Extraction Summary

7
People
8
Organizations
4
Locations
1
Events
5
Relationships
3
Quotes

Document Information

Type: Legal filing (joint stipulation and proposed order)
File Size: 20.6 KB
Summary

This document is a Joint Stipulation and Proposed Order filed on June 12, 2020, in the U.S. District Court for the Southern District of New York (Case No. 1:19-cv-07625). The plaintiff, identified as 'VE', and the defendants (Executors of the Epstein Estate and associated entities) agreed to stay the lawsuit to allow the plaintiff to participate in the 'Epstein Victims' Compensation Program', a non-adversarial alternative for resolving sexual abuse claims. The document is signed by attorneys Brad Edwards (for the plaintiff) and Bennet J. Moskowitz (for the defendants).

People (7)

Name Role Context
VE Plaintiff
Victim suing the Epstein Estate; seeks to participate in the Victims' Compensation Program
Darren K. Indyke Defendant
Joint Personal Representative/Co-Executor of the Estate of Jeffrey E. Epstein
Richard D. Kahn Defendant
Joint Personal Representative/Co-Executor of the Estate of Jeffrey E. Epstein
Jeffrey E. Epstein Decedent
Deceased; claims of sexual abuse against him are the subject of the litigation
Brad Edwards Attorney
Attorney for Plaintiff; Edwards Pottinger LLC
Bennet J. Moskowitz Attorney
Attorney for Defendants; Troutman Sanders LLP
Debra C. Freeman Judge
United States District Judge (signature line for proposed order)

Organizations (8)

Name Type Context
United States District Court Southern District of New York
Venue of the litigation
The Estate of Jeffrey E. Epstein
Estate being sued
Nine East 71st Street Corporation
Corporate entity associated with Epstein
Financial Trust Company, Inc.
Corporate entity associated with Epstein
NES, LLC
Corporate entity associated with Epstein
Epstein Victims' Compensation Program
Non-adversarial alternative to litigation for resolving claims
Edwards Pottinger LLC
Representing the Plaintiff
Troutman Sanders LLP
Representing the Defendants

Timeline (1 events)

2020-06-12
Filing of Joint Stipulation and Proposed Order Staying Action
New York, New York

Locations (4)

Location Context
Location of the court and signing of the document; address for Troutman Sanders LLP
Address for Edwards Pottinger LLC
Address for Bennet J. Moskowitz
Address for Brad Edwards

Relationships (5)

VE Accuser/Alleged Victim Jeffrey E. Epstein
VE is Plaintiff in sexual abuse claims against decedent Epstein
Indyke is Joint Personal Representative of the Estate of Jeffrey E. Epstein
Kahn is Joint Personal Representative of the Estate of Jeffrey E. Epstein
Brad Edwards Attorney/Client VE
Brad Edwards listed as Attorneys for Plaintiff
Bennet J. Moskowitz Attorney/Client Darren K. Indyke
Moskowitz listed as Attorneys for Defendants

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
065.pdf
Quote #1
"Plaintiff VE... seeks to participate in the Program"
Source
065.pdf
Quote #2
"The captioned action is hereby stayed pending further Order of the Court."
Source
065.pdf
Quote #3

Full Extracted Text

Complete text extracted from the document (2,304 characters)

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.
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.
Case No. 1:19-07625-AJN-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 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 confer on a schedule for the
remaining discovery in this action.
Dated: June 12, 2020
New York, New York
Respectfully submitted,
EDWARDS POTTINGER LLC
By: /s/ Brad Edwards
Brad Edwards
425 North Andrews Avenue, Suite 2
Fort Lauderdale, Florida 33301
Tel: (954) 524-2820
brad@epllc.com
Attorneys for Plaintiff
TROUTMAN SANDERS LLP
By: /s/Bennet 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 District Judge
2
42501382v1

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