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eodore J. Leopold, Esq. Ricci-Leopold, P.A. oe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto
diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her twin sister lives with her mother in Georgia); Affidavit of Dawn LaVogue Sandberg, at ¶ 1(
: # 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
fter all), there is still complete diversity given that "[a] non-diverse defendant who is fraudulently joined does not defeat diversity." Shenkarl. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. Oct. 15, 2007) (Moreno, J.) (citing Riley'. Merrill Lynch, Pierce, Fenner & Smith, Inc., 292 F.
ax: 561 697 2383 Counsel for Plaintiff Jane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto
diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her twin sister lives with her mother in Georgia); Affidavit ofine, at ¶ I (stating, "I am the
, FL 33410 Fax: Counsel for Plaintiff Jane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto
diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her twin sister lives with her mother in Georgia); Affidavit of at ¶ I (stating, "I am the mot
s, FL 33410 Fax: Counsel for Plaintiffiane Doe Douglas M. McIntosh, Esq. Jason A. McGrath, Esq. McInto
diverse defendant who is fraudulently joined does not defeat diversity because his citizenship is excluded from the diversity calculus." Shenkar v. Money Warehouse, Inc., No. 07-20634-CIV, 2007 WL 3023531, at *1 (S.D. Fla. her. sister lives with her mother in Georgia); Affidavit of LaVogue at y I (stating, "I am th
Entities connected to both Michael Douglas and Money Warehouse, Inc.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Marc Rich
PERSON
Alan Dershowitz
PERSON
Scarlett Johansson
PERSON
George Mitchell
PERSON
Virginia Giuffre
PERSON
New York
LOCATION
Alfredo Rodriguez
PERSON
Samantha Power
PERSON
Barry Diller
PERSONDarren Indyke
PERSON
Bill Richardson
PERSON
Abraham Lincoln
PERSONJack Goldberger
PERSONJane Doe
PERSONthe Southern District
LOCATION
Kenneth Marra
PERSON
David Rodgers
PERSONHaley Robson
PERSON