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Case 1:19-cv-10474-NRB Document 13 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. Naomi Reice Buchwald
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, NY 10007-1312
Re: Maria Farmer v. Darren K. Indyke and Richard D. Kahn, as Executors of the Estate
of Jeffrey E. Epstein, 1:19-cv-10474 (NRB)
Dear Judge Buchwald:
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 Rules 1(A) and 2(B) to request a pre-motion conference in
connection with the Co-Executors’ anticipated motion pursuant to Fed. R. Civ. P. 12(b)(6) to
dismiss Plaintiff Maria Farmer’s (“Plaintiff”) Complaint (ECF No. 1) which is time-barred and
impermissibly seeks punitive damages.
1. Plaintiff is an Arkansas resident who alleges Decedent committed torts against
her in Ohio in 1995 or 1996 when she was 26 years old.
Plaintiff, who claims Arkansas citizenship and residency, alleges that Mr. Epstein (“Decedent”),
now deceased, sexually assaulted her in 1995 or 1996 in Ohio. (Compl. ¶¶ 1, 11, 35, 46, 48.)
Plaintiff asserts two causes of action -- battery and intentional infliction of emotional distress --
and demands punitive damages. (Id. ¶¶ 59 – 68, p. 15.)
2. Plaintiff’s causes of action are time-barred.
CPLR § 202 provides that, when a non-New York resident such as Plaintiff sues on a cause of
action accruing outside New York, the complaint must be filed timely under the statute of
limitations of both New York and the jurisdiction where the ca
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