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t several of the young girls that were victimized and abused by Jeffrey Epstein. While we are aware of his recent guilty plea and conviction in his State Court case, the sentence imposed in that case is grossly inadequate for a sexual predator of this magnitude. The information and evidence that has come to
decision); see also Paul G. Cassell, Nathanael J. Mitchell & Bradley J. Edwards, Crime Victims' Rights Duri
, and #38 B-70 7/21/2008 Valhalla; cc: Senior Sloman Email response to Villafafia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Valhalla Kuyrkendall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Villafana, A. Acosta, J. Sloman, R. Senior
letter to Mr. Black 12/12/2008 Villafana; cc: Mitch Kitroser Spencer Kuvin Email response advising he
papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § I446(b) the undersigned are auth
lie to the police, don't you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 Michelle Pagan three years ago, didn't you? 24 A. To my knowledge, no, I did not. 25 Q. Well, you lied to the police when you Ph. 561.682.0905 - Fax. 5
), the District Court dismissed a purely state law claim for equitable subrogation because there had been an earlier claim for declaratory relief in State Court; the Eleventh Circuit reversed, concluding ...that no exceptional circumstances require dismissal of this case in deference to the pending state c
opportunity. Lingle v. Dion, 776 So.2d 1073 (Fla. 4th DCA 2001). The Florida Constitution establishes the right commonly known as access to courts. Mitchell v. Moore, 786 So.2d 521 (Fla. 7 EFTA00175248 6se 9:08-cv-80993-KAM Document 52 Entered on FLSD Docket 05/07/2009 Page 9 of 12 others, diminis
papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(6) the undersigned are auth
lie to the police, don't you? 20 A. No. 21 Q. Well, you lied to the police in your 22 tape-recorded statement that you gave to Detective 23 Michelle Pagan three years ago, didn't you? 24 A. To my knowledge, no, I did not. 25 Q. Well, you lied to the police when you Ph. 561.682.0905 - Fax. 5
30, #32, and #38 7/21/2008 Villafaiia; cc: Senior Sloman Email response to Vilkfaiia's 7/21/08 email regarding Motion for Return of Property in State Court 7/22/2008 Villafaiia K tz% rkcndall Email chain regarding victim addresses 7/22/2008 Emails between A. M. Vitiate's, A. Acosta, J. Sloman, R. S
ter to Mr. Black 12/12/2008 Villataria; cc: . Mitch Kitroser Spencer Kuvin Email response advising h
Entities connected to both State Court and George Mitchell

Jeffrey Epstein
PERSON
Lesley Groff
PERSONLeon Black
PERSON
Marc Rich
PERSON
Prince Andrew
PERSONDarren Indyke
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSON
Donald Trump
PERSON
United States
LOCATION
Alfredo Rodriguez
PERSON
Joe Biden
PERSON
Eric Trump
PERSON
Department of Justice
ORGANIZATION
Julie K. Brown
PERSON
Prince Charles
PERSON
Bill Clinton
PERSON
Martha Stewart
PERSON
New York
LOCATION