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Case 1:20-cv-02365-LJL-DCF Document 48 Filed 09/06/21 Page 1 of 11
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
JANE DOE,
Plaintiff,
v. Case No. 1:20-cv-02365-LJL-DCF
DARREN K INDYKE and RICHARD D. KAHN, in
their capacities as executors of THE ESTATE OF
JEFFERY E. EPSTEIN,
Defendants.
CO-EXECUTORS’ MEMORANDUM OF LAW
IN SUPPORT OF THEIR MOTION TO
DISMISS PLAINTIFF’S COMPLAINT
TROUTMAN PEPPER HAMILTON SANDERS LLP
875 Third Avenue
New York, New York 10022
Tel: 212-704-6000
Fax: 212-704-6288
Attorneys for Defendants Darren K. Indyke and Richard D. Kahn,
Co-Executors of the Estate of Jeffrey E. Epstein
119125600
Case 1:20-cv-02365-LJL-DCF Document 48 Filed 09/06/21 Page 2 of 11
Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey
E. Epstein (the “Co-Executors”), respectfully submit this Memorandum of Law in support of their
Motion to Dismiss Plaintiff Jane Doe’s (“Plaintiff”) Complaint (ECF No. 1) pursuant to Federal
Rule of Civil Procedure 12(b)(6).
PRELIMINARY STATEMENT
Plaintiff brings a single count against the Co-Executors for Jeffrey Epstein’s (“Epstein”)
alleged violations of Sections 1591, 1593A, 1594(a), and 1594(b) of the Trafficking Victims
Protection Act, 18 U.S.C. § 1591, et seq. (“TVPA”). (Compl. ¶¶ 33, 36.) The Court must dismiss
that claim for two separate reasons.
First, Plaintiff’s claim must be dismissed because she fails to plead its essential elements.
Plaintiff does not sufficiently allege Epstein’s knowledge or how Doe
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