UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK¶
JANE DOE,¶
Plaintiff,¶
v.¶
DARREN g INDYKE and RICHARD D. KAHN in their capacities as the executors of the ESTATE OF JEFFREY EDWARD EPSTEIN and GHISLAINE MAXWELL, an individual,¶
Defendants.¶
Case No. 1:20-cv-00484-JOK-DCF¶
NOTICE OF CO-EXECUTORS' MOTION TO DISMISS¶
PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law and all prior pleadings and proceedings in this action, Defendants Darren,. Indyke and Richard D. Kahn, as Co-Executors of the estate of Jeffrey E. Epstein, will move this Court before the Hon. John G. Koeltl, United States District Judge, at the Daniel Moynihan United States Courthouse, 500 Pearl Street, New York, NY 10007, at a time to be scheduled by this Court, for an Order, pursuant to Federal Rule of Civil Procedure 12iIi(6), to dismiss with prejudice Counts I-IV in Plaintiff Jane Doe's ("Plaintiff") Complaint (ECF Doc. 9) to the extent they are time-barred, Count V in its entirety, and Plaintiff's demand for punitive damages against them.¶
Dated: New York, New York April 17, 2020¶
By: /s/ Bennet J. Moskowitz¶
Bennet J. Moskowitz TROUTMAN SANDERS LLP 875 Third Avenue New York, New York 10022¶
Attorneys for Co-Executors¶