📧 Communication

This document is a letter from Bennet J. Moskowitz of Troutman Sanders LLP to Judge Andrew L. Carter Jr., dated January 24, 2020. It serves as a pre-motion letter outlining the Estate of Jeffrey Epstein's intent to move for dismissal of a lawsuit filed by Juliette Bryant. The Estate argues that Bryant's claims regarding alleged sexual abuse between 2002 and 2004 are time-barred by the statutes of limitations in New York, USVI, Florida, and New Mexico, and that she cannot rely on the Child Victims Act or tolling because she was an adult (age 20-22) at the time of the alleged incidents. Additionally, the letter argues that punitive damages cannot be recovered from a decedent's estate under the relevant laws.