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

vt, kouo• 33133 5 of 316 EFTA00234229 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[w]hen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from

l Stuart said the depanty In the odorant sentences was arse/ The USW Saws Moneys Oda dee *dyed not lo charge any ol Eolith's possible co-compmica • Sarah Kellen, Actlans Rom Lesley Groff end Nada Misrartove The agreement was negotiated In pert by New York howywegm ezignInal deem. Quemoy Geoid Larogn on Its

ment that lets Epstein and co-conspirators Sarah Kellen, Adrian& Ross, Lesley Groff and Nadia Marcinkova

, that Epstein could've spent behind bars had he been prosecuted in the federal system. They're hoping that the correspondence, ordered released by the Eleventh Circuit Court of Appeals, will shed light on what they say is an unusually lenient deal. "I can say that I've been teaching criminal law for more than two decades and I hav

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

rt, f tomm 33113 Sol 316 EFTA00180359 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "[w 'hen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent fro

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

GEM% FM1:433133 I of 311 EFTA00180412 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 7 of 100 To cement this point, the Eleventh Circuit Court of Appeals has said that "Ewlhen [a] complaint does not claim a specific amount of damages, removal from state court is proper if it is facially apparent from