Epstein Secrets

eclines to exercise pendent jurisdiction over the state law claims and remands the action to state court. The Court finds In United Mine Workers v. Gibbs, 383 U.S. 715 (1966), a jury's verdict against a union based on State law claims was reversed, in part, because the federal law claim failed. The

ure of the deficiency that would keep the former claims out of federal court if presented on their own. Our general approach to the application of Gibbs, however, has been markedly more cautious. For example, as a matter of statutory construction of the pertinent jurisdictional provisions, we refuse

Dismiss must be denied; however, if the Court determines otherwise, Plaintiff respectfully requests leave to amend. Respectfully submitted, BY: s/ Isidro M. Garcia ISIDRO M. GARCIA Florida Bar No. AIR IA LAW FIRM P.A. West Palm Beach, FL 33401 Telephon Telecopie e-mail CERTIFICATE OF SERVICE ft bellsouth

law claims." Id. at *5-6 (emphasis added). In Daimler Chrysler Corporation. Charlotte Cuno, 547 U.S. 332, 351-52 (2006) the Supreme Court stated: Gibbs held that federal-question jurisdiction over a claim may authorize a federal court to exercise jurisdiction over state-law claims that may be viewed

ure of the deficiency that would keep the former claims out of federal court if presented on their own. Our general approach to the application of Gibbs, however, has been markedly more cautious. For example, as a matter of statutory construction of the pertinent jurisdictional provisions, we refuse

Dismiss must be denied; however, if the Court determines otherwise, Plaintiff respectfully requests leave to amend. Respectfully submitted, BY: s/ Isidro M. Garcia ISIDRO M. GARCIA GARCIA LAW FIRM, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 19 EFTA00222860 Case 9:09-cv-80469-KAM Documen

to federal law. Economy also weighs in favor of remand as state courts are better equipped to efficiently handle state 2 In United Mine Workers v. Gibbs 383 U.S. 715 (1966), a jury's verdict against a union based on State law claims was reversed, in part, because the federal law claim failed. The C

Point EFTA00175272 Case 9:09-cv-80469-KAM Document 31 Entered on FLSD Docket 06/01/2009 Page 11 of 11 Jane Doe II v. Epstein, et al. Page 11 Isidro M. Garcia, Esq. Garcia Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL 33401 F isidrogarcia(a:bellsouth.net Counsel for Plaintiff Jack A

ant Jeffrey Epstein Date Filed: 03/24/2009 Jury Demand: Plaintiff Nature of Suit: 360 P.I.: Other Jurisdiction: Federal Question represented by Isidro Manuel Garcia Garcia Elkins & Boehringer 224 Datura Avenue Suite 900 West Palm Beach , FL 33401 I - Email:11111 LEAD ATTORNEY TO BE NOTICED represented by Mi