Response to Defendants' request for a pre-motion conference regarding motion to dismiss, arguing claims are timely and equitable estoppel applies.
This document is a legal letter from Boies Schiller Flexner LLP on behalf of Plaintiff Maria Farmer in the case 'Farmer v. Indyke et al.' It argues against the Defendants' anticipated motion to dismiss, asserting that Farmer's claims are timely under NY CPLR ยง 215(8)(a) because they were filed within one year of the termination of the criminal action against Jeffrey Epstein (Aug 29, 2019). The letter also argues that equitable estoppel applies due to threats made against Farmer, including a specific death threat involving the West Side Highway.
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