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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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