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

Southern District of Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case 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

Southern District of Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case 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

Southern District of Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case to