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Case 9:10-cv-81111-WPD Document 15 Entered on FLSD Docket 11/11/2010 Page 1 of 16




                             UNITED STATES DISTRICT COURT
                             SOUTHERN DISTRICT OF FLORIDA



   M.J.,                       CASE NO. 9:10-CV-81111-WPD

           Plaintiff,

   Vs.

   JEFFREY EPSTEIN, and
   SARAH KELLEN,

        Defendants.
   _________________________________/


    PLAINTIFF M.J.’S RESPONSE TO ESPTEIN’S MOTION TO QUASH SERVICE OF
      PROCESS AND MOTION FOR A HEARING TO PROVE FRAUD, TO PROVE
   PROPER SERVICE, TO OBTAIN SANCTIONS FOR EPSTEIN’S SUBMISSION OF A
     FRAUDULENT AFFIDAVIT, TO OBTAIN A WARNING FORBIDDING FURTHER
    OBSTRUCTIONS IN THE CASES, AND TO SET AN ACCELERATED SCHEDULE
                              FOR DISCOVERY

           Plaintiff, M.J., hereby files this response to Epstein’s Motion to Quash Service of

   Process and for a hearing to demonstrate fraud, to prove the defendant Epstein was

   properly served, to obtain sanctions for his submission of fraudulent affidavits, to obtain

   a warning forbidding any further obstruction in the case, and to set an accelerated

   schedule for discovery including an Order that Epstein is in default for failing to timely

   answer the complaint.

           Plaintiff M.J. was repeatedly sexually abused by defendant Jeffrey Epstein when

   she was a minor. Epstein is a politically-connected billionaire. M.J. filed suit in this

   Court against Epstein, seeking substantial damages. After Epstein’s counsel refused to

   accept service of M.J.’s complaint, M.J.’s counsel sent a private investigator to Epstein’s

   New York mansion (Epstein’s usual place of abode) to serve Epstein.            On Friday,
Case 9:10-cv-81111-WPD Document 15 Entered on FLSD Docket 11/11/2010 Page 2 of 16



                                                   CASE NO: 08-CV-80119-MARRA/JOHNSON



   October 8, 2010, the investigator hand-delivered to one of Epstein’s employees, who

   iden

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