EFTA00180294

Case 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: It's the witness's aunt. 
7 
BY MR. TEIN: 
8 
Q. 
Oh, of your aunt. 
9 
A. 
The only one that we've ever discussed or 
10 
ever had. 
11 
Q. 
And so you were in a conversation with 
12 
Mr. Herman and your aunt? 
13 
A. 
Yes, sir. 
14 
Q. 
And you discussed privileged matters during 
15 
that conversation? 
16 
MR. LEOPOLD: Object to the form. I think 
17 
you might have to educate her on that question. 
18 
BY MR. TEIN: 
19 
Q. 
You discussed the lawsuit? 
20 
A. 
Yes. 
21 
Q. 
Did IMO 
tell you about any 
22 
conversations that she had with Mr. Herman? 
23 
A. 
As far as I'm concerned, she's never spoken 
24 
or she's never had a conversation. She only opened the 
25 
door and then left. She's the one who answered the door. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
74 of 311 
EFTA00180394

Case 9:08-cv-80804-KAM 
D 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 77 of 100 
nsor & Associates 
Ropartins and Transoription, Inc. 
Page 51 
1 
A. 
No. 
2 
Q. 
And we've learned that many of the girls, 
3 
some of whom are as old as 23, were told by the 
4 
government that they would get money at the end of the 
5 
criminal prosecution. Does that sound familiar to you?' 
6 
A. 
No, sir. 
7 
Q. 
Other than Mr. Leopold here -- I'm not 
8 
asking about Mr. Herman either --
9 
A. 
Uh-huh. 
10 
Q. 
-- did anyone ever discuss with you that 
11 
you could get reimbursement for your damages? 
12 
A. 
No, sir. 
13 
Q. 
Did you or any member 
14 
MR. LEOPOLD: Are you referring to a 
15 
criminal matter or a civil matter? 
16 
BY MR. TEIN: 
17 
Q. 
Did you or any member --
18 
MR. LEOPOLD: Excuse me. Let me object to 
19 
the form of the question. 
20 
BY MR. TEIN: 
21 
Q. 
Did you or any member of your family ever 
22 
get a victim notification letter from anyone? 
23 
A. 
I no longer live at that residence and I 
24 
wouldn't know. 
25 
Q. 
So your testimony is that you have never 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
in of on 
EFTA00180395

TO of 315 
Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 79 of 100 
nsor & Associates 
Roaming and TranscsiSiOll, Jac. 
Page 53 
1 
it back at the end of the meeting? 
2 
A. 
No. They -- yeah. No. They have it. I'm 
3 
guessing. I don't have it. 
4 
Q. 
How much money are you hoping to get out of 
5 
Mr. Epstein? 
6 
MR. LEOPOLD: Objection to the form of the 
7 
question. Attorney/client privilege. 
8 
BY MR. TEIN: 
9 
Q. 
How much money are you hoping to get, you, 
10 
yourself, hoping to get out of Epstein? 
11 
MR. LEOPOLD: Same. Same objection, 
12 
attorney/client privilege. 
13 
Don't answer the question. 
14 
BY MR. TEIN: 
15 
Q. 
I'm not asking about what your lawyer told 
16 
you. 
17 
MR. LEOPOLD: I'm instructing her not to 
18 
answer the question, because any of those 
19 
conversations involve her counsel. 
20 
MR. TEIN: Certify that. 
21 
MR. LEOPOLD: Please. 
22 
 
CERTIFIED QUESTION 
23 
BY MR. TEIN: 
24 
Q. 
Now, 
you lied to get out of this 
25 
deposition, didn't you? 
• 
.. 
•••••• •I•• 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180396

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 81 of 100 
nsor & Associates 
Roporrins and Transctipa no ). Inc. 
Page 55 
1 
 
