Epstein Secrets

original memorandum, that Defendant EPSTEIN may not contest this Court's jurisdiction based on the Non Prosecution Agreement ("NPA"). Although the State Court action is not a part of this Complaint, and is not alleged in the four (4) corners of it, it is a fact that cannot be contested since Plaintiff has

ft bellsouth.net I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, West Palm Beach, Florida 33401 this 12th day of June, 2009. BY:s/ Isidro M. Garcia ISIDRO M. GARCIA 19

), 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

FICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN CRITTON LUTTIER & COLEMAN, 515 N. Drive, Suite 400, West Palm Beach, Florida 33401 this 22nd day of May, 2009. BY:s/ Isidro M. Garci

n of not only the instant claim, but for other suits filed against Defendant EPSTEIN, including but not limited to the Florida RICO claims filed in State Court. 6. As stated in the certificate, the undersigned has conferred with counsel for EPSTEIN. They take the position that this motion would be moot bec

lectronically Notices of Electronic Filing. s/Richard H. Willits SERVICE LIST Michael Tein, Esq. -- Jack Goldberger, Esq. Bruce Reinhart, Esq. — Michael Pike, Esq. Robert Critton, Esq. EFTA00175480 D'ase 9:08-cv-8(,_ .1-KAM Docu....:nt 1 Entered oi. • LSD Docket 07i..'2008 FIFA/All Ogif0 D.C. UNITED