Epstein Secrets

ary Public, State of Florida Consor & Associates Reporting and Transcription Phone - 561.682.0905 Copy Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 2701316 EFTA00234250 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 28 of 100 ns

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

ver had a conversation. She only opened the 25 door and then left. She's the one who answered the door. Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 74 of 311 EFTA00180394 Case 9:08-cv-80804-KAM D ent 1 Entered on FLSD Docket 07/21/2008 Page 77 of 10

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

orted By: Judith F. Consor, FPR C PY Notary Public, State of Florida Consor ry Asociates Reporting and Transcription Phone - Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 270316 EFTA00231039 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 28 of 100 nso

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

ported By: Judith F. Consor, FPR copy Notary Public, State of Florida Consor & ASsociates Reporting and Transcription Phone - Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 atom EFTA00232159 Case 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 28 of 100 nsor

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