Epstein Secrets

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).

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

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).

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

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).

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

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)

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