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Case 9:10-cv-81111-WPD Document 14 Entered on FLSD Docket 11/10/2010 Page 1 of 7




                              UNITED STATES DISTRICT COURT
                              SOUTHERN DISTRICT OF FLORIDA

                                    Case No. 9:10-cv-81111-WPD


  M.J.,

                 Plaintiff,

  vs.

  JEFFREY EPSTEIN and
  SARAH KELLEN,

              Defendant.
  ___________________________________/


          RENEWED MOTION OF DEFENDANT JEFFREY EPSTEIN TO QUASH
          SERVICE OF PROCESS AND SUPPORTING MEMORANDUM OF LAW

          Defendant Jeffrey Epstein, by and through undersigned counsel, respectfully moves pursuant

  to Fed. R. Civ. P. 12(b)(5) to quash service of process, and without waiving any available

  jurisdictional defenses and without making a general appearance, states as follows.

                                   SUMMARY OF ARGUMENT

          Plaintiff, M.J., attempted to effect service on Mr. Epstein by leaving a copy of the Summons

  and Complaint in an unmarked, unaddressed and unpostmarked envelope in a mailbox at Mr.

  Epsteins’ vacation house at 9 East 71st Street, New York, New York, at an unknown time between

  October 8, 2010 and October 13, 2010, and by purportedly leaving a summons with “Mark” at Mr.

  Epstein’s alleged “residence or usual place of abode.” Such purported “service” does not comply

  with the requirements of service of process under New York, Florida or federal law. The attempt

  at service of process was ineffective. Service of process should be quashed.
Case 9:10-cv-81111-WPD Document 14 Entered on FLSD Docket 11/10/2010 Page 2 of 7



                                                                         Case No. 9:10-cv-81111-WPD


                                          BACKGROUND

         1.      The Complaint in this action was filed, and a summons was issued as to Jeffrey

  Epstein, on September 17, 2010.

         2.      The Proof of Service filed by Plaintiff (D.E. 11 at 3) reci

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