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

sages from other people (see, e.g., Am. Compl. TV 9, 11, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. F..I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained

0312010 Page 5 of 10 reveals that Plaintiff alleges with whom Defendant conspired, stating that he "conspired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these acts and to avoid police detection." See ¶ 15. Additionally, Plaintiff sufficiently alleges the identi

ired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these act

the similarities between Florida and federal RICO acts, Florida looks to federal authority regarding the interpretation and application of its act. Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 So.2d 565, 570 n.1 (3rd DCA 2004); see also RLS Business Ventures, Inc. v. Second Chance Wholesale

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

sages from other people (see, e.g., Am. Compl. ¶¶ 9, I I, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. CI, e.g., Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Ca, Inc., 881 So. 2d 565, 570 (Fla. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained no

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

ages from other people (see, e.g., Am. Compl. ti 9, I I, 12, 32), those activities are not alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. E.I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Ha. 3d DCA 2004) (holding that "'indirect injuries, that is injuries sustained no