Case 1:19-cv-08673-KPF-DCF Document 75 Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Filed 06/19/20 Page 1 of 30 troutmarir sanders Bennet J. Moskowitz [email protected] June 19, 2020 Via ECF Hon. Katherine Polk Failla Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: Jane Doe, 1:19-cv-08673 (KPF) (DCF) Dear Judge Failla: We represent Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced action. We write to further supplement the Co-Executors' pending motion to dismiss (ECF Doc. 47) with the enclosed copy of the Opinion & Order entered June 10, 2020 by The Hon. Edgardo Ramos in another personal injury action against the Co-Executors (Lisa Doe v. Darren K. lndyke and Richard D. Kahn, as Joint Personal Representatives of the Estate of Jeffrey E. Epstein, et at, 19-cv-07773 (ER) (DCF)). In His Honor's Opinion & Order, Judge Ramos grants the CoExecutors' motion to dismiss in part, including by dismissing the plaintiff's punitive damages claim against them as a matter of law on grounds applicable to Plaintiff's claim for punitive damages in this action. Therefore, there are now three decisions by two S.D.N.Y. judges dismissing claims for punitive damages against the Co-Executors. (See ECF Nos. 61 and 64.) Respectfully submitted, s/Bennet J. Moskowitz Bennet J. Moskowitz cc: Counsel of Record (via ECF) 42540143v1 EFTA02751421