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

s pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds

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

pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 MCRJWCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds

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

s pled here. Thus, in resorting to fraudulent joinder, the plaintiff has sought to avoid any application of this otherwise controlling statute. Cf. Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D. Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on grounds