Plaintiff's Counsel
Memorandum submitted by Isidro M. Garcia on behalf of Plaintiff
Listed as Counsel for Plaintiff
Listed as 'Counsel for Plaintiff'
Isidro M. Garcia signs as counsel for Plaintiff
081.pdf
Legal filing from July 2, 2010, in the case of Jane Doe II vs. Jeffrey Epstein and Sarah Kellen. Plaintiff's counsel Isidro Garcia responds to a court order, apologizing for delays in filing a scheduling report, partly attributing the delay to difficulty serving Sarah Kellen who was 'believed to have been avoiding service.' The document announces that a settlement has been reached resolving all claims in this federal case and a companion state court case.
047.pdf
This document is a Plaintiff's Memorandum of Law filed on July 14, 2009, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen. The Plaintiff opposes Sarah Kellen's motion to set aside a default judgment, arguing that Kellen was properly served via 'nail and mail' in New York on April 23, 2009, after six attempts, and deliberately ignored the lawsuit. The filing asserts Kellen has provided no evidence she didn't receive service and has failed to present a meritorious defense as required by law.
016.pdf
This document is a legal motion filed on May 15, 2009, in the Southern District of Florida, case number 09-80469-CIV-MARRA. Plaintiff Jane Doe II requests an extension until May 22, 2009, to file a reply to Defendant Jeffrey Epstein's Motion to Dismiss, citing complex issues and other business. Epstein's counsel, Robert Critton, was consulted and did not oppose the extension.
061.pdf
This document is Jeffrey Epstein's Answer and Affirmative Defenses to a civil complaint filed by Jane Doe II in the Southern District of Florida in October 2009. Epstein pleads the Fifth Amendment against self-incrimination in response to most factual allegations. He asserts multiple affirmative defenses, claiming the plaintiff consented to the acts, that he believed she was 18 years or older, and that the claims are barred by the statute of limitations and various constitutional challenges to the retroactivity and application of 18 U.S.C. §2255.
007.pdf
This document is an unopposed motion filed on May 1, 2009, in the Southern District of Florida (Case 09-CIV-80469) by Jeffrey Epstein's attorneys requesting a five-day extension to file a response to Jane Doe II's complaint. The extension (until May 6, 2009) was requested because Epstein's counsel, Robert D. Critton, Jr., was preparing for an unrelated state court trial. The document confirms that Plaintiff's counsel, Isidro M. Garcia, agreed to this extension.
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