UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA¶
JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA¶
PLAINTIFF'S MOTION FOR DEFAULT AGAINST DEFENDANT¶
Plaintiff, JANE DOE II, moves for a default against Defendant, and¶
would show in support:¶
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- Defendant has been avoiding service as detailed in the Affidavit of Service of attached as Exhibit 1.
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- Mr. effected service on Defendant in a manner authorized by New York State law, and Defendant has failed to timely answer the complaint or otherwise respond thereto.
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- Defendant is aware of this action and has in fact traveled to visit with Defendant EPSTEIN at the Palm Beach County Jail on several occassions.
WHEREFORE, Plaintiff respectfully requests that this Court enter a default against¶
Defendant¶
Respectfully submitted,¶
BY: s/ Isidro M. ISIDRO M. Florida Bar No. 437883 LAW FIRM, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 Telephone:(561) 832-7732 Telecopier: (561) 832-7137 e-mail: isidrogarcia@bellsouth.net¶
CERTIFICATE OF SERVICE¶
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida 33401 this 12th day of June, 2009.¶
BY:s/ Isidro M. ISIDRO M.
¶