034.pdf

This document is a Memorandum of Law in Support of Defendants' Motion to Dismiss Plaintiff's Complaint, filed by the executors of the Estate of Jeffrey E. Epstein. The defendants argue that the plaintiff's claims for battery and intentional infliction of emotional distress, stemming from alleged sexual assaults in 1999, are time-barred by the applicable statutes of limitations in New York and Florida. They further argue that recent New York legislation extending the statute of limitations does not apply retroactively to already expired claims, and that the plaintiff cannot claim equitable tolling or estoppel. Additionally, the defendants assert that punitive damages cannot be recovered from a decedent's estate under New York or Florida law.