📧 Communication

This document is a letter from attorney Bennet J. Moskowitz of Troutman Sanders LLP to Judge Gregory H. Woods, dated January 21, 2020. It outlines the grounds for an anticipated motion to dismiss claims brought by plaintiff Teala Davies against the Estate of Jeffrey Epstein. The defense argues that Davies' claims of sexual assault (alleged to have occurred between 2002 and 2004 in FL, NM, NY, USVI, and France) are time-barred by applicable statutes of limitations and that punitive damages cannot be recovered from a deceased tortfeasor's estate.