Service of legal memorandum via electronic case management system.
This document is a Plaintiff's Memorandum of Law filed on July 14, 2009, in the case of Jane Doe II v. Jeffrey Epstein and Sarah Kellen. The Plaintiff opposes Sarah Kellen's motion to set aside a default judgment, arguing that Kellen was properly served via 'nail and mail' in New York on April 23, 2009, after six attempts, and deliberately ignored the lawsuit. The filing asserts Kellen has provided no evidence she didn't receive service and has failed to present a meritorious defense as required by law.
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