Requesting the Court disregard a new legal argument regarding New Mexico statute of limitations raised by Defendants for the first time in their reply brief.
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.
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