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to court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by Doe, who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that 7 Lewis stein n. 3059 Gum Amax, hart 340, CocomO Gam Flora 33133 7 0 316 EFTA00234230 Case 9:08-cv-80804-KAM Doc
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
his state-court state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by Doe. who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that 7 Lewis 'rein a 30596244444044,Sunt 340, COCOMO Goa.% home. 33233 70316 EFTA00231019 Case 9:08-cv-80804-KAM Docu
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
o cool t gut his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by 1)oc, who has since moved to another state."); Jane Doe Depo. at 77, 112 (indicating that 7 Lewitt Teinn. 3059 Gun Mt PM, lulu 340, cmowr GROW. (IOWA 33133 Tog 314 EFTA00232139 Case 9:08-cv-80804-KAM Do
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
Entities connected to both Jane Doe Depo and See Florence v. Crescent Resources
Jane Doe
PERSON
Jeffrey Marc Herman
PERSON
Bill Richardson
PERSON
Jeffrey Epstein
PERSON
Kenneth Marra
PERSONHerman
PERSONJack Goldberger
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSONPalm Beach Lakes Blvd
LOCATION
Scarlett Johansson
PERSONBruce E. Reinhart
PERSONFlorida Bar
ORGANIZATIONKEITH J. BRETT
PERSON
Les Wexner
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSON
Alfredo Rodriguez
PERSON
New York
LOCATION