048.pdf
271 KB
Extraction Summary
6
People
2
Organizations
2
Locations
7
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal pleading (reply to plaintiff's response)
File Size:
271 KB
Summary
This is a legal reply filed by Sarah Kellen's attorney in July 2009, requesting the court set aside a default judgment in the case brought by Jane Doe II. The document argues that service of process in New York was legally deficient because the 'nail and mail' method was used without proper due diligence (attempts were made when Kellen was known to be out of town) and that the default was entered prematurely before the response deadline. Kellen also asserts a meritorious defense, stating she did not conspire with Jeffrey Epstein to commit sexual battery and was unaware of what occurred privately between Epstein and the Plaintiff.
People (6)
| Name | Role | Context |
|---|---|---|
| Sarah Kellen | Defendant |
Seeking to set aside a default judgment; denies knowledge of Epstein's alleged sexual battery.
|
| Jeffrey Epstein | Defendant |
Co-defendant; alleged to have received massages arranged by Kellen.
|
| Jane Doe II | Plaintiff |
Suing Epstein and Kellen; alleged victim.
|
| Denise Kalland | Attorney |
Attorney for Sarah Kellen; signatory of the document.
|
| Bruce E. Reinhart | Attorney |
Name partner of the law firm representing Sarah Kellen.
|
| Process Server | Service Agent |
Unnamed individual who attempted to serve Kellen in New York.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Venue of the lawsuit.
|
|
| Bruce E. Reinhart, P.A. |
Legal counsel for Sarah Kellen.
|
Timeline (7 events)
2009-03
Plaintiff filed the case (Jane Doe II v. Epstein & Kellen).
Southern District of Florida
2009-06-17
Locations (2)
| Location | Context |
|---|---|
|
Location of Sarah Kellen's residence where service was attempted; jurisdiction for service of process laws cited.
|
|
|
Location of defense counsel's office.
|
Relationships (2)
Plaintiff alleges Kellen arranged massages for Epstein; Kellen denies conspiracy but document admits the allegation of arranging massages.
Kalland signs as attorney for Kellen.
Key Quotes (5)
"Ms. Kellen did not personally commit any sexual battery on the Plaintiff, nor did she conspire with Mr. Epstein to do so."Source
048.pdf
Quote #1
"The evidence will show that Ms. Kellen was not aware of whatever happened (or would happen) privately between Mr. Epstein and Plaintiff."Source
048.pdf
Quote #2
"Plaintiff does not allege any physical contact with Ms. Kellen... At best, she alleges that Ms. Kellen arranged for Plaintiff to massage Mr. Epstein."Source
048.pdf
Quote #3
"Plaintiff will not be able to prove Ms. Kellen’s knowledge or intent to commit any tortious conduct, nor her agreement to further such conduct."Source
048.pdf
Quote #4
"The process server states that on April 14, 2009, April 21, 2009 and April 24, 2009 he was informed by the doorman at Ms. Kellen’s apartment residence that Ms. Kellen was 'out of town.'"Source
048.pdf
Quote #5
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