Epstein Secrets

Counsel for Plaintiff Jane Doe 6 EFTA00175540 Case 9:08-cv-8uo04-KAM Document Entered ..i FLSD Docket 09115L . J8 Page 7 of 8 SERVICE LIST Doe Epstein, et. al. CASE NO: 08-80804-Civ-MARIUUJOHNSON United States District Court, Southern District of Florida Robert Critton, Esq. Burman, Critton, Lut

natabase - flsd Page 1 of 6 U.S. District Court Southern District of Florida (West Palm Beach) CIVIL DOCKET FOR CASE #: 9:08-cv-80804-KAM Doe v. Epstein et al Assigned to: Judge Kenneth A. Marra Referred to: Magistrate Judge Linnea R. Johnson ' Case in other court: 15th Judicial Circuit, 50 2008 C

stion Plaintiff Jane Doe represented by Spencer Todd Kuvin Ricci Leopold 2925 PGA Boulevard Suite 200 Palm Beach Gardens , FL 33410 Defendant Jeffrey Epstein Fax: 515-2610 Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Theodore Jon Leopold Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Garden

SD Do t 3.8/1b,..,08 Page 4 of 21 Iktb4-1 PLEA IN THE CIRCUIT COURT THE FOLLOVVING IS TO REFLECT Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister _Dellloe a D 06CF009454A Felony Solicitation of Prostitution 1 No 3.FEI rocuring Person Under 18 for

nying as moot 2 Motion for Hearing. Signed by Judge Kenneth A. Marra on 8/5/08. (ir) (Entered: 08/06/2008) 08/08/20(8 a r ns KB MOTION Defendant Jeffiwy Epstein's Opposed Motion to Align Response Date by Jeffrey Epstein. (Attachments: # 1 Text of Proposed OrderXTein, Michael) (Entered: 08/08/2008) 08/13/2008

F.3d at 1314. conditions, and sensitive protocols concerning the fact of Epstein's previously disclosed incarceration. See DE 24 in Jane Doe No. 2 I. Epstein, Case No. 9:08-CV-80119-KAM (S.D. Fla. filed Feb. 6, 2Q08) (disclosing fact of Epstein's criminal sentence and incarceration); DE 19 in Jane Doe No

1332: the amount in controversy exceeds $75,000; Defendant Epstein is a citizen of the U.S. Virgin Islands; and Def

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,liste

Al .l TERMS OF THE NEGOTIATED SETTLEMEN*1 Name: Jeffrey E. Epstein Plea: Guilty 1 NP.---_.. SIMI .,lister

a/k/a, JANE DOE NO. 1, Plaintiff, vs. IF'.F .EY EPSTEIN , and Defendants. PLAINTIFF'S REPLY TO OPPOSIT

remand the matter back to state court if any of the properly joined parties in interest are citizens of the state in which the suit was filed. See Lincoln Prop. Co.'. Roche, 546 U.S. 81, 126 S.Ct. 606, 613, 163 L.Ed.2d 415 (2005) (citing 28 U.S.C. § 1441(b)). Such a remand is the necessary corollary of a federal

driguez advised he had very limited contact with Mr. Epstein. If Rodriguez needed to relay a message to Mr. E

d Six, to-wit The Grand Jurors of the State of Florida, inquiring in end for the body of said County of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. in the Circuit and State aforesaid. COUNT ONE FELONY SOLICITATION OF PROSTITUTION on or about or between th

esses and register himself as an agent. I also observed Epstein has his El Zorro Ranch Corporation, New York Strategy Group, Ghislaine Corporation, J Epstein and Company and the Financial Strategy Group registered to this same address. Finally, a third call is received by at 12:02 pm from the same corp

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid.

I wrote that, but I didn't write what you 13 said. 14 4. 15 16 you write that? 17 18 19 20 21 22 about what happened when you went to Jeff Epstein's house You wrote in this exhibit, "I got some stupid court s-h-i-t on the 20th. Bull s-h-i-t." Didn't A. Yes. Q. Referring to this deposition, d

his associates. ) (describing character of party defendant Epstein as a "sexual predator" (a term defined by Florida

y of Palm Beach, upon their oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid. i

Southern District of Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co.'. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case toda

SD Do ;,A8/18/2008 Page 4 of 21 ktIVA4 . PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _charge Cpynt Lessei _Dee' ep &b 06CF00945 Felony Solicitation of Prostitution 1 No 3 FUT rocuring Pers

told detectives, 'I'm like a Heidi Fleiss.'"). EFTA00234424 Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08)18:2008 Page 2 of 11 Epstein," (Notice of Removal, DE 1, p. 3) and that Plaintiff fraudulently joined her in this action to prevent complete diversity.2 3. As demonstrated in Pl

ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _char

ut, however, that there is a question of whether Defendant Epstein is actually a citizen of Florida because he is n

ALI. TERMS OF THE NEGOTIATED SI TTLFMEN I Name: Jeffrey E. Epstein Plea: Guilty A 6e4 /9—,—..... . _charg

remand the matter back to state court if any of the properly joined parties in interest are citizens of the state in which the suit was filed. See Lincoln Prop. Co.' Roche, 546 U.S. 81, 126 S.Ct. 606, 613, 163 L.Ed.2d 415 (2005) (citing 28 U.S.C. § 1441(b)). Such a remand is the necessary corollary of a federal