Epstein Secrets

Sum 340, Oxciran Gotovi, ROMA 33133 14 et 316 EFTA00234237 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 15 of 100 Buchanan v. Miami Herald Publ'g Co., 230 So. 2d 9, 12 (Fla. 1969) (holding that where Count I of the complaint had failed to state a cause of action for mali

it is clear that the plaintiff seeks damages in connection with her own illegal conduct; this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a f

uitm, km. 140, (coma GOMMORIOA 33133 14 of 316 EFTA00180420 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 15 of 100 Buchanan v. Miami Herald Publ'g Co., 230 So. 2d 9, 12 (Fla. 1969) (holding that where Count I of the complaint had failed to state a cause of action for mali

it is clear that the plaintiff seeks damages in connection with her own illegal conduct; this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a f

rt 340.,Cccaivr Grow. FLORIDA 33133 14 of 31$ EFTA00231026 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 15 of 100 Buchanan v. Miami Herald Publ'g Co., 230 E. 2d 9, 12 (Fla. 1969) (holding that where Count I of the complaint had failed to state a cause of action for malic

it is clear that the plaintiff seeks damages in connection with her own illegal conduct; this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support a f

rt 340.,Cccaivr Grow. FLORIDA 33133 14 of 31$ EFTA00232146 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 15 01 100 Buchanan v. Miami Herald Publg Co., 230 So. 2d 9, 12 (Fla. 1969) (holding that where Count I of the complaint had failed to state a cause of action for malic

it is clear that the plaintiff seeks damages in connection with her own illegal conduct, this is enough to support a finding of fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 n.3 ( I I th Cir. 2007) (acknowledging that "under some circumstances, application of an affirmative defense can support