📧 Communication

This document is a legal memorandum filed by the executors of Jeffrey Epstein's estate moving to dismiss a complaint by Teresa Helm. The defendants argue that Helm's claims of battery and emotional distress, stemming from an alleged 2002 sexual assault in New York when she was 22, are time-barred by the statute of limitations which expired in 2005. They further argue that statutory exceptions for criminal proceedings do not apply because Epstein's indictment involved trafficking minors, whereas Helm was an adult, and that punitive damages are legally barred against an estate.