Epstein Secrets

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

ard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en bane), the Eleventh Circuit Court of Appeals adopted as binding precedent all decisions of the former Fifth Circuit rendered prior to October I, 1981. 9 Lewis Tein n. 3059 GRAND AVINUI. Suits 340, Cocoma Won, CIORIOA 33133 9o33,6 EFTA00234232 Case 9:08-cv-80

nterests in full disclosure of the plea agreement-the right of the public and the press to have access to court proceedings ( see Washington Post v. Robinson, 935 F.2d 282, 288 (D.C.Cir.1991)) and the victims' right of access to the terms of a plea agreement under the Crime Victim Rights Act, 18 U.S.C. §

rime, e m and that this holding extended to statements made by government counsel at a plea hearing); Anderson, 55 F.Supp.2d at 1167 (%In Smith, the Fifth Circuit extended the Briggs rule well beyond the grand jury context, and ordered other court filings and records naming an unindicted co-conspirator sealed

ity clearance for three years. However, on September 8, U.S. Magistrate Judge Deborah Robinson increased the fine to $50,000 at Berger's sentencing. Robinson stated, "The court finds the fine [recommended by government prosecutors] is inadequate because it doesn't reflect the seriousness of the offense."

a, 110 F.3d 260, 263 (5th Cir.1997)). ut see United Page 12 States I Laney. 189 F.3d 954 (9th Cir.1999) (pecuniary gain required). In fact, the Fifth Circuit in Canada found that the defendant's distribution of material involving the sexual exploitation of minors with a purpose of enticing another to ha

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

ard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en bane), the Eleventh Circuit Court of Appeals adopted as binding precedent all decisions of the former Fifth Circuit rendered prior to October 1, 1981. 9 Lewh:Fein n. 3059 CUPID AWNIJI, Syllt 340. Cocowl GROW, flow 33131 9 01316 EFTA00180361 Case 9:08-cv-8080

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

ard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en bane), the Eleventh Circuit Court of Appeals adopted as binding precedent all decisions of the former Fifth Circuit rendered prior to October 1, 1981. 9 LeNyiA,Tyin 3059 GPM° AVTOPX. Swig 340, COCOINI 69091, halm 33133 9 91310 EFTA00180415 Case 9:08-cv-80804