Epstein Secrets

ainst disclosure are beside the point.") (citing Douglas Oil Co. of Calif. v. Petrol Stops Nw., 441 U.S. 2

Mini • or Oardird) a WI 11.9-Thod Poly 26 USC 1600 I FILED by D.C.; VI. ORIGIN it 1. Original 0 2. Removed from 0 3. Remanded from Proceeding State Court Appellate Court (Specify) 0 4. Refilled 0 6. Multidistrict Litigation 0 7. Appeal to District Judge from 0 5. Transferred from another distric

eodore J. Leopold, Esq. Ricci-Leopold, P.A. oe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto

papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § I446(b) the undersigned are auth

Entered on FLSD Docket 08/21/2008 Page 5 of 5 Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto

only the instant claim, but for six (6) other claims filed against Defendant EPSTEIN, including but not limited to the Florida RICO claims filed in State Court. WHEREFORE, Plaintiff respectfully request the Court grant her Motion to Preserve of all of the seized Evidence identified in Ex. A, to Exhibit 1 o

ssaoui, 483 F.3d 220, 235 (4th Cir. 2007) (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211,

rties to this litigation Box #2 P-008299 Thru P-008363 File folder entitled "FINAL AGREEMENTS" containing subfolder entitled "Agrints Filed in State Court" (P-008300-P-008327 [not being withheld as privileged — have been produced to opposing counsel]); signed Non-Prosecution Agreement, Addendum, and

ax: 561 697 2383 Counsel for Plaintiff Jane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto

papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(6) the undersigned are auth

, FL 33410 Fax: Counsel for Plaintiff Jane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto

papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are auth

s, FL 33410 Fax: Counsel for Plaintiffiane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto

papers have been filed. In accordance with 28 U.S.C. § 1446(d), defendants have served this Notice of Removal on July 18, 2008. All papers filed in State Court are attached to this Removal Petition. 3. There is unanimity among the defendants. In accordance with 28 U.S.C. § 1446(b) the undersigned are auth