029.pdf
778 KB
Extraction Summary
4
People
2
Organizations
2
Locations
2
Events
4
Relationships
13
Quotes
Document Information
Type:
Legal pleading
File Size:
778 KB
Summary
This document is a legal memorandum filed by Teresa Helm, the Plaintiff, in opposition to the Defendants' (executors of Jeffrey Edward Epstein's estate) motion to dismiss her complaint. It argues against the dismissal of claims as untimely, asserts the applicability of equitable estoppel and tolling, and contends that punitive damages are recoverable under Virgin Islands law, guided by New York's choice-of-law principles.
People (4)
| Name | Role | Context |
|---|---|---|
| TERESA HELM | Plaintiff |
Plaintiff in the case 1:19-cv-10476-PGG
|
| DARREN K. INDYKE | Executor |
Executor of the Estate of Jeffrey Edward Epstein, Defendant
|
| RICHARD D. KAHN | Executor |
Executor of the Estate of Jeffrey Edward Epstein, Defendant
|
| JEFFREY EDWARD EPSTEIN | Deceased |
Subject of the estate being sued
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK |
Court where the case is filed
|
|
| Estate of Jeffrey Edward Epstein |
Defendant in the case
|
Locations (2)
| Location | Context |
|---|---|
|
Southern District of New York
|
|
|
Mentioned in relation to legal principles and case law
|
Relationships (4)
Plaintiff in the case against the estate of Jeffrey Edward Epstein, represented by executors
Plaintiff in the case against the estate of Jeffrey Edward Epstein, represented by executors
Executor of the Estate of Jeffrey Edward Epstein
Executor of the Estate of Jeffrey Edward Epstein
Key Quotes (13)
"PLAINTIFF’S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS PLAINTIFF’S COMPLAINT"Source
029.pdf
Quote #1
"Defendants Have Not Met Their Burden of Proving that Plaintiff’s Claims Are Untimely"Source
029.pdf
Quote #2
"Plaintiff’s Claims Are Timely Under N.Y. C.P.L.R. § 215(8)(a)"Source
029.pdf
Quote #3
"The Indictment Was Not Restricted to Minors."Source
029.pdf
Quote #4
"Plaintiff’s Claims Concern the Same Sex-Trafficking Operation that the Indictment Concerned."Source
029.pdf
Quote #5
"Defendants’ Attempts to Narrow the Scope of C.P.L.R. § 215(8)(a) Fail."Source
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Quote #6
"Defendants Have Not Met Their Burden of Proving that Plaintiff Cannot Invoke Equitable Estoppel."Source
029.pdf
Quote #7
"Defendants Have Not Met Their Burden of Proving that Plaintiff Cannot Invoke Equitable Tolling."Source
029.pdf
Quote #8
"The Court Should Deny the Defendants’ Motion to Dismiss Punitive Damages."Source
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Quote #9
"Defendants’ Motion to Dismiss Punitive Damages is Procedurally Improper."Source
029.pdf
Quote #10
"Plaintiff May Recover Punitive Damages in this Case."Source
029.pdf
Quote #11
"The Law of the Virgin Islands for Punitive Damages Governs Under New York’s Choice-of-Law Principles."Source
029.pdf
Quote #12
"Virgin Islands Law Would Allow for Punitive Damages against Defendants in this Case."Source
029.pdf
Quote #13
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