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hat? 16 A. I do now. 17 Q. You agree that court is a very serious 18 matter? 19 A. Yes. 20 Q. And you're here with your lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently filed a lawsuit in federal court against Jeffrey Epstein, Illillif you know t
diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her twin sister lives with her mother in Georgia); Affidavit of Dawn LaVogue Sandberg, at ¶ 1(
. (Kuvin, Spencer) (Entered: 09/15/2008) 09/16/2008 21 r 893 KB NOTICE of Substitution of Counsel by Theodore Jon Leopold on behalf ofJane Doe (Leopold, Theodore) (Entered: 09/16/2008) 09/18/2008 24 r 3itil, Unopposed MOTION for Extension of Time to File Response as to 19 Defendant's MOTION to D
fter all), there is still complete diversity given that "[a] non-diverse defendant who is fraudulently joined does not defeat diversity." Shenkarl. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. Oct. 15, 2007) (Moreno, J.) (citing Riley'. Merrill Lynch, Pierce, Fenner & Smith, Inc., 292 F.
hat? 16 A. I do now. 17 Q. You agree that court is a very serious 18 matter? 19 A. Yes. 20 Q. And you're here with your lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently 24 filed a lawsuit in federal court against Jeffrey Epstein, 25 seeking fif
diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her twin sister lives with her mother in Georgia); Affidavit of at ¶ I (stating, "I am the mot
hat? 16 A. I do now. 17 Q. You agree that court is a very serious 18 matter? 19 A. Yes. 20 Q. And you're here with your lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently 24 filed a lawsuit in federal court against Jeffrey Epstein, 25 seeking fif
diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her. sister lives with her mother in Georgia); Affidavit of LaVogue at y I (stating, "I am th
Entities connected to both Leopold and Money Warehouse, Inc.

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Palm Beach Gardens
LOCATIONTheodore J. Leopold
PERSON
Sarah Kellen
PERSON
Kenneth Marra
PERSONBruce E. Reinhart
PERSONMichael J. Pike
PERSON
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONHerman
PERSON
Jeffrey Marc Herman
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATION
Palm Beach County
LOCATION
Bill Richardson
PERSON
Alfredo Rodriguez
PERSON