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DISTRICT COURT SOUTHERN 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 wit
lez, Case No. 50 2008 DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of Robson's citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circu
1 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of Robson's citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has
ed one. Epstein's attorneys actually made these baseless allegations in depositions and other court filings. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 EFTA00177092 Case 9:08-cv-80736-KAM Document 62 Entered on FLSD
gs. (See, e.g., Jane Doe' Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- M
tions to the victims — and having induced reliance by the victims — the Government is stopped from taking a different position now. As explained by the Eleventh Circuit, to make out a claim of estoppel against the Government, a party must adduce evidence of the following: (I) words, conduct, or acquiescence that in
ed one. Epstein's attorneys actually made these baseless allegations in depositions and other court filings. (See, e.g., Jane Doei Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- Marra/Johnson, DEl at 44-52.) 42 08-80736-CV-MARRA 000861 EFTA00230685 fmney,'" Case 9:08-cv-8
gs. (See, e.g., Jane Doei Jeffrey Epstein, Haley Robson, and Sarah Kellen, Court File No. 08-80804-Civ- M
Jersey. I am also admitted to the practice in the United States District Court for the Southern District of Florida, the U.S. Court of Appeals for the Eleventh Circuit, the U.S. Supreme Court, and several other federal courts. 3. I graduated from Princeton University in 1984 with a B.S.E. in civil engineering cu
LLP FR Tr. at 6 8, 22, 45; Tab 7, Tr. 13; Tab 8 Robson Tr. at 8; Tab 9, Tr. at 5; and O, MI Tr. at 14
individual woman. As the statute makes clear, the essence of this crime is the communication itself—not the resulting act. The Court of Appeals for the Eleventh Circuit, in Murrell, underscores the point: The defendant in Bailey contended that attempt under § 2422(b) `requires the specific intent to commit illegal
harges," Unattributed, July 30, 2020, 9:08 PM A grand jury indicted Sen. Katrina Robinson on theft, embezzlement and wire fraud charges. Wednesday, Robinson was federally charged with theft and embezzlement involving government programs and wire fraud. [Continue Reading] See also: WMC-NBC (Memphis TN) WR
ologists Say 11th Circ. Church Arbitration Biased," Unattributed, July 30, 2020, 5:06 PM Two former Scientologists suing the church for fraud asked the Eleventh Circuit on Thursday to vacate an arbitration award that they argue was the result of an unfair process that suppressed much of their evidence and did not l
iderable discretion in ruling on a motion to set aside an entry of default, and the Court's decision will only be reviewed for abuse of discretion. Robinson, US, 734 F.2d 735, 739 (11111 Cir. 1984); Baez 1. S.S. Kresge Co., 518 F.2d 349, 350 (5th Cir. 1975).' "[D]efaults are seen with disfavor because o
ess, prejudice, and a meritorious defense are the most often 'In Bonner" City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11111 Cir. 1981) (en banc), the Eleventh Circuit adopted as binding precedent the decisions of the Fifth Circuit rendered prior to October 1, 1981. 2 EFTA00221159 Case 9:08-cv-80380-KAM Docume
iderable discretion in ruling on a motion to set aside an entry of default, and the Court's decision will only be reviewed for abuse of discretion. Robinson. US, 734 F.2d 735, 739 (11111 Cir. 1984); Baez. S.S. Kresge Co., 518 F.2d 349, 350 (5th Cir. 1975).' "[D]efaults are seen with disfavor because of
ss, prejudice, and a meritorious defense are the most often 'In Bonner.. City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11111 Cir. 1981) (en banc), the Eleventh Circuit adopted as binding precedent the decisions of the Fifth Circuit rendered prior to October 1, 1981. 2 EFTA00222637 Case 9:08-cv-80381-KAM Docume
States v. St. Amour, 886 F.3d 1009, 1013 (11th Cir. 2018) (quoting United States v. Fisher, 289 F.3d 1329, 1337-38 (11th Cir. 2002)); see also ? Robinson g Shell Oil Co., 519 U.S. 337, 341, 117 S.Ct. 843, 136 L.Ed.2d 808 (1997) ("The plainness or ambiguity of WESTLAW @ 2021 Thomson Reuters. No claim
ssent misses the point: we are not only deciding Ms. Wild's case today. The majority's opinion will set precedent for how CVRA suits will proceed in the Eleventh Circuit. The mere fact that an Assistant United States Attorney in this case recognized certain individuals as victims says nothing about how prosecutors a
diction. (b) There is no ossibili that the plaintiff can establish a cause of action against under Florida law. (i) The conspiracy claim against Robson must fail. As a general rule, "[a]n actionable conspiracy [under Florida law] requires an actionable underlying tort or wrong." Wright v. Yurko, 44
JPL/slm Decisions of the United States Court of Appeals for the Filth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit. $.0 Bonner v. City of Prichard, Ala , 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 19439748.2 EFTA00180297 Rov BLACK HOWARD M. SREBNICK Scorer A
3031340, 600:00.rt 64064, 10:0100 33133 301316 EFTA00180409 Case 9:08-cv-80804-KAM Document 1 Entered on FLSD Docket 07/21/2008 Page 4 of 100 Robson, besides having nothing to do with the substantive allegations of the plaintiff's $50,000,000 case, is a community-college student with no assets w
1141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless ofillin citizenship. Although the Eleventh Circuit has recently indicated that a district court may not conduct jurisdictional discovery under such circumstances, another division of this Court has
Entities connected to both Haley Robson and the Eleventh Circuit

Jeffrey Epstein
PERSONJane Doe
PERSON
United States
LOCATION
Kenneth Marra
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON
Department of Justice
ORGANIZATION
Bradley Edwards
PERSON
George W. Bush
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Julie K. Brown
PERSON
Ghislaine Maxwell
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATIONFBI
ORGANIZATIONMaria Farmer
PERSON
Joe Biden
PERSON