Court records
- Format
- Set
- Court Records
- Text
- Searchable
Text as released
Machine-read from the scan. Names, dates and numbers can be misread — check anything you rely on against the original page.
Case 1:19-cv-10474-NRB Document 25 Filed 03/27/20 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
March 27, 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 Rule 2(B) to request a pre-motion conference in anticipation
of moving to dismiss Plaintiff Maria Farmer’s (“Plaintiff”) Amended Complaint (ECF No. 22)
because it is time-barred and impermissibly seeks punitive damages.
As a matter of context, we previously requested a pre-motion conference in anticipation of
moving to dismiss Plaintiff’s original Complaint, on the same grounds. Your Honor, after
reviewing our request and Plaintiff’s response, determined that the Co-Executors could bring
their motion “without the necessity of a pre-motion conference.” (Feb. 24, 2020 Order (ECF. No.
16, p. 1).) Your Honor further Ordered: “if, consistent with Rule 11, the plaintiff can assert
additional allegations to cure any alleged deficiencies raised by the defendants' letter, it would
be in the best interest of both the parties and the Court for the plaintiff to assert them now,
before briefing on the proposed motion … if no amended complaint has been filed, the parties
should confer on a briefing schedule.” (Id. (emphasis added).) Plaintiff’s amendments are
sparse, vague and fail to cure any of h
[…]