06/23/2010 11:03 5618327/37 GARCIA LAW FIRM PA PAGE 02/07 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----- ------ ------- -------- — --------- ----x Jane Doe. -against- STRICTLY CONFIDENTIAL DRAFT - FOR DISCUSSION ONLY Plaintiff, 08-CV-90119 (Southern District of Florida) STIPULATION OF JEFFREY EPSTEIN, CONFIDENTIALITY Defendant. --------- ail...m.••••hmmn•m. x WHEREAS, plaintiff Jane Doe and defendant Jeffrey Epstein ("Epstein") arc presently engaged in discovery in the above-captioned civil action pending in the United States District Court for the Southern District of Florida; WHEREAS, thirteen related civil actions are currently pending against defendant Epstein: (collectively with the above-captioned action, the "Related Pending Actions"). The Related Pending Actions are identified on Schedule A attached hereto; WHEREAS, counsel in all Related Pending Actions shall be collectively referred to herein as ("Counsel"); WHEREAS, Obislathe Noe:le Maxwell ("Maxwell"). a non-party, was served with a subpoena dated September 21, 2009 issued out of the United States District Court for the Southern District of New York (the "Subpoena") to testify at a deposition in connection with the above-captioned matter; WHEREAS, Maxwell has requested, and Counsel has agreed, that all aspects of her involvement in this matter, including but not limited to, the issuance of the Subpoena, the fact of EFTA00181291