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for this deposition. 18 BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. 20 A. Yes. 21 Q. Thank you. 22 In fact, you know that Mr. Herman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 A. After it happened. Ph. 561.682
Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case today. Even
which I'm doing, and I'll make the same objection. And if it calls for attorney/client privilege, any conversations you In fact, you know that Mr. Herman held a Ph. 561.682.0905 - Fax. 561.682.1771 1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 76 o1316 EFTA00180376 Case 9:08-
Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case today. Even
e 9:08-cv-80804-KAM ent 1 Entered on FLSD Docket 07/21/2008 Page 75 of 100 nsor & Associates \ Reporting and Transcriponn, Inc. Page 49 1 Mr. Herman in the presence of IMO" 2 A. None. 3 Q. What discussions did you have in the 4 presence of her aunt? 5 A. Of my aunt? 6 MR. GOLDBERGER:
Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case today. Even
1 Entered on FLSD Docket 07/21/2008 Page 40 of 100 nsor & Associates Roportenp and Tanscriptinn, 2 4 5 6 7 8 9 10 11 stepmother and Mr. Herman at the press conference 12 regarding your lawsuit? 13 A. Yes. 14 Q. Now you know that this is a very serious 15 matter, don't you? 16 MR.
f Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co.'. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case today. Even
for this deposition. 18 BY MR. TEIN: 19 Q. Go ahead. Please answer yes or no. 20 A. Yes. 21 Q. Thank you. 22 In fact, you know that Mr. Herman held a 23 press conference after he filed the fifty-million-dollar 24 lawsuit on your behalf, don't you? 25 After it happened. Ph. - Fax. 16
Florida. A state-court case is properly removable when "it could have been brought, originally, in a federal district court." Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005) (citing 28 U.S.C. § 1441(a)). This case was originally filed in federal district court, and it is the same case today. Even
Entities connected to both Herman and Roche

Jeffrey Epstein
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSON
United States
LOCATIONJane Doe
PERSON
Jeffrey Marc Herman
PERSONLeon Black
PERSON
George W. Bush
PERSON
Department of Justice
ORGANIZATION
A. Marie Villafana
PERSONthe Southern District
LOCATION
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Scarlett Johansson
PERSONRoy Black
PERSON
Virginia Giuffre
PERSONSouthern District
LOCATION
Bill Clinton
PERSON
Prince Andrew
PERSON
Joe Biden
PERSON