Epstein Secrets

009 Page 13 of 37 Jane Doe No. 2 v. Epstein Page 2 Certificate of Service WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S. Mail and facsimile to the following addressees this 26th day of January 2009. Adam D. Horowitz, Esq. Jeffrey Marc Herman, Esq. Stuart S. Mermelstei

Citing to U.S. v. Lot 5. Fox Grove, supra, the Southern District Court, Florida, in Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), stated — The Eleventh Circuit has also created a test for these circumstances. stating that where there exists a concurrent civil and criminal proceeding, a court must stay a ci

n, Critton, Luttier & Coleman, LLP 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 Phone: Fax: Counsel for Jeffley Epstein Served via U.S. Mail, postage prepaid Guy Alan Lewis Es . Email: Lewis Tein 3059 Grand Avenue, Suite 340 Coconut Grove, FL 33133 Phone: Fax: Counsel for Jeffrey E

he doctrine of fraudulent joinder to allow the removal of a case to federal court despite the presence of a non-diverse or forum-citizen defendant. The Eleventh Circuit has provided substantial guidance for the district courts in situations where a party removes a case from state court, alleging fraudulent joinder o

rney for Respondent CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via fitcsimilc transmission and U.S. Mail, this? day of July, 2008, to: Brad Edwards, Esq., The Law Offices of Brad Edwards & Associates, LLC, (954) 924-1530, 2028 Harrison Street, Suite 20

tioner, she would have explained why this proposed disposition did not begin to reflect "the seriousness of the offense" 18 U.S.C. § 3553(aX2)(A). The Eleventh Circuit has instructed that the district courts must make substantial findings before sealing records in cases before it. For instance, in United States I O