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diction. 2. There is complete diversity among the real parties to this controversy. Diversity jurisdiction requires complete diversity. Carden v. Arkoma Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the diversity statute to require `complete diversity' of citizenship."
EM EFTA00234224 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 2 of 100 Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as the instant Amended Complaint, and demanded damages of $5
diction. 2. There is complete diversity among the real parties to this controversy. Diversity jurisdiction requires complete diversity. Carden v. Arkoma Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the diversity statute to require `complete diversity' of citizenship."
16 EFTA00180407 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 2 of 100 Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as the instant Amended Complaint, and demanded damages of $5
diction. 2. There is complete diversity among the real parties to this controversy. Diversity jurisdiction requires complete diversity. Carden v. Arkoma Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the diversity statute to require `complete diversity' of citizenship."
11 EFTA00231013 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 2 of 100 Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as the instant Amended Complaint, and demanded damages of $5
diction. 2. There is complete diversity among the real parties to this controversy. Diversity jurisdiction requires complete diversity. Carden v. Arkoma Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the diversity statute to require 'complete diversity' of citizenship."
10 EFTA00232133 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 2 of 100 Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as the instant Amended Complaint, and demanded damages of $5
Entities connected to both Arkoma and The First Federal Action
Jack Goldberger
PERSON
Kenneth Marra
PERSONCarden
PERSONStrawbridge
PERSONGoldberger & Weiss
ORGANIZATIONJane Doe
PERSONMacGinnitie
ORGANIZATION
the United States District Court
ORGANIZATION
Jeffrey Epstein
PERSONthe Southern District
LOCATIONFleming v. Dane
PERSONLiappas
PERSONRX Solutions
ORGANIZATIONCounty Court
ORGANIZATIONRounick
ORGANIZATIONWoods v. Southwest Airlines, Co.
ORGANIZATIONCOCONUT GROVE
ORGANIZATIONMiami Herald Publ'g Co.
ORGANIZATIONCir. Ct
ORGANIZATION
Wyeth
ORGANIZATION