042.pdf

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Extraction Summary

3
People
2
Organizations
3
Locations
4
Events
2
Relationships
5
Quotes

Document Information

Type: Legal motion (civil)
File Size: 49.3 KB
Summary

This document is a Motion to Set Aside Order of Default filed by attorney Bruce E. Reinhart on behalf of defendant Sarah Kellen in the case Jane Doe No. 2 v. Sarah Kellen. Kellen argues that the default judgment entered on June 17, 2009, is invalid because the plaintiff failed to properly serve the summons under New York law (specifically regarding timing of filing the affidavit of service) and because the time for a responsive pleading had not yet expired when the default was entered.

People (3)

Name Role Context
Sarah Kellen Defendant
Epstein associate; moving to set aside a default judgment due to improper service.
Jane Doe No. 2 Plaintiff
Anonymous plaintiff suing Sarah Kellen.
Bruce E. Reinhart Attorney
Counsel for Defendant Sarah Kellen; filed the motion.

Timeline (4 events)

2009-04-25
Summons delivered to a doorman at a building where plaintiff allegedly has an apartment.
New York (implied)
Doorman Process Server
2009-04-29
Summons mailed to the address where the doorman was served.
New York (implied)
2009-06-12
Affidavit of Service filed in Court (44 days after mailing).
Southern District of Florida
Plaintiff
2009-06-17
Order of Default entered by the court.
Southern District of Florida

Locations (3)

Location Context
Court jurisdiction
State where service was attempted; governing law for service validity
Address of attorney Bruce E. Reinhart

Relationships (2)

Sarah Kellen Attorney-Client Bruce E. Reinhart
Reinhart signs the motion as counsel for Kellen.
Jane Doe No. 2 Adversarial (Plaintiff-Defendant) Sarah Kellen
Case caption: Jane Doe No. 2 vs. Sarah Kellen

Key Quotes (5)

"Defendant Sarah Kellen... hereby moves to set aside the Order of Default entered on June 17, 2009"
Source
042.pdf
Quote #1
"Plaintiff did not execute proper service under New York law."
Source
042.pdf
Quote #2
"service upon the doorman was sufficient to satisfy the requirement that the summons be affixed to a dwelling place or usual place of abode."
Source
042.pdf
Quote #3
"By waiting 44 days to file the Affidavit of Service, plaintiff did not comply with the New York requirement that the proof of service 'shall be filed... within twenty days'"
Source
042.pdf
Quote #4
"The Order of Default entered on June 17, 2009, should be set aside because, as of that date no responsive pleading was due, so there was no default."
Source
042.pdf
Quote #5

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