Epstein Secrets

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

lows: 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)(1), Defendant Jeffrey Epstein was required to answer or otherwise serve a r

ocument 47 Entered on FLSD Docket 07/14/2009 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA/JOHNSON ) ) ) ) ) ) ) ) ) PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT MOT

oing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, Counsel for Defendant EPSTEIN, 515 N. Drive, Suite 400, West Palm Beach, Florida 33401 and to Bruce Reinhart, Esq., BRUCE REINHART, P.A., Counsel for Defendant , 250 S. Austral

., BURMAN CRITTON LUTTIER & COLEMAN, Counsel for Defendant EPSTEIN, 515 N. Drive, Suite 400, West Palm Beach, Flori

ISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469

N.Y.S.C., Appellate Division, June 26, 2008). Defendant first argues that Plaintiffs Motion is defective because the Plaintiff did not timely file the Affidavit of Service. However, a delay in filing proof of service under CPLR 308 is merely a procedural irregularity, not jurisdictional, and may be corrected nunc pro

ey Epstein, this Court found valid service under New York law and entered an Order to Show Cause Why Default Should Not be Entered Against Defendant Jeffrey Epstein, dated July 16, 2008. 2. I submit this Declaration to correct what appears to be a factual error in the Court's Order to Show Cause. I do so even

OHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DECLARATION OF JEFFREY M. HERMAN RE

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DECLARATION OF JEFFREY M. H

cess server also mailed a copy of the summons and complaint to Defendant on May 5, 2008, via first class mail. (DE 4)." It is my understanding that the Affidavit of Service (DE 4) crosses out language regarding mail to the Defendant, and that the process server in this case did not mail a copy of the Summons and Compla

2008 Page 1 of 3 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 ENTRY OF DEFAULT AGAINST DEFENDANT Plaintiff, Jane Doe No. 2, by and through her undersigned counsel, and purs

OHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION FOR ENTRY OF DE

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

nst Defendant, and states as follows: 1. On May 7, 2008, Defendant Jeffrey Epstein was served with a Summons and Complaint in this case. A copy of the Affidavit of Service is attached hereto as Exhibit "A". 2. Pursuant to Federal Rule of Civil Procedure 12(a)(1), Defendant was required to answer or otherwise serve a

/2008 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80232-MARRA/JOHNSON JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION FOR ENTRY OF DEFAULT AGAINST DEFENDANT Plaintiff, Jane Doe No. 3, by and through her undersigned counsel, and purs

OHNSON JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION FOR ENTRY OF DE

-MARRA/JOHNSON JANE DOE NO. 3, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFF'S MOTION FOR ENTR

nst Defendant, and states as follows: 1. On May 7, 2008. Defendant Jeffrey Epstein was served with a Summons and Complaint in this case. A copy of the Affidavit of Service is attached hereto as Exhibit "A". 2. Pursuant to Federal Rule of Civil Procedure 12(a)(1), Defendant was required to answer or otherwise serve a