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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."
cument 1 Entered on FLSD Docket 07121:2008 Page 6 of 100 1. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-KAM (S.D. Fla. filed Jan. 24, 2008) (Compl. 1 6).
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."
cument 1 Entered on FLSD Docket 07/21/2008 Page 6 of 100 I. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-KAM (S.D. Fla. filed Jan. 24, 2008) (Compl. ¶ 6).
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."
cument 1 Entered on FLSD Docket 07/21/2008 Page 6 of 100 1. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-KAM (S.D. Fla. filed Jan. 24, 2008) (Compl. ¶ 6).
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."
cument 1 Entered on FLSD Docket 07/21/2008 Page 6 of 100 1. The amount in controversy in this action exceeds $75,000. This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-ICAM (S.D. Fla. filed Jan. 24, 2008) (Compl. ¶ 6)
Entities connected to both Arkoma and the First Federal Lawsuit
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