Epstein Secrets

ile folder with signed sealed Orders, and light green file folder with Exhibits to Motion to Unseal Grand Jury Materials notes, White binder with Jane Doe 1 and Jane Doe 2's Consolidated Statement of Undisputed Material Facts and Motion for Partial Summary Judgment with Incorporated Memorandum of Law Bo

with NPA 2/18/10 Letter to from Black regarding attorney's fees 3/20/11 Letter from Acosta Transcript of 6/12/09 Motion Hearing in Jane Doe case Notice of Removal (DE#1) in 08-CV-8084-KAM Jane Doe case Redwell with Epstein's Motion to Seal Non-Pros Agreement Epstein New York Case (Redwell) 12/10/10, 3/1/11,

plaintiffs are seeking damages in excess of $50 million - - well over the $75,000 amount-in-controversy requirement for diversity jurisdiction. See Jane Doe No. 2 at D.E. 1 ¶ 4; Jane Doe No. 3 at D.E. 1 ¶ 4; Jane Doe No. 4 at D.E. 1 ¶ 4; Jane Doe No. Sat D.E. 1 ¶ 4. 3. There is complete diversity. Div

ly where it was filed within 30 days after the last defendant was served). Second, in accordance with section 1446(d), defendants have served this Notice of Removal on July 21, 2008. Third, in accordance with section 1446(b), all of the defendants join this Petition and consent to removal. 4 District courts m

1 Entered on FLSD Docket 08)18:2008 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-80804-CIV-MARRA/JOHNSON JANE DOE, a/k/a, JANE DOE NO. I, Plaintiff, VS. JEFFREY EPSTEIN and Defendants. MOTION TO REMAND Plaintiff Jane Doe moves the Court to remand this act

tion that she is a citizen of Florida, Defendants question whether she might actually be a citizen of Georgia because her mother lives in Georgia. (Notice of Removal, DE I, pp. 7-8, n.6). Defendants fail to point out, however, that there is a question of whether Defendant Epstein is actually a citizen of Florida

age 2 of 4 judicial notice of a similar motion and its attachments filed at Docket Entry 12 in the separate case filed in this court by the name of JANE DOE, a/k/a. JANE DOE NO. 1 v. JEFFREY EPSTEIN et al. Case NO. 08-80804-CIV-MARRADOMISON 5. This evidence is relevant and critical to the prosecution of

ly where it was filed within 30 days after the last defendant was served). Second, in accordance with section 1446(d), defendants have served this Notice of Removal on July 21, 2008, Third, in accordance with section 1446(6), all of the defendants join this Petition and consent to removal. District courts may

led by Jeffrey Epstein. (Tein, Michael) (Entered: 09/05/2008) 09/15/2008 22 r 3" KB REPLY to Response to Motion re 11 MOTION to Remand filed by Jane Doe. (Kuvin, Spencer) (Entered: 09/15/2008) 09/16/2008 21 r 893 KB NOTICE of Substitution of Counsel by Theodore Jon Leopold on behalf ofJane Doe (

32: the amount in controversy exceeds $75,000; Defendant Epstein is a citizen of the U.S. Virgin Islands; and Defendant is a citizen of New York. (Notice of Removal ¶ 2.) As Plaintiff is a citizen of Florida, complete diversity exists and this Court's jurisdiction is alleged to be proper. As for Defendants cla

es and opinion and filed documents Redwell labeled Telephone Charts with a post it saying Duplicate White binder with additional documents filed in Jane Doe case White binder with CVRA Research White binder labeled Duplicate Box D: Empty file folder Jane Does I. U.S. Standing/Ripeness Research & 6(e

er) 6/12/09 Breach Ltr file folder) — post it says Epstein Defense 3 (Kelly) 7/29/11 Letter to from regarding NPA being a confidential document Notice of Removal (DEtf1) in 08-CV-8084-KAM Jane Doe case Redwell with Epstein's Motion to Seal Non-Pros Agreement Epstein New York Case (Redwell) 12/10/10, 3/1/11,

ed on FLSD Docket 07/15/2008 Page 1 of 8 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOHNSON IN RE: JANE DOE, Petitioner. FILED by I G D.C. JUL 0 9 2008 STEVEN M LANIMORE CURS U.S. DISE c s.o.or FLA • W.P.B. GOVERNMENT'S RESPONSE TO VICTIM'S EMERGENCY

e case to federal district court, where it was ultimately transferred to the Southern District of Florida. The League filed a Motion to Quash DER's Notice of Removal, which motion was argued before Judge William Hoeveler on July 10, 1991, and was granted on September 10, 1991. The federal court held that there

ction. Introduction This lawsuit arises from a pending federal criminal action concerning, among other things, an alleged assault of the plaintiff Jane Doe, who, according to her complaint, on "numerous occasions" provided "massages" to Epstein with "no credentials to provide massage therapy" and was "

e case to federal district court, where it was ultimately transferred to the Southern District of Florida. The League filed a Motion to Quash DER's Notice of Removal, which motion was argued before Judge William Hoeveler on July 10, 1991, and was granted on September 10, 1991. The federal court held that there