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

9 (1883) (stating that "`[n]o court will lend its aid to a [plaintiff] who founds [a] cause of action upon an immoral or an illegal act'") (quoting Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that this policy is ("not for the sake of the defendant, but because [the court

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

149 (1883) (stating that 'Inlo court will lend its aid to a [plaintiff] who founds [a] cause of action upon an immoral or an illegal act') (quoting Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that this policy is "not for the sake of the defendant, but because [the courts

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

49 (1883) (stating that "`[n]o court will lend its aid to a [plaintiff] who founds [a] cause of action upon an immoral or an illegal ace") (quoting Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that this policy is "'not for the sake of the defendant, but because [the court