024.pdf
76.6 KB
Extraction Summary
6
People
3
Organizations
3
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal correspondence (pre-motion letter)
File Size:
76.6 KB
Summary
This document is a letter from Bennet J. Moskowitz, attorney for the Co-Executors of Jeffrey Epstein's Estate, to Judge Lorna G. Schofield, dated January 24, 2020. The letter requests a pre-motion conference to move for the dismissal of a lawsuit filed by Jane Doe 1000. The defense argues that the plaintiff's claims regarding alleged abuse in 1999 are time-barred by the statutes of limitations in New York and Florida, do not qualify for tolling under the Child Victims Act or criminal proceeding statutes, and that punitive damages cannot be legally awarded against a decedent's estate.
People (6)
| Name | Role | Context |
|---|---|---|
| Bennet J. Moskowitz | Attorney |
Attorney for Defendants (Estate Co-Executors), Troutman Sanders LLP
|
| Lorna G. Schofield | Judge |
United States District Judge, recipient of the letter
|
| Jane Doe 1000 | Plaintiff |
New Jersey resident alleging sexual offenses by Epstein in 1999
|
| Darren K. Indyke | Defendant |
Co-Executor of the Estate of Jeffrey Edward Epstein
|
| Richard D. Kahn | Defendant |
Co-Executor of the Estate of Jeffrey Edward Epstein
|
| Jeffrey Edward Epstein | Decedent |
Deceased, alleged to have committed sexual offenses against Plaintiff
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Troutman Sanders LLP |
Law firm representing the Defendants
|
|
| United States District Court |
Southern District of New York (S.D.N.Y.)
|
|
| Estate of Jeffrey Edward Epstein |
Defendant entity represented by Co-Executors
|
Timeline (3 events)
1999
Alleged sexual offenses/torts committed by Jeffrey Epstein against Jane Doe 1000.
New York and Florida
2002-2005
Period covered by the criminal indictment against Epstein referenced in the document (sex trafficking of minors).
Unspecified in text, but related to indictment
Locations (3)
| Location | Context |
|---|---|
|
Location of court, law firm, and one of the locations of alleged abuse
|
|
|
One of the locations of alleged abuse
|
|
|
Plaintiff's state of residence
|
Relationships (3)
Plaintiff alleges Decedent committed sexual offenses against her in New York and Florida.
Co-Executor of the Estate of Jeffrey E. Epstein
Co-Executor of the Estate of Jeffrey E. Epstein
Key Quotes (4)
"Plaintiff is a New Jersey resident who alleges Decedent committed torts against her in or around 1999 in New York and Florida; Plaintiff’s causes of action expired nearly two decades ago."Source
024.pdf
Quote #1
"Plaintiff does not allege she was a minor when Decedent sexually abused her in or around 1999."Source
024.pdf
Quote #2
"Therefore, this action and the Indictment arise from entirely different occurrences."Source
024.pdf
Quote #3
"Plaintiff’s punitive damages claim must be dismissed as a matter of law because neither Florida law nor New York law permits punitive damages against a decedent tortfeasor’s estate."Source
024.pdf
Quote #4
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