📧 Communication

This document is a legal letter dated January 24, 2020, from attorney Bennet J. Moskowitz (representing the Estate of Jeffrey Epstein) to Judge Naomi Reice Buchwald. The letter requests a pre-motion conference to move for the dismissal of a lawsuit filed by Maria Farmer. The defense argues that Farmer's claims of assault occurring in Ohio in 1995/1996 are time-barred under both New York and Ohio statutes of limitations and that her arguments for tolling (based on Epstein's later criminal indictment or equitable estoppel) are legally insufficient. It also argues that punitive damages cannot be awarded against an estate.