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Case 1:19-cv-10479-ALC-DCF Document 12 Filed 01/24/20 Page 1 of 4
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutmariP
troutman.com
sanders
Bennet J. Moskowitz
bennet.moskowitz@troutman.com
January 24, 2020
ECF
Hon. Andrew L. Carter Jr.
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007
Re: Juliette Bryant v. Darren K. Indyke and Richard D. Kahn, in their capacities as
executors of the Estate of Jeffrey E. Epstein, 1:19-cv-10479-ALC-DCF
Dear Judge Carter:
We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of
Jeffrey E. Epstein (together, the “Co-Executors”), in the above-referenced action. We write
pursuant to Your Honor’s Individual Practice § 2(A) to set forth the bases for the Co-Executors’
anticipated motion pursuant to Fed. R. Civ. P. 12(b)(6) to dismiss the time-barred claims and
punitive damages demand in Plaintiff Juliette Bryant’s (“Plaintiff”) Complaint (ECF No. 1).
1. Plaintiff is a South African resident who alleges Decedent committed torts against
her from 2002 to 2004 when she was an adult, in various jurisdictions.
Plaintiff, who claims South African citizenship and residency, alleges that, from 2002 (when she
was 20) to 2004, Mr. Epstein (“Decedent”), now deceased, committed various sexual offenses
against her in the U.S. Virgin Islands (“USVI”), France, Florida, New Mexico and New York.
(Compl. ¶¶ 16, 38, 50, 55.) Plaintiff asserts two causes of action -- battery and intentional
infliction of emotional distress -- and demands punitive damages. (Id. ¶¶ 54-64, p. 15.)
2. Plaintiff’s causes of action are time-barred.
CPLR § 202 provides that, when a non-N.Y. resident such as Plaintiff sues on causes of action
accruing outside N.Y., the complaint must be time
[…]