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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
indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in
[email protected]>; RH_SQ8 <[email protected]>; Ricci, Maria L. (CD) (FBI) <[email protected]>; Rivera, Jessica (MM) (FBI) <[email protected]>; Robeson, Kristi A. (DL) (FBI) <[email protected]>; Rodriguez-Rosario, Kathia Jeanille (SJ) (FBI) <[email protected]>; Rosas, Nicole Kath
Y-SSA_CD <[email protected]>; OC_SQ14 <[email protected]>; Oliver, Amanda (CTD) (FBI) <[email protected]>; OM_Intel2 <[email protected]>; O'Malley, Margaret Noreen (OGC) (FBI) <[email protected]>; OM-Squad8 <[email protected]>; O'Reilly, Lisa C. (CG) (FBI) <[email protected]>; Ort
0, Kramer) also reported on the story. Continued Reporting: Director Patel Says He Will Pledge More Agents To Kansas, Topeka KSNT (NBC-27) (05/20, Robinson) reported that Director Patel plans to pledge additional agents to Kansas, specifically to field offices in areas with high violent crime rates. He
me and DePaul University, was just named Special Agent in Charge of the FBI's Indianapolis Field Office. Before being promoted to the new position, O'Malley was the Section Chief in the Lab Division at the FBI Headquarters, as Chief of the Forensic Response Section since October 2023. According to the ar
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
'indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO." (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in
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
indirect injuries, that is injuries sustained not as a direct result of predicate acts . . . will not allow recovery under Florida RICO."' (quoting O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) (emphasis added). Because the Amended Complaint does not satisfy the direct-in
Entities connected to both Haley Robson and O'Malley

Jeffrey Epstein
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Donald Trump
PERSONLeon Black
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Ghislaine Maxwell
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Prince Andrew
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George W. Bush
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United States
LOCATION
Alan Dershowitz
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Department of Justice
ORGANIZATION
Joe Biden
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Julie K. Brown
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Virginia Giuffre
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Scarlett Johansson
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Prince Charles
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Alfredo Rodriguez
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Michael Jackson
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Marc Rich
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Sarah Kellen
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Eric Trump
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