IS IIII 'I PI RIOR ( O1 RI O1 !III 'KU% ISI %NI" FILED Cune 01, 2020 TAMARA CHARLES CLERK OF THE COURT IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS DIVISION OF ST. AND ST. JOHN CIVIL CASE NO.: ST-20-CV-I55 GHISLAINE MAXWELL, Plaintiff, vs. ESTATE OF JEFFREY E. EPSTEIN, DARREN K. INDYKE, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, RICHARD D. KAHN, in his capacity as EXECUTOR OF THE ESTATE OF JEFFREY E. EPSTEIN, and NES, LLC, a New York Limited Liability Company, Defendants. JOINT MOTION TO STAY PROCEEDINGS Plaintiff GH1SLAINE MAXWELL ("Plaintiff'), and Defendants DARREN K. INDYKE ("lndyke") and RICHARD D. KAHN ("Kahn"), by and though their undersigned counsel, in their capacity as Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), and on behalf of the Estate and NES, LLC, an entity administered in probate by the Co-Executors as part of the Estate (collectively, the "Defendants"), through their respective undersigned attorneys, hereby file this Joint Motion to Stay Proceedings until September 7, 2020, and state as follows: I. "The power to stay proceedings is incidental to the power inherent in every court to control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants." v. Treasure Bay V.I. Corp., 2016 WL 9503682, at *3 (V.1. Super. Oct. 6, 2016) (citing Landis v. North American Co., 299 U.S. 248, 254-55 (1936)). Generally, the party seeking a stay "must make out a clear case of hardship or inequity in being required to go EFTA02822002