EFTA00222895.pdf

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 JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defendants. ) CASE NO.: 09-80469-CIV-MARRA ) ) ) ) ) ) ) ) ) PLAINTIFF'S MOTION FOR DEFAULT AGAINST DEFENDANT Plaintiff, JANE DOE II, moves fora default against Defendant , and would show in support: 1. Defendant has been avoiding service as detailed in the Affidavit of Service of Joseph Sanchez, attached as Exhibit 1. 2. Mr. Sanchez effected service on Defendant in a manner authorized by New York State law, and Defendant has failed to timely answer the complaint or otherwise respond thereto. 3. Defendant is aware of this action and has in fact traveled to visit with Defendant EPSTEIN at the Palm Beach County Jail on several occassions. WHEREFORE, Plaintiff respectfully requests that this Court enter a default against Defendant EFTA00222895 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 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, this 12th day of June, 2009. BY:s/ Isidro M. Garcia ISIDRO M. GARCIA 2 EFTA00222896