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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 ) CASE NO.: 09-80469-CIV-MARRA
)
Plaintiff, )
)
vs. )
)
JEFFREY EPSTEIN, )
and SARAH KELLEN, )
)
Defendants. )
/

PLAINTIFF’S MOTION FOR DEFAULT AGAINST DEFENDANT SARAH KELLEN

Plaintiff, JANE DOE II, moves for a default against Defendant SARAH KELLEN, and

would show in support:

1. Defendant KELLEN 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 KELLEN in a manner authorized

by New York State law, and Defendant KELLEN has failed to timely answer

the complaint or otherwise respond thereto.

3. Defendant KELLEN 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 KELLEN.
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
Florida Bar No. 437883

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