CERTIFIED QUESTION 
2 
BY MR. TEIN: 
3 
Q. 
You asked your co-workers --
4 
MR. LEOPOLD: it's vague and ambiguous. 
5 
BY MR. TEIN: 
6 
Q. 
You asked your co-workers at the 
7 
Quarterdeck Tavern to lie for you, didn't you? 
8 
A. 
No. I informed my boss about what was 
9 
going on and he told me that he would help in any way 
10 
that he can. 
11 
Q. 
Okay. You got your friend 
to lie 
12 
by switching name tags with you, correct? 
13 
A. 
Incorrect. It was a coincidence that same 
14 
night she was not wearing her name tag; she was wearing 
15 
mine. But I was also not wearing -- I was wearing my 
16 
name tag. Everyone switches name tags. It just so 
17 
happens it was a coincidence that same night the people 
18 
came with the papers. 
19 
MR. TEIN: Will you put up Exhibit 18-001? 
20 
MR. GOLDBERGER: And mark 18-001 for 
21 
identification purposes to this deposition. 
22 
MR. LEOPOLD: None of them have been marked 
23 
yet. Can we mark them and put them as attachment 
24 
25 
to the depositions? Because I think you've shown
three photos now. And this is the only one that 
.
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Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
ill of 316 
EFTA00180397

Case 9:08-cv-80804-KAM 
Document 1 
II3 o 316 
Entered on FLSD Docket 07/21/2008 
Page 83 of 100 
nsor & Associates 
Ropromna owl Transcription, loc. 
Page 57 
1 
A. 
Yes. 
2 
Q. 
your friend, who you say the day 
3 
that the process servers went to serve you with a 
4 
subpoena for this deposition, just happened -- just by 
5 
coincidence, was wearing your name tag? 
6 
A. 
Yes, sir. 
7 
Q. 
And just by coincidence, you were wearing 
8 
her name tag, correct? 
9 
A. 
Yes. 
10 
Q. 
Your testimony under oath is that's just a 
11 
coincidence, right? 
12 
A. 
Total honesty. 
13 
Q. 
It just happens to be the day that you were 
14 
going to be served with a subpoena, correct? 
15 
A. 
That wasn't the first day that --
16 
MR. LEOPOLD: 
just answer the 
17 
question. It calls for a yes or no. 
18 
THE WITNESS: Yes. 
19 
BY MR. TEIN: 
20 
Q. 
You said that wasn't the first day you were 
21 
going to be -- you thought you were being served with a 
22 
subpoena, correct? 
23 
A. 
Correct. 
24 
Q. 
You knew before the day that you switched 
25 
name tags with 
that the process servers were 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180398

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 85 of 100 
nsor & Associates 
kopnrung and Transcription, lnc 
1 
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Page 59 
MR. LEOPOLD: I'll certify it. 
 
CERTIFIED QUESTION 
She's answered that question. She's explained it five 
tines already. The fact that Counsel doesn't like the 
answer, that's a different query. 
MR. TEIN: Stop making speaking objections. 
MR. LEOPOLD: I'm not. I'm not going to 
put up with it, because it's in appropriate, Jack, 
and you know it. I will not allow Counsel to 
berate a witness, whether it's in a criminal case 
or a civil case, whether my client or --
MR. TEIN: Calm down. 
MR. LEOPOLD: Excuse me. 
No, I'm not going to allow it. That is not 
proper. 
MR. GOLDBERGER: Okay. 
MR. LEOPOLD: If he wants to say that she's 
lying after asking it five times and her 
explaining in great detail, he can do that. But 
I'm not going to allow her to answer, nor be 
harassed by him. It's improper. 
MR. GOLDBERGER: Okay. But your response 
that Counsel doesn't like the question -- or 
doesn't like the answer -- just let me finish. 
MR. LEOPOLD: Absolutely. I wasn't going 
05 aril* 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180399

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 87 of 100 
nsor & Associates 
!ippon. ng 
Mtn 
Inc. • 
Page 61 
1 
MR. LEOPOLD: This is really big stuff that 
2 
you're going through. But that's fine; just ask 
3 
your question and move on. But do it one time. 
4 
If you don't understand it, 
let you follow 
5 
up, but I'm not going to allow you to ask the same 
6 
question time and again and then call her a liar. 
7 
Just ask the question, get the answer and move to 
8 
the next subject matter. 
9 
MR. TEIN: Ted, I'm sitting right across 
10 
the table from you. 
11 
MR. LEOPOLD: Yes, sir. 
12 
MR. TEIN: Please be quiet. Don't yell. 
13 
MR. LEOPOLD: I will not be quiet. 
14 
MR. TEIN: Stop yelling. 
15 
MR. LEOPOLD: Lewis, when I'm yelling 
16 
you'll know it. I will not 
17 
MR. TEIN: My name is not Lewis. 
18 
MR. LEOPOLD: I thought your first name was 
19 
Lewis, Mr. Tein. 
20 
MR. TEIN: You watched me for three days at 
21 
the evidentiary hearing where you sat in the back 
22 
of the courtroom. You should know who I am. 
23 
MR. LEOPOLD: Well, that's the impression 
24 
you must have made in the courtroom. 
25 
I will not be quiet. 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
EFTA00180400

