February 24, 2020
Proposed deadline for moving brief.
024.pdf
This document is a letter from Bennet J. Moskowitz, attorney for the Co-Executors of Jeffrey Epstein's Estate, to Judge Lorna G. Schofield, dated January 24, 2020. The letter requests a pre-motion conference to move for the dismissal of a lawsuit filed by Jane Doe 1000. The defense argues that the plaintiff's claims regarding alleged abuse in 1999 are time-barred by the statutes of limitations in New York and Florida, do not qualify for tolling under the Child Victims Act or criminal proceeding statutes, and that punitive damages cannot be legally awarded against a decedent's estate.
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