Epstein Secrets

: # 1 Exhibit Unopposed Motion for Enlargement of Time to File Civil Rico Case Statement Pursuant to Local Rule 12.1, and Proposed Order)(Mclntosh, Douglas) (Entered: 08/29/2008) 09/04/2008 12 r 46$.2 KB Defendant's MOTION to Dismiss 1 Notice of Removal Amended Complaint by Jeffrey Epstein. Response

the burden of establishing federal jurisdiction under § 1441 rests with the party seeking removal. Carson'. Dunham. 121 U.S. 421, 425 (1887); Diaz, Sheppard, 85 F.3d 1502, 1505 (11th Cir. 1996). The right of removal is strictly construed, as it is considered a federal infringement on a state's power to

te criminal prosecutions, the rule is stated in Douglas v. City of Jeannette, 819 U.S. 167, 163-164, 63

id not offer or advise Shep- pard of other railroad employment upon his release following the change in A&EC ownership. Soon after his dis- charge, Sheppard learned from an inde- pendent source of an open job as spike puller with an A&EC labor gang out of Morehead City. lie had worked out of New Bern w

ed, PAUL I. PEREZ United States Attorney By: s/Douglas Molloy DOUGLAS MOLLOY Assistant United States A

he therefore needed a favor from her. Scott wanted her to make some money by prostituting herself, and he gave Frey condoms and sent her out with Sheppard and Riebesehl. The three all engaged in sexual intercourse for money, and upon her return to the motel Frey gave Scott all of the money she made.