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 89 of 100 
lOk
nsor & Associates 
Reporting and Transcriptina, 
Page 63 
1 
Q. 
Where were you when IIIIIIptold this 
2 
soreone that you were not at the Quarterdeck Tavern? 
3 
A. 
Eating nachos. 
4 
Q. 
At the Quarterdeck Tavern? 
5 
A. 
Yes. 
6 
Q. 
What did you do so that IIIIIIPwould lie to 
7 
the process servers for you? 
8 
A. 
Nothing. 
9 
Q. 
You just got him to lie for you, didn't 
10 
you? 
11 
A. 
No. I had no influence on him saying I 
12 
wasn't there. 
13 
Q. 
Be took that upon himself? 
14 
Isn't it true that Mr. Epstein's process 
15 
servers had to ask the police to get you out of the 
16 
restaurant so that they could serve you? 
17 
MR. LEOPOLD: Objection. Lack of 
18 
foundation, predicate. 
19 
BY MR. TEIN: 
20 
Q. 
You can answer the question. 
21 
MR. LEOPOLD: If you know. Don't guess. 
22 
THE WITNESS: No. Can you repeat the 
23 
question? 
24 
MR. TEIN: Don't coach. 
25 
MR. LEOPOLD: Don't guess. 
Ph. 561.682,0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
99 of 319 
EFTA00180401

Case 9:08-cv-80804-KAM 
Doc ment 1 
Entered on FLSD Docket 07/21/2008 
Page 91 of 100 
nsor & Associates 
Rationing and Transotiption, Inc. 
1 
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Page 65 
Q. 
When did you delete your MySpace page? 
A. 
A couple days ago. 
Q. 
Who told you to take your MySpace page down 
a couple of days ago? 
A. 
Nobody. I'm sick and tired of MySpace. 
Q. 
You all of a sudden got sick and tired of 
MySpace and just a few days before this deposition you 
decided to delete your MySpace page, correct? 
A. 
Correct. 
Q. 
Is that your testimony under oath? 
A. 
Yes. 
Q. 
Did you take your MySpace page down because 
you thought the government might subpoena it? 
A. 
Incorrect. 
Q. 
Hadn't your MySpace page been up for over 
three months before you took it down? 
A. 
Correct. But I also had made tons of 
MySpaces over the last years. I just get tired of them 
and delete them because -- drama -- and make new ones. 
Q. 
We're going to talk about that. 
So you deleted your MySpace page after you 
were already under subpoena for this deposition, correct? 
A. 
Correct. 
Q. 
What about the MySpace page didn't you want 
us to see,
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
II of 310 
EFTA00180402

Case 9:08-cv-80804-KAM 
DQcpfpent 1 
Entered on FLSD Docket 07/21/2008 
Page 93 of 100 
nsor & Associates 
Repartina and Transcription, Jac.
Page 67 
1 
Q. 
And where is the one body piercing? 
2 
A. 
Belly. 
3 
Q. 
When did you get that? 
4 
A. 
For my birthday, with my stepmother and my 
5 
father. 
6 
Q. 
And when was that? 
7 
A. 
When I was 14. 
8 
Q. 
Okay. So you had that body piercing when 
9 
you met Epstein, correct? 
10 
A. 
It might have been, or maybe that 
yeah, 
11 
either my 14th birthday or my 15th. I honestly don't 
12 
remember. 
13 
Q. 
Now you've lied about your age to get into 
14 
bars by using driver's licenses that aren't yours, 
15 
correct? 
16 
A. 
Incorrect. 
17 
Q. 
Are you swearing under oath that you've 
18 
never done that? 
19 
A. 
Yes, I swear under oath. 
20 
Q. 
And you've lied about your age to buy beer, 
21 
correct? 
22 
A. 
Incorrect. 
L3 
Q. 
You're swearing under oath that you've 
24 
never lied to stores about your age? 
25 
A. 
I've never lied to a store about my age or 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Pan Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
amore 
EFTA00180403

