Case 1:20-cv-00484-JGK-DCF Troutman Sanders LLP 875 Third Avenue New York, New York 10022 troutman.com Document 29 Filed 03/27/20 Page 1 of 4 troutmar? sanders Bennet J. Moskowitz [email protected] March 27, 2020 VIA ECF Hon. J Koeltl Daniel Moynihan United States Courthouse 500 Pearl St. New York, NY 10007-1312 Re: Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as coexecutors of the Estate of Jeffrey E. Epstein, and Ghislaine Maxwell, Case No. 1:20-cv-00484 (JGK) (DCF) Dear Judge Koeltl: We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors") in the above-referenced action. We write pursuant to Your Honor's Individual Practices § 2(B) to request a pre-motion conference in anticipation of filing a motion, pursuant to Fed. R. Civ. P. 12(b)(6), to dismiss the time-barred claims and punitive damages claim in Plaintiff Jane Doe's ("Plaintiff") Complaint (Doc. 9). The bases for our anticipated motion are as follows. A. Plaintiff's claims based on alleged torts that occurred outside of New York and those that occurred when she was an adult, regardless of location, are time-barred. Many of Plaintiff's claims are time-barred. Plaintiff alleges that Jeffrey E. Epstein, now deceased, sexually abused her starting in 1994, when she was 14, and until sometime in 1999, when Plaintiff was an adult, in Florida, New York and New Mexico. (Compl. ¶¶ 17-19, 21, 22, 24.) Plaintiff alleges she was 16 in 1996 (id. at ¶ 20); so she turned 18 in 1998. Plaintiff asserts causes of action for sexual assault, sexual battery, intentional infliction of emotional distress and false imprisonment and seeks punitive damages. (Id. at ¶¶ 33-58, 60.) Plaintiff's claims based on alleged torts occurring outside New York expired long ago, including torts that occurred while she was a minor, as follows: (Florida) for torts occurring while she was a minor, the later of within 7 yea