Document Mentions (3 shared documents)

EFTA00234224

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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

LEOPOLD: Objection. Asked and answered. THE WITNESS: No. 12 Q. After you left Epstein's house you took the 13 money and you went shopping with IIIIIIrand the other 14 girl in the car, correct? 15 A. Incorrect. I didn't spend any of the 16 money. 17 Q. You went to Marshall's, didn't you? 18

EFTA00180294_sub_001 - EFTA00180294_100

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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

and 9 answered. 10 THE WITNESS: No. 11 BY MR. TEIN: 12 Q. After you left Epstein's house you took the 13 money and you went shopping with IIIIIIrand the other 14 girl in the car, correct? 15 A. Incorrect. I didn't spend any of the 16 money. 1 Q. You went to Marshall's, didn't you? 18 A

EFTA00180294_sub_002 - EFTA00180294_200

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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