Case 9:08-cv-80804-KAM 
0 
D 
ument 1 
Entered on FLSD Docket 07/21/2008 
Page 95 of 100 
nsor & Associates 
Kcponinp mid Trance ri plum, Inc. 
Page 69 
1 
Q. 
Now you can explain your answer. 
2 
A. 
I know that I have seen all of these and I 
3 
know that this one is mine. 
4 
Can you go down? 
5 
MR. LEOPOLD: Just for the record, you're 
6 
pointing to the photo. 
7 
THE WITNESS: I'm pointing to --
8 
BY MR. TEIN: 
9 
Q. 
You're pointing to the one where it says 
10 
your age is 18? 
13. 
A. 
Correct. 
12 
Q. 
That's yours, right? 
13 
A. 
Correct. That's mine from a couple years 
14 
ago that I have not been on, because I don't use that. 
15 
Please keep going down, please. And I think that's it, 
16 
because there's no one -- just that one is mine. 
17 
Q. 
So the one you pointed to where it says 
18 
your age is 18, that's yours, correct? 
19 
A. 
Correct. 
20 
Q. 
And when you wrote 18 as your age on your 
21 
MySpace page, that was a lie, wasn't it? 
22 
A. 
Correct. 
23 
Q. 
Did you lie about your MySpace page back 
24 
then because you couldn't post on MySpace unless you were 
25 
18? 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
95 al 316 
EFTA00180404

Case 9:08-cv-80804-KAM 
nt 1 
Entered on FLSD Docket 07/21/2008 
Page 97 of 100 
%nsor 
& Associates 
Roparmist and Transcription, 
Page 71 
1 
THE WITNESS: I don't know which MySpace 
2 
you're talking about. 
3 
BY MR. TEIN: 
Q. 
The MySpace page that you're just pointing 
5 
to, where it says you were 18. 
6 
A. 
Yes. 
7 
Q. 
And you were lying about your age, right? 
8 
A. 
Uh-huh. 
9 
Q. 
Why did you finally post your true age on 
10 
your MySpace profile --
11 
A. 
Uh --
12 
0. 
-- four days before you were scheduled to 
13 
testify before the Grand Jury? 
14 
A. 
I honestly don't know which MySpace, 
15 
because I've had like a bazillion MySpaces, and in that 
16 
year, I had two, that one and another one, and that one's 
17 
been deleted. So I don't know which one you're referring 
18 
to. 
19 
Q. 
You remember that you changed your age on 
20 
your MySpace page from 18 to your true age just four days 
21 
before you went and testified in the Grand Jury? 
22 
A. 
No. 
23 
Q. 
You don't remember that. 
24 
A. 
No. 
25 
Q. 
Do you remember Detective Recarey? Did you 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
97 94 310 
EFTA00180405

Case 9:08-cv-80804-KAM 
Dgcrpent 1 
Entered on FLSD Docket 07/21/2008 
Page 99 of 100 
risor & Associates 
Ropaneng and Transctiplinn, Inc. 
Page 73 
1 
THE WITNESS: No. I'm pretty sure my dad 
2 
drove me, because he was there with me. 
3 
BY MR. TEIN: 
4 
Q. 
Did any detective tell you to change your 
5 
age on your MySpace page, to put your true age? 
6 
A. 
No, sir. 
7 
Q. 
Now you also lied on your MySpace page 
8 
about your income, didn't you? 
9 
A. 
Yes. 
10 
Q. 
And you lied, saying that you made a 
11 
quarter million dollars a year and higher, correct? 
12 
A. 
As a joke, yes. 
13 
Q. 
That was a lie, wasn't it? 
14 
A. 
Yes. 
15 
Q. 
And you also lied on your MySpace page, 
16 
saying that you were married, didn't you? 
17 
A. 
Possibly. And that might have been an 
18 
error on my part. 
19 
Q. 
Now you also lie to the police, don't you? 
20 
A. 
No. 
21 
Q. 
Well, you lied to the police in your 
22 
tape-recorded statement that you gave to Detective 
23 
Michelle Pagan three years ago, didn't you? 
24 
A. 
To my knowledge, no, I did not. 
25 
Q. 
Well, you lied to the police when you 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
99 91310 
EFTA00180406

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 FIP6040y1 0O1$00  D.C. 
ELECT 
tic 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
08-80804-Civ-MARRA/JOHNSON 
CASE NO.: 
JANE DOE, 
a/k/a JANE DOE N1, 
Plaintiff, