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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
f 100 nsor & Associates Itcpanitnc had lranuripturri Inc 1 2 3 INDEX WITNESS: Page 3 PAGE: DIRECT EXAMINATION 4 4 BY MR. TEIN: 5 6 7 NOEXHIBITS MARKED 8 9 CERTIFIED QUESTIONS 10 Page Line 53 22 11 55 1 59 2 12 111 14 112 2 13 14 15 16 17 78 19 20 21 22 23 24
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
9 of 100 nsor & Associates Repnrnnp and Transcri pan Inc 1 2 WITNESS: INDEX Page 3 PAGE: 3 DIRECT EXAMINATION 4 4 BY MR. TEIN: 5 6 7 NOEXHIBITS MARKED 8 - - - 9 CERTIFIED QUESTIONS 10 Page Line 53 22 11 55 1 59 2 12 111 14 112 2 13 14 15 16 17 18 19 20 21 22 2
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
ge 29 of 100 sor & Associates Rep/irons and Traucripuna, 1 2 3 INDEX WITNESS: Page 3 PAGE: DIRECT EXAMINATION 4 4 BY MR. TEIN: 5 6 7 NOEXHIBITS MARKED - 23 24 25 Page - CERTIFIED QUESTIONS Line 53 22 55 1 59 2 111 14 112 2 Ph. - Fax. 1655 Palm Beach Lakes Blvd., Suite 50
Entities connected to both See Florence v. Crescent Resources and NOEXHIBITS

Jeffrey Epstein
PERSON
Scarlett Johansson
PERSONPalm Beach Lakes Blvd
LOCATION
Judith F. Consor
PERSONPalm Beach County Courthouse
LOCATION
Wellington
LOCATION
the United States District Court
ORGANIZATIONGoldberger & Weiss
ORGANIZATIONHerman
PERSON
Kenneth Marra
PERSONthe Southern District
LOCATION
the Police Department
ORGANIZATIONthe Eleventh Circuit
ORGANIZATIONMySpace
ORGANIZATIONJack Goldberger
PERSON
Marc Rich
PERSONDouglas M. McIntosh
PERSON
Virginia Giuffre
PERSONSawran
LOCATIONPierce, Fenner & Smith
ORGANIZATION