Case 1:20-cv-00484-JGK-DCF Document 92 Filed 01/29/21 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JANE DOE, Plaintiff, Case No. 1:20-cv-00484-JGK-DCF v. DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, and GHISLAINE MAXWELL, an individual, Defendants. CO-EXECUTORS' RESPONSE TO PLAINTIFF'S MOTION TO DISMISS WITH PREJUDICE PURSUANT TO FRCP 41(a)(21 Defendants Darren K. Indyke and Richard D. Kahn, in their capacities as Co-Executors of the Estate of Jeffrey E. Epstein (the "Co-Executors"), submit this response to Plaintiff Jane Doe's Motion to Dismiss With Prejudice Pursuant to FRCP 41(a)(2) (ECF No. 37). As the Co-Executors previously advised the Court, they have no objection to Plaintiff's request that the Court dismiss this action following her decision to accept the Epstein Victims' Compensation Program's (the "Program") independent Administrator's compensation determination. Accordingly, and as Plaintiff's counsel accurately notes, on December 21, 2020, the Co-Executors executed the Joint Stipulation for Dismissal of Entire Action With Prejudice (ECF No. 87). The Co-Executors submit this Response solely to address Plaintiff's request for "alternate relief'—namely, for the Court to "enter dismissal with prejudice as to [the Co-Executors]...and allow Plaintiff to continue the prosecution of her case against Ms. Maxwell." (Pl.'s Mem. of Law [ECF 91-1] at p. 3.) Such relief would be inappropriate. -1- EFTA02752384