📧 Communication

This document is a Reply Memorandum filed by the executors of Jeffrey Epstein's estate (Indyke and Kahn) moving to dismiss a complaint by plaintiff Teresa Helm. The defendants argue that Helm's claims are time-barred by the statute of limitations and that she has failed to prove 'extraordinary circumstances' or a relevant criminal indictment to toll this period. Additionally, the defense argues that punitive damages are not recoverable against an estate under either New York law (where the alleged torts occurred) or USVI law (where the estate is probated).