and the recipients of such information shall not disclose it
to any other persons.

3. If Defendants wish to disclose Plaintiff’s identity to any person not otherwise permitted to
receive such information under this Order, Defendants are limited to doing so in connection
with defending this action, and must require such person to first execute a non-disclosure
agreement, in a form agreed to by the parties, that prevents such person from disclosing
Plaintiff’s identity to any other persons. Defendants must maintain a list of all such persons
to whom Plaintiff’s identity is disclosed and copies of the executed non-disclosure
agreements, all of which are subject to in camera inspection.

4. All portions of pleadings, motions or other papers filed with the Court that disclose
Plaintiff’s identity shall be filed under seal with the Clerk of the Court and kept under seal
until further order of the Court. The parties shall use their best efforts to minimize such
sealing. Any party filing a motion or any other papers with the Court under seal shall also
publicly file a redacted copy of the same, via the Court’s Electronic Case Filing system,
that redacts the Plaintiff’s identity and text that would reveal Plaintiff’s identity.
Case 1:19-cv-11869-MKV-DCF Document 14 Filed 01/28/20 Page 1 of 4

5. The parties may seek to modify or amend this Order at any time upon motion to the Court
or by stipulation.

SO ORDERED.

Date: __________________ ____________________________
New York, New York Alison J. Nathan
United States District Judge
Case 1:19-cv-11869-MKV-DCF Document 14 Filed 01/28/20 Page 2 of 4

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

ANASTASIA DOE,

Plaintiff,

v.

DARREN K. INDYKE AND RICHARD D. KAHN
CO-EXECUTORS OF THE ESTATE OF JEFFREY
E. EPSTEIN,

Defendant.

Case No. 1:19-cv-11869-AJN

JOINT STIPULATION FOR ORDER
ON PLAINTIFF’S ANONYMITY

Plaintiff, Anastasia Doe (“Plaintiff”), jointly with Defendants Darren K. Indyke and
Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, through undersigned counsel
for Plaintiff, hereby respectfully submit the following Stipulation and (Proposed) Order on
Plaintiff’s Anonymity.

The parties have reached an agreement on a form Anonymity Order, which includes the
condition that a Non-Disclosure Agreement be signed by any non-party provided with the identity
of Plaintiff.

The parties respectfully request the Court enter the attached (proposed) Order and Agreed
Non-Disclosure Agreement.

Dated: January 28, 2020
New York, New York
Case 1:19-cv-11869-MKV-DCF Document 14 Filed 01/28/20 Page 3 of 4

Respectfully Submitted,
EDWARDS POTTINGER, LLC

By: Bradley J. Edwards
Bradley J. Edwards
425 N. Andrews Ave., Suite 2
Fort Lauderdale, FL 33301
(954)-524-2820
Fax: (954)-524-2822
Email: ecf@epllc.com
brad@epllc.com
brittany@epllc.com

Attorneys for Plaintiff
(ADMISSION PRO HAC VICE)
Case 1:19-cv-11869-MKV-DCF Document 14 Filed 01/28/20 Page 4 of 4