Epstein Secrets

THERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants. NOTICE OF REMOVAL July 18, 2008 STEVEN M. LARIMORF CLERK D.S. DIST. CT. S.O. OF FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441

stroy diversity jurisdiction, and to prevent any application of 18 § 3509(k), a mandatory stay provision applicable in federal court 2 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section

er the circumstances alleged in the complaint." Florence v. Crescent Res., LLC, 484 F.3d 1293, 1299 (11th Cir. 2007) (citations omitted). See also, Holloway v. Morrow, No. 07-0839-WS-M, 2008 WL 401305, at *5 (S.D. Ala. Feb. 11, 2008) (emphasizing that "ItJhe potential for legal liability must be reasonab

1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (2) In or around 2001, Defendant SARAH ICELLEN led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001

in exchange for posing for nude photographs. (13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that auJant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane 1.J1 Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who w

o- tions for bail pending appeal. After panel denied motions for release pending appeal, rehearing en banc was granted, with the Court of Appeals, Holloway, Chief Judge, holding that: (1) Bail Reform Act section setting forth standards governing release of defendants on bail pending appeal applied to

y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section

er the circumstances alleged in the complaint." Florence v. Crescent Res., LLC, 484 F.3d 1293, 1299 (11th Cir. 2007) (citations omitted). See also, Holloway v. Morrow, No. 07-0839-WS-M, 2008 WL 401305, at *5 (S.D. Ala. Feb. I I, 2008) (emphasizing that "`[t]he potential for legal liability must be reason