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      Case 1:19-cv-10476-PGG-DCF Document 26 Filed 03/20/20 Page 1 of 1



UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

TERESA HELM,

                              Plaintiff,
              v.                                          Case No. 1:19-cv-10476 (PGG) (DCF)
DARREN K. INDYKE AND RICHARD D. KAHN,
in their capacities as the executors of the ESTATE OF
JEFFREY EDWARD EPSTEIN,
                              Defendants.


                   NOTICE OF DEFENDANTS’ MOTION TO DISMISS

       PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law and all prior

pleadings and proceedings in this action, Defendants will move this Court before the Hon. Paul G.

Gardephe, United States District Judge, at the Thurgood Marshall United States Courthouse, 40

Foley Square, New York, New York 10007, at a time to be scheduled by this Court, for an Order,

pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure, dismissing Plaintiff’s Complaint

(ECF No. 1) with prejudice for failure to state a claim and Plaintiff’s claim for punitive damages;

and for such other and further relief as may be just and proper.



Dated: New York, New York
       February 24, 2020
                                                   By: /s/ Bennet J. Moskowitz
                                                      Bennet J. Moskowitz
                                                      TROUTMAN SANDERS LLP
                                                      875 Third Avenue
                                                      New York, New York 10022

                                                      Attorneys for Defendants


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