💰 Financial Record

This document is a Memorandum of Law filed on November 29, 2019, by the defendants (Estate of Jeffrey Epstein and associated corporate entities) in the case VE v. Indyke et al. The defendants move to dismiss several counts of the plaintiff's complaint, arguing that the battery claim is time-barred and not revived by the Child Victims Act because it is distinct from claims under NY Penal Law § 130. Furthermore, they argue that negligence claims against the corporate defendants (Nine East, FTC, and NES) are based on vague, conclusory allegations that fail to establish a duty of care, breach, or proximate cause, and that punitive damages are legally barred against an estate.