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Case 1:19-cv-10577-LJL-DCF Document 24 Filed 01/24/20 Page 1 of 3
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. Lorna G. Schofield
Thurgood Marshall
United States Courthouse
40 Foley Square
New York, NY 10007
Re: Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, in their capacities as the
executors of the Estate of Jeffrey Edward Epstein, 19-cv-10577-LGS-DCF
Dear Judge Schofield:
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 referenced action. We write pursuant to
Your Honor’s Individual Rule III(C)(2) to request a conference on and to explain the bases for
the Co-Executors’ anticipated motion pursuant to Fed. R. Civ. P. 12(b)(6) to dismiss Plaintiff
Jane Doe 1000’s (“Plaintiff”) Complaint (ECF No. 1). We propose this briefing schedule: moving
brief by February 24, 2020; opposition brief by March 25, 2020; and reply brief by April 8, 2020.
1. Plaintiff is a New Jersey resident who alleges Decedent committed torts against
her in or around 1999 in New York and Florida; Plaintiff’s causes of action expired
nearly two decades ago.
Plaintiff, a New Jersey citizen and resident, alleges that, in or about 1999, Mr. Epstein
(“Decedent”), now deceased, committed sexual offenses against her in New York and Florida
(Compl. ¶¶ 16, 38, 50, 55.) Plaintiff asserts two causes of action -- battery and intentional
infliction of emotional distress -- and demands punitive damages. (Id. ¶¶ 49-59, p. 13.)
Plaintiff does not allege she was a minor when Decedent sexually abused her in or around
1999. Therefore, Plaintiff’s
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