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Case 1:19-cv-10788-GHW-DCF Document 36 Filed 04/10/20 Page 1 of 3
Troutman Sanders LLP
875 Third Avenue
New York, New York 10022
troutmariP
troutman.com
sanders
Bennet J. Moskowitz
D: 212-704-6000
bennet.moskowitz@troutman.com
April 10, 2020
ELECTRONIC COURT FILING
Hon. Debra Freeman
Daniel Patrick Moynihan
United States Courthouse
500 Pearl Street
New York, New York 10007-1312
Re: Teala Davies v. Darren K. Indyke and Richard D. Kahn, as Executors of the Estate
of Jeffrey E. Epstein, 1:19-cv-10788 (GHW) (DCF)
Dear Judge Freeman:
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 in response to Plaintiff Teala Davies’ (“Plaintiff”) April 8, 2020 letter (ECF No. 35) seeking
to strike an argument from the Co-Executors’ reply brief in support of their motion to dismiss
Plaintiff’s claims based on torts that allegedly occurred over fifteen years ago. Plaintiff’s
counsel filed their letter, without first conferring with us, incorrectly claiming that the Co-
Executors raised a new legal argument in their reply, and supplying new argument themselves,
in a rushed attempt at a do-over following their failure to avoid the correct version of the statute
of limitations applicable to Plaintiff’s claims based on conduct that allegedly occurred in New
Mexico in 2002. The Court should reject Plaintiff’s request for at least five reasons.
First, there is no “new” argument here. Plaintiff’s counsel argues that the Co-Executors’
reply brief “attempts for the first time to suggest that a different legal standard applies.” (ECF
No. 35 at 2.) That is wrong. The Co-Executors cont
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