035.pdf
85.6 KB
Extraction Summary
6
People
2
Organizations
2
Locations
2
Events
3
Relationships
2
Quotes
Document Information
Type:
Legal correspondence / letter to judge
File Size:
85.6 KB
Summary
Legal correspondence from Plaintiff's attorney Daniel Mullkoff to Judge Debra Freeman regarding the case Davies v. Indyke et al. The letter argues that the Defendants improperly raised a new argument concerning the New Mexico statute of limitations for the first time in a reply brief and contends that the Plaintiff's claims regarding sexual abuse by Jeffrey Epstein in New Mexico are timely under the discovery rule.
People (6)
| Name | Role | Context |
|---|---|---|
| Daniel Mullkoff | Attorney |
Author of the letter representing Plaintiff Teala Davies; Attorney at Cuti Hecker Wang LLP.
|
| Teala Davies | Plaintiff |
Victim alleging sexual assaults by Jeffrey Epstein in New Mexico when she was 17.
|
| Jeffrey Epstein | Perpetrator |
Accused of inflicting sexual assaults on Teala Davies in New Mexico.
|
| Debra Freeman | Judge |
Honorable Judge of the U.S. District Court (SDNY) receiving the letter.
|
| Indyke | Defendant |
Named defendant in the case caption (Davies v. Indyke et al.). Likely executor of Epstein estate.
|
| Bennet J. Moskowitz | Attorney |
Counsel for Defendants, copied on the letter.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Cuti Hecker Wang LLP |
Law firm representing the Plaintiff.
|
|
| U.S. District Court for the Southern District of New York |
Court where the case is being heard.
|
Timeline (2 events)
2020-04-08
Letter filed by Plaintiff's counsel regarding Defendants' Motion to Dismiss.
New York, NY
Unknown (Historical)
Sexual assaults inflicted on Teala Davies when she was seventeen years old.
New Mexico
Locations (2)
| Location | Context |
|---|---|
|
Location of the law firm and the U.S. District Court.
|
|
|
Location where the alleged sexual assaults by Epstein occurred.
|
Relationships (3)
Letter states claims arise from 'sexual assaults inflicted on her by Jeffrey Epstein'.
Opening sentence: 'We represent Plaintiff Teala Davies.'
Listed as 'Counsel for Defendants'.
Key Quotes (2)
"Plaintiff’s claims arising from sexual assaults inflicted on her by Jeffrey Epstein in New Mexico when she was seventeen years old are time-barred under New Mexico law."Source
035.pdf
Quote #1
"Plaintiff has alleged that that she 'is still in the nascent stages of understanding the deep and lasting injuries that Epstein’s pattern of abuse has caused her,' and that she 'is still just beginning to process and understand the full extent of the injuries...'"Source
035.pdf
Quote #2
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