Epstein Secrets

TRICT OF FLORIDA NO. 09-80469-CIV-MARRA/JOHNSON JANE DOE II, Plaintiff, v. JEFFREY EPSTEIN and Defenda

oses H. Cone Memorial Hosp. v. Mercury Constr., 460 U.S. 1 (1983). As the Eleventh Circuit explained in American Bankers Ins., 891 F.2d at 884: In Colorado River [Water Conserv. Dist. v. United States, 424 U.S. 800 (1976)] the Supreme Court announced that a federal court may dismiss an action because of para

; Doe II - Clerk's Notice of Reassignment 04/13/2009 RDC Receipt and review Doe ll's offer of settlement 04/13/2009 MJP Review and analysis of Jane Doe's Response in Opposition to Motion to Slay 04/14/2009 RDC E-mails; review motions/responses re: Pacer on #2-7; Response to Stay 04/14/2009 RDC Co

nsel Stat. 2255 issues, constitutional issues 04/30/2009 RHB Legal research concurrent jurisdiction. comity, Jane Doe II, state/federal actions, Colorado River abstention 04/30/2009 RHB Draft Motion to Dismiss Jane Doe II (federal) 04/30/2009 RDC Receipt and review EW, LM, Doe -Federal - Edwards April

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defen

purely federal issues in this case because there is an independent action under State law is absurd. For this argument the Defendant relies on the Colorado River abstention doctrine, clearly inapplicable to this case. Only in "exceptional" circumstances, to promote conservation of judicial resources and comp

TES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE II Plaintiff, VS. JEFFREY EPSTEIN, and Defen

purely federal issues in this case because there is an independent action under State law is absurd. For this argument the Defendant relies on the Colorado River abstention doctrine, clearly 4 EFTA00222845 Case 9:09-cv-80469-KAM Document 20 Entered on FLSD Docket 05/22/2009 Page 5 of 20 inapplicable to

ould ultimately result in reversible error at any trial. II. Conclusion and Prayer for Relief 22. Epstein requests the following relief: a. That JANE DOE's Motion to Proceed Anonymously be denied; b. That this Court grant Epstein's Motion and that JANE DOE be identified by her legal name in the style

comprehensive disposition of litigation, would a federal court be authorized to dismiss federal parallel' claims that are initiated in state court. Colorado River Water Conservation District v. United States, 424 U.S. 800 (1976). However, for the Colorado River doctrine to even apply, there must be clear Cong