031.pdf
121 KB
Extraction Summary
6
People
4
Organizations
4
Locations
2
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal memorandum (defendants' reply memorandum of law in support of motion to dismiss)
File Size:
121 KB
Summary
This document is a Reply Memorandum filed by the executors of Jeffrey Epstein's estate (Indyke and Kahn) moving to dismiss a complaint by plaintiff Teresa Helm. The defendants argue that Helm's claims are time-barred by the statute of limitations and that she has failed to prove 'extraordinary circumstances' or a relevant criminal indictment to toll this period. Additionally, the defense argues that punitive damages are not recoverable against an estate under either New York law (where the alleged torts occurred) or USVI law (where the estate is probated).
People (6)
| Name | Role | Context |
|---|---|---|
| Teresa Helm | Plaintiff |
Suing the Epstein estate for alleged abuse; claims she was abused as an adult.
|
| Jeffrey Edward Epstein | Decedent / Alleged Abuser |
Deceased; his estate is being sued. Alleged to have told Helm 'Don't do anything I wouldn't do'.
|
| Darren K. Indyke | Defendant / Executor |
Executor of the Estate of Jeffrey Edward Epstein.
|
| Richard D. Kahn | Defendant / Executor |
Executor of the Estate of Jeffrey Edward Epstein.
|
| Bennet J. Moskowitz | Attorney |
Attorney for Defendants (Troutman Sanders LLP).
|
| Sheldon G. Adelson | Litigant |
Mentioned in cited case law (Nat’l Jewish Democratic Council v. Adelson).
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Troutman Sanders LLP |
Attorneys for the Defendants.
|
|
| Estate of Jeffrey Edward Epstein |
The estate being sued by Teresa Helm.
|
|
| United States District Court Southern District of New York |
The jurisdiction where the case is filed.
|
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| FBI |
Mentioned regarding a press release cited by the Plaintiff.
|
Timeline (2 events)
2002
Alleged interaction between Plaintiff and Epstein in New York where he made intimidating statements.
New York, NY
Teresa Helm
Jeffrey Epstein
2020-03-20
Filing of Defendants' Reply Memorandum of Law.
New York, NY
Locations (4)
| Location | Context |
|---|---|
|
Location of the court, the law firm, and the alleged torts committed against the Plaintiff.
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Location where Epstein's estate is being probated; Plaintiff argues USVI law should apply for punitive damages.
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Location where Plaintiff returned to after visiting New York.
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Mentioned in case law (Funk v. Belneftekhim) regarding extraordinary circumstances for tolling.
|
Relationships (3)
Helm is suing Epstein's estate for alleged abuse.
Indyke is an executor of Epstein's estate.
Kahn is an executor of Epstein's estate.
Key Quotes (5)
"Don’t do anything I wouldn’t do"Source
031.pdf
Quote #1
"[Decedent] was a very powerful person"Source
031.pdf
Quote #2
"[Decedent] made very clear to [Plaintiff] that he was incredibly wealthy, powerful, and regularly in contact with world leaders"Source
031.pdf
Quote #3
"Plaintiff asks the Court to depart from well-established law to resuscitate her claims that expired fifteen years ago."Source
031.pdf
Quote #4
"The Indictment has nothing to do with Plaintiff, even if it concerns her alleged abuser and describes a 'pattern' similar to what she described."Source
031.pdf
Quote #5
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