Epstein Secrets

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

FF'S AMENDED' MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a dismissal is premised on the following: 1) Plaintiff is not permitted to file a claim under Florida l

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

PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a dismissal is premised on the following: 1) Plaintiff is not permitted to file a claim under Florida l

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

PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT EPSTEIN'S MOTION TO DISMISS Plaintiff, JANE DOE II, through counsel, opposes Defendant's RICHARD EPSTEIN's Motion to Dismiss. Defendant's argument for a dismissal is premised on the following: 1) Plaintiff is not permitted to file a claim under Florida l