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Case 9:08-cv-80119-KAM

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EFTA 00222583
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Case 9:08-cv-80119-KAM Document 7 Entered on FLSD Docket 05)29:2008 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 pursuant to the Federal Rule of Civil Procedure 55(a) and S.D. Fla. L.R. 7.1, hereby files this Motion for Entry of Default Against 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 response to the Complaint on or before May 27, 2008. 3. To date, Defendant has neither answered the Complaint, filed a response of any kind, nor requested an enlargeme

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Case 9:08-cv-80119-KAM Document 7 Entered on FLSD Docket 05)29:2008 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 pursuant to the Federal Rule of Civil Procedure 55(a) and S.D. Fla. L.R. 7.1, hereby files this Motion for Entry of Default Against 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 response to the Complaint on or before May 27, 2008. 3. To date, Defendant has neither answered the Complaint, filed a response of any kind, nor requested an enlargement of time. Moreover, no attorney has entered an appearance on behalf of the Defendant. 4. The Defendant, Jeffrey Epstein is not on active duty in the armed forces of the United States. See Exhibit "B". 5. Accordingly, pursuant to Federal Rule of Civil Procedure 55(a), Plaintiff applies to this Honorable Court for the entry of default judgment against the Defendant. HERMAN & MERMELSTEIN, P. A. www.hermanlaw.com - 1 - EFTA00222583 Case 9:08-cv-80119-KAM Document 7 Entered on FLSD Docket 05/29.2008 Page 2 of 3 WHEREFORE, Plaintiff, JANE DOE NO. 2, respectfully requests this Court to grant this motion in favor of Plaintiff and enter a default against Defendant, JEFFREY EPSTEIN. Dated: May 29, 2008. Respectfully submitted, By: 5/ Adam D. Horowitz Jeffrey M. Herman (FL Bar No. Stuart S. Mermelstein (FL Bar No Adam D. Horowitz (FL Bar No. HERMAN & MERMELSTEIN, P.A. Attorneys for Plaintiffs Jane Doe CERTIFICATE OF SERVICE I hereby certify that on May 29, 2008, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day to all parties on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ Adam D. Horowitz HERMAN & MERMELSTEIN. P. A. www.hermanlaw.com - 2 - EFTA00222584 Case 9:08-cv-80119-KAM Document 7 Entered on FLSD Docket 05)29.2008 Page 3 of 3 SERVICE LIST DOE vs. JEFFREY EPSTEIN CASE NO.: 08-CV-80119-MARRA/JOHNSON United States District Court, Southern District of Florida Jeffrey Epstein (Via Regular Mail) 9 East 71st Street New York, NY 10021 /s/ Adam D. Horowitz HERMAN & MERMELSTEIN. P. A. ww.v.hermanlaw.com EFTA00222585

Related Documents (6)

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Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10/31/2008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE NO. 2, CASE NO.: 08-CV-80119-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 3, CASE NO.: 08-CV-80232-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 4, CASE NO.: 08-CV-80380-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 5, CASE NO.: 08-CV-80381-MARR)VJOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. EFTA00222466 Case 9:08-cv-80119-KAM Document 49 Entered on FLSD Docket 10;31.2008 Page 2 of 11 JANE DOE NO. 6, CASE NO.: 08- 80994-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. JANE DOE NO. 7, CASE NO.: 08- 80993-CIV-MARRA/JOHNSON Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION TO MOTIONS TO DISMISS Plaintiffs, Jane Does 2-7, by and through undersigned counsel, file this Mem

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Case 9:08-cv-80069-KAM

Case 9:08-cv-80069-KAM Document 7-1 Entered on FLSD Docket 02/13/2008 Page 1 of 5 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80069-CIV-MARRA/JOHNSON y and through FATHER as arent and natural • ATHER, and STEPMOTHER, individually, Plaintiffs, vs. JEFFREY EPSTEIN, Defendant. PLAINTIFFS' MEMORANDUM OF LAW IN OPPOSITION STAY PROCEEDINGS PENDING ACHING AGE OF MAJORITY Plaintiffs by and throu g leather as parent and natural guardian, andMFather and Stepmother, individually, submit this Memorandum of Law in Opposition to Motion to Stay Proceedings Pending M N o. 1 Reaching Age of Majority, as follows: I. Introduction This action alleges the sexual assault of Plaintiff by the Defendant when she was 14 years old. The Motion to Stay Proceedings filed bother is without basis and should be stricken or denied for the following reasons: I. It fails to include or be accompanied by a memorandum of law, in violation of S.D.Fla.L.R. 7.1(A)

