Epstein Secrets

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ____________________________________/ PLAINTIFF’S MOTION FOR ORDER COMPELLING CLERK TO ENTER DEFAULT AGAINST DEFENDANT, OR ALTE

f Time to Serve Process, and Incorporated Memorandum of Law, as follows: 1. This action was filed on February 6, 2008. On May 7, 2008, Defendant Jeffrey Epstein was served with the Summons and Complaint. A copy of the Affidavit of Service was filed with the Court. (D.E. 4). 2. Pursuant to Fed.R.C

o Serve Process, and Incorporated Memorandum of Law, as follows: 1. This action was filed on February 6, 2008. On May 7, 2008, Defendant Jeffrey Epstein was served with the Summons and Complaint. A copy of the Affidavit of Service was filed with the Court. (D.E. 4). 2. Pursuant to Fed.R.Civ.P. 1

an, where the above-described service was made. Mr. Epstein began receiving extensive press coverage approxi

attempted in related cases in this Court against Defendant Epstein, Jane Doe 3 v. Epstein, case no. CASE NO.: 08-

. 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

e the subject of discovery.1 The Affidavit Attached to the Defendant’s Response to the Motion is Insufficient Service of process was effected at Jeffrey Epstein’s New York residence on May 7, 2008, at 7:45 a.m. by handing a copy of the Summons and Complaint to a person in Defendant’s residence who refused to

nse as Exhibit “A” the Affidavit of Richard Barnett, who claims to have received the copies of the Summons and Complaint on May 7, 2008 at Defendant Epstein’s residence. In this Affidavit, Mr. Barnett states very little. He asserts that he does not now, nor has he ever, resided at 9 E. 71st Street, Ne

resided at 9 E. 71st Street, New York, New York (Mr. Epstein’s residence). He fails to state in this Affidavi

s of the Summons and Complaint on May 7, 2008 at Defendant Epstein’s residence. In this Affidavit, Mr. Barnett sta

Default, as follows: Introduction Defendant Jeffrey Epstein claims that service of process on him was

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

of Time to Serve Process, and Incorporated Memorandum of Law, as follows: 1. This action was filed on February 6, 2008. On May 7, 2008, Defendant Jeffrey Epstein was served with the Summons and Complaint. A copy of the Affidavit of Service was filed with the Court. (D.E. 4). 2. Pursuant to Fed.R.Civ.P. 12(a

e with multiple residences; his principal residence is a 45,000 square foot townhouse in Manhattan, where the above-described service was made. Mr. Epstein began receiving extensive press coverage approximately two years ago when allegations first surfaced that he sexually molested young girls. There a

tan, where the above-described service was made. Mr. Epstein began receiving extensive press coverage approxi

attempted in related cases in this Court against Defendant Epstein, Jane Doe 3'. Epstein, case no. CASE NO.: 08- CV-

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION FOR ORDE

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