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vt, kouo• 33133 5 of 316 EFTA00234229 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[w]hen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from
s pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds
rt, f tomm 33113 Sol 316 EFTA00180359 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[w 'hen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent fro
pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 MCRJWCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds
GEM% FM1:433133 I of 311 EFTA00180412 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "Ewlhen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from
s pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds
Gam, rims33133 9 a/ 31$ EFTA00231018 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[wjhen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from
s pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. cf Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WI_ 517847, at *1-2 (ND. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds
iovt. NOM* 33133 Go1316 EFTA00232138 Case 9:08-cv-80804-KANI Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[w]hen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from
s pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 Mat/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds
Entities connected to both the Eleventh Circuit Court of Appeals and Doe v. Francis

Jeffrey Epstein
PERSONJane Doe
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSONthe Eleventh Circuit
ORGANIZATIONJack Goldberger
PERSON
Michael Douglas
PERSONGoldberger & Weiss
ORGANIZATION
Jeffrey Marc Herman
PERSON
Scarlett Johansson
PERSONMICHAEL R. TEIN
PERSON
Anderson
PERSONLeon Black
PERSON
United States
LOCATION
the United States District Court
ORGANIZATIONMichael J. Pike
PERSON
the Police Department
ORGANIZATIONMiami Herald Publ'g Co.
ORGANIZATIONRobert D. Critton
PERSON
George W. Bush
PERSON