037.pdf
40.4 KB
Extraction Summary
7
People
4
Organizations
4
Locations
2
Events
2
Relationships
2
Quotes
Document Information
Type:
Legal motion (motion for default)
File Size:
40.4 KB
Summary
This document is a Plaintiff's Motion for Default filed on June 12, 2009, in the Southern District of Florida against Sarah Kellen in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. The motion asserts that Kellen has been avoiding service but was successfully served according to New York law and failed to respond. Notably, it alleges that Kellen is aware of the legal action and has visited Jeffrey Epstein at the Palm Beach County Jail on several occasions.
People (7)
| Name | Role | Context |
|---|---|---|
| Jane Doe II | Plaintiff |
Moving for default against Sarah Kellen
|
| Jeffrey Epstein | Defendant |
Listed as defendant; visited by Sarah Kellen at Palm Beach County Jail
|
| Sarah Kellen | Defendant |
Subject of motion for default; accused of avoiding service; visited Epstein in jail
|
| Joseph Sanchez | Process Server |
Provided Affidavit of Service; effected service on Kellen
|
| Isidro M. Garcia | Attorney |
Attorney for Plaintiff filing the motion
|
| Robert D. Critton | Attorney |
Recipient of service via ECM
|
| Michael Pike | Attorney |
Recipient of service via ECM
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| United States District Court Southern District of Florida |
Court where case is filed
|
|
| Garcia Law Firm, P.A. |
Plaintiff's legal representation
|
|
| Burman Critton Luttier & Coleman |
Defense counsel firm receiving service
|
|
| Palm Beach County Jail |
Location where Epstein was held and visited by Kellen
|
Timeline (2 events)
Prior to 2009-06-12
Sarah Kellen visited Jeffrey Epstein at Palm Beach County Jail
Palm Beach County Jail
Prior to 2009-06-12
Service of process effected on Sarah Kellen by Joseph Sanchez
New York State (implied by jurisdiction)
Locations (4)
| Location | Context |
|---|---|
|
Location of visits between Kellen and Epstein
|
|
|
Address of Garcia Law Firm
|
|
|
Address of Burman Critton Luttier & Coleman
|
|
|
Jurisdiction whose laws authorized the manner of service
|
Relationships (2)
Kellen traveled to visit Epstein at Palm Beach County Jail on several occasions.
Plaintiff vs Defendant in lawsuit
Key Quotes (2)
"Defendant KELLEN has been avoiding service as detailed in the Affidavit of Service of Joseph Sanchez"Source
037.pdf
Quote #1
"Defendant KELLEN is aware of this action and has in fact traveled to visit with Defendant EPSTEIN at the Palm Beach County Jail on several occassions."Source
037.pdf
Quote #2
Full Extracted Text
Complete text extracted from the document (1,664 characters)
Case 9:09-cv-80469-KAM Document 37 Entered on FLSD Docket 06/12/2009 Page 1 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
SOUTHERN DISTRICT OF FLORIDA
JANE DOE II
Plaintiff,
Plaintiff,
vs.
JEFFREY EPSTEIN,
and SARAH KELLEN,
Defendants.
and SARAH KELLEN,
Defendants.
CASE NO.: 09-80469-CIV-MARRA
PLAINTIFF’S MOTION FOR DEFAULT AGAINST DEFENDANT SARAH KELLEN
Plaintiff, JANE DOE II, moves for a default against Defendant SARAH KELLEN, and
would show in support:
would show in support:
1. Defendant KELLEN has been avoiding service as detailed in the Affidavit of
Service of Joseph Sanchez, attached as Exhibit 1.
Service of Joseph Sanchez, attached as Exhibit 1.
2. Mr. Sanchez effected service on Defendant KELLEN in a manner authorized
by New York State law, and Defendant KELLEN has failed to timely answer
the complaint or otherwise respond thereto.
by New York State law, and Defendant KELLEN has failed to timely answer
the complaint or otherwise respond thereto.
3. Defendant KELLEN is aware of this action and has in fact traveled to visit with
Defendant EPSTEIN at the Palm Beach County Jail on several occassions.
Defendant EPSTEIN at the Palm Beach County Jail on several occassions.
WHEREFORE, Plaintiff respectfully requests that this Court enter a default against
Defendant KELLEN.
Defendant KELLEN.
Case 9:09-cv-80469-KAM Document 37 Entered on FLSD Docket 06/12/2009 Page 2 of 2
Respectfully submitted,
BY: s/ Isidro M. Garcia
ISIDRO M. GARCIA
Florida Bar No. 437883
GARCIA LAW FIRM, P.A.
224 Datura Street, Suite 900
West Palm Beach, FL 33401
Telephone:(561) 832-7732
Telecopier: (561) 832-7137
e-mail: isidrogarcia@bellsouth.net
ISIDRO M. GARCIA
Florida Bar No. 437883
GARCIA LAW FIRM, P.A.
224 Datura Street, Suite 900
West Palm Beach, FL 33401
Telephone:(561) 832-7732
Telecopier: (561) 832-7137
e-mail: isidrogarcia@bellsouth.net
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA
ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN
CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida
33401 this 12th day of June, 2009.
ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN
CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida
33401 this 12th day of June, 2009.
BY:s/ Isidro M. Garcia
ISIDRO M. GARCIA
2
ISIDRO M. GARCIA
2
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