Epstein Secrets

inhartlaw.com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax: 561-515-2610 Counsel for Plaintiff in Related Case No. 08-08804 [email protected] [email protected] Nos. 09-

ets to establish a fund with which to satisfy a potential judgment for money damages is not an appropriate exercise of a federal district court's 1 The Eleventh Circuit in Rosen "rejected appellees' suggestion that they successfully invoked the district court's equitable jurisdiction through their requests for any a

laration. Here is what Special Agent Kuyrkendall states: In October 2007, my co-case agent and I met with Jane Doe #1 at a Publix grocery store in Palm Beach Gardens. We were meeting with Jane Doe #1 to advise her of the main tenns of the Non-Prosecution Agreement. Among other information I provided, I told Jane

ng cases and concluding "the relevant case law unanimously agrees that the CVRA extends rights to crime victims before charges have been filed"). As the Eleventh Circuit has explained, "Congress is presumed to know the federal courts' interpretation of a statute that it intends to amend," and "[w]here there is no in

cument 1 Entered on FLSD Docket 07/21/2008 Page 25 of 100 Service List Theodore J. Leopold, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: 561 697 2383 Counsel for Plaintiffiane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P.

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

cument 1 Entered on FLSD Docket 07/21/2008 Page 25 of 100 Service List Theodore J. Leopold, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: 561 697 2383 Counsel for Plaintiff Jane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P

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

ited States Attorney's Office. Dated: August 5, 2009 By: Diana L. Martin Florida Bar No. 624489 L,EOPOLD-KUVIN, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Telephone: 561-515-1400 Facsimile: 561-515-1401 [email protected] 3 EFTA00193924 CERTIFICATE OF SERVICE hereby certify that a

L/slm I Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit, Sag Bonner v. City of Prichard, Ala., 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 19439748.2 EFTA00193952 EFTA00193953

he reports involving the arrests were reques Palm Beach County Sheriff's Office. The last number is assigned to Thomas Rofrano of 9850 Alt AlA in Palm Beach Gardens. Research on Mr. Rofrano, revealed that he is a Florida Chiropractic Physician. Vehicles that were previously documented on the property while su

mother"), In re (Palm Beach Co. Family Ct.) . If this turns out to be the case, there is complete diversity, regardless of 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

cument 1 Entered on FLSD Docket 07/21/2008 Page 25 of 100 Service List Theodore J. Leopold, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Fax: Counsel for Plaintiffiane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McIntosh, Sawran, Peltz & Cartaya, P.A. Centurion

DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there is complete diversity, regardless of 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