Epstein Secrets

L 33132 Telephone: 305-961-9320 Facsimile: 305-530-7139 Email: [email protected] EFTA00724493 Case 9:08-cv-80736-KAM Document 44 Entered on FLSD Docket 10/28/2010 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA/JOIINSON JANE DOES #1 AND #2, Petit

7 of 9 at the insistence of the U.S. Attorney's Office. There is no reason to dismiss the case precipitously now on the eve of a final resolution. The Eleventh Circuit has repeatedly noted that dismissal with prejudice is an "extreme sanction" and "is plainly improper unless and until the district court finds a cle

Case 9:08-cv-80736-KAM Document 140 Entered on FLSD Docket 01/24/2012 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petiti

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00601808 Case 9:08-cv-80736-KAM Documen

Avenue • Suite 2 • Fort Lauderdale, Florida 33301 954.524.2820 office 954.524.2822 fax EFTA00210762 Case 9:08-cv-80736-KAM Document 1 Entered on FLSD Docket 07/07/2008 EllackiLlt of DJ D.C. ELE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA 08-80736-Civ-MARRA/JOHNSON CASE NO.: IN RE: JANE

oner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense " 18 U.S.C. § 3553(a)(2)(A). The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States v.

federal procedure. Federal Rule of Civil Procedure 4(e)(1) permits service to be 2 EFTA00222189 Case 9:08-cv-80119-KAM Document 11 Entered on FLSD Docket 06/13.2008 Page 3 of 11 made according to "state law for serving a summons in . . . the state . . . where service is made" as an alternative to fo

tiff has exercised diligence and good faith in attempting to serve Defendant Epstein with process. Accordingly, entry of default is appropriate."). The Eleventh Circuit is clear, however, that "actual notice of a suit does not dispose of the requirements of service of process." Jackson'. Warden, FCC Coleman-USP, 25

Case 9:08-cv-80736-KAM Document 140 Entered on FLSD Docket 01/24/2012 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80736-CIV-MARRA JANE DOE #1 and JANE DOE #2, Petiti

on that the Court should order the United States to produce discovery while a motion to dismiss for lack of subject matter jurisdiction is pending. The Eleventh Circuit has clearly and repeatedly stated that dispositive motions should be decided before discovery begins: EFTA00660795 Case 9:08-cv-80736-KAM Documen

for monetary compensation. (Am. Compl. ¶ 13). brought Plaintiff to Epstein's mansion 2 EFTA00175528 Case 9:08-ov-80004-KAM Document Entered . FLSD Docket 10/03/2„8 Page 3 of 8 in Palm Beach. (Am. Compl. ¶ 13). Plaintiff was introduced to a, who led her up the stairs to the room with the massage tab

he doctrine of fraudulent joinder to allow the removal of a case to federal court despite the presence of a non-diverse or forum-citizen defendant. The Eleventh Circuit has provided substantial guidance for the district courts in situations where a party removes a case from state court, alleging fraudulent joinder o