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CM/ECF - Live Database - flsd

CM/ECF - Live Database - flsd Page 1 of 17 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80380-KAM Doe No. 4'. Epstein Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson Lead case: 9:08-ev-80111-.KAM Member case• (View Member Case) Case: 9:09-0-80802-KAM Cause: 28:1332 Diversity Plaintiff Jane Doe No. 4 Date Filed: 04/14/2008 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Diversity represented by Adam D. Horowitz Mermelstein & Horowitz PA 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Jeffrey Marc Herman Herman & Mermelstein 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 Fax: 931-0877 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein Mermelstein & Horowitz PA 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 MOM Fax: 931-0877 Email: LRJ https://ecIfIsd.uscourts.g

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Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 41 Entered on FLSD Docket 09/22/2008 Page 1 of 4 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 MEMORANDUM IN RESPONSE TO DEFENDANT'S MOTION TO DISMISS Plaintiff, Jane Doe No. 2, ("Jane" or "Jane Doe"), by and through her undersigned counsel, files this Memorandum in Response to Defendant's Motion to Dismiss, and states as follows: 1. Defendant, Jeffrey Epstein is alleged to have sexually abused Jane Doe when she was a minor. The Complaint is in two Counts: Count I is labeled "Sexual Assault", and alleges an intentional tort based on the actions of Jeffrey Epstein; Count II alleges the tort of intentional infliction of emotional distress based on the same factual allegations. Defendant Epstein has moved to dismiss only Count I of the Complaint, contending that Plaintiff has failed to state a claim. Simultaneously her

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CM/ECF - Live Database - flsd

CM/ECF - Live Database - flsd Page 1 of 15 LRJ U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80232-KAM Doe No. 3 v. Epstein Assigned to: Judge Kenneth A. Marra Lead case: 2:flasaAhd Member case: (View Member Case) Case: 9:09-cv-80802-KAM Cause: 28:1332 Diversity-Personal Injury Plaintiff Jane Doe No. 3 Date Filed: 03/05/2008 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Diversity represented by Adam D. Horowitz Mermelstein & Horowitz PA 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Jeffrey Marc Herman I lennan & Mermelstein 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 Fax: 931-0877 Email: [email protected] LEAD ATTORNEY ATTORNEY TO BE NOTICED Stuart S. Mermelstein Mermelstein & Horowitz PA 18205 Biscayne Boulevard Suite 2218 Miami FL 33160 Fax: 931-0877 Email: LEAD ATTORNEY https://ect flsd.uscourts.gov/

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Case 9:08-cv-80119-KAM

Case 9:08-cv-80119-KAM Document 11 Entered on FLSD Docket 06)13.2008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80119-MARRA-JOHNS0N JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. RESPONSE TO MOTION FOR ORDER COMPELLING CLERK TO ENTER DEFAULT, OR ALTERNATIVELY, FOR ENLARGEMENT OF TIME Defendant Jeffrey Epstein, pursuant to Fed. R. Civ. P. 55(c), hereby opposes plaintiff Jane Doe No. 2's motion for order compelling clerk to enter default, or alternatively, for enlargement of time to serve process, upon the following showing of "good cause." Introduction A clerk's default should not be entered in this case. Service was effected as of June 2. Accordingly the response is due 20 days later, on or before June 23. See Fed. R. Civ. P. 12(a)(1)(A)(i). EFTA00222188 Case 9:08-cv-80119-KAM Document 11 Entered on FLSD Docket 06,'1312008 Page 2 of 11 The plaintiff, in moving for a clerk's default, implied that service

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