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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
Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doe may, in fact, be a citizen of Georgia. not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D
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
Doe is a citizen of Florida. (Am. Compl. ¶ 1.) 6 Jane Doc may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. I, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D
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
Doe is a citizen of Florida. (Am, Compl. ¶ 1.) 6 'Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by D
Entities connected to both Sarah Kellen and See New York Post

Jeffrey Epstein
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONBruce E. Reinhart
PERSONMichael J. Pike
PERSON
George W. Bush
PERSON
Palm Beach Gardens
LOCATIONSpencer Kuvin
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATIONRobert D. Critton
PERSON
Scarlett Johansson
PERSON
Alfredo Rodriguez
PERSON
Palm Beach County
LOCATIONTheodore J. Leopold
PERSONHaley Robson
PERSON
New York
LOCATION