Epstein Secrets

copies of the summons and complaint resided at the residence, then service would have been valid under Florida or Federal law on May 7, 2008.2 See National Development Co. v. Triad Holding Corp., 930 F.2d 253 (2d Cir. 1991) (upholding service of process on housekeeper of defendant’s New York

r No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs Jane Doe 18205 Biscayne Blvd., Suite 2218

. In other words, it was the defendant’s burden to show that the cook did not reside in his home, and he failed to meet that burden.3 Id. See also National Development Co. v. Triad Holding Corp., 930 F.2d 253, 256-58 (2d Cir. 1991) (upholding service on the defendant’s housekeeper, where the defendant, like Defendant

period, Defendant Epstein was out of the country, in the State of Israel, and not amenable to service. (Herman Aff., ¶ 5). WHEREFORE, Plaintiff, JANE DOE NO. 2, respectfully requests that this Court enter an 4 This action was filed on February 6, 2008.

017. In other words, it was the defendant's burden to show that the cook did not reside in his home, and he failed to meet that burden? Id. See also National Development Co. I. Triad Holding Corp., 930 F.2d 253, 256-58 (2d Cir. 1991) (upholding service on the defendant's housekeeper, where the defendant, like Defendant

TO ENTER DEFAULT AGAINST DEFENDANT, OR ALTERNATIVELY, FOR AN ENLARGEMENT OF TIME TO SERVE PROCESS, AND INCORPORATED MEMORANDUM OF LAW Plaintiff, Jane Doe No. 2, by and through her undersigned counsel, and pursuant to Federal Rules of Civil Procedure 55(a) and 4(m), and S.D. Fla. L.R. 7.1, hereby files