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

]o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such as occurred in this case."). CI Ewell v. Daggs, 108 U.S. 143, 149 (1883) (stating that "`[n]o court will lend its aid to a [plaintiff] who founds [a] cause of action upon an immoral or an illega

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

o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such as occurred in this case."). Cf. Ewell v. Daggs, 108 U.S. 143, 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

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

o public policy should allow appellant to recover damages as a result of engaging in criminal conduct such as occurred in this case."). Cf. Ewell v. Daggs, 108 U.S. 143, 149 (1883) (stating that "`[n]o court will lend its aid to a [plaintiff] who founds [a] cause of action upon an immoral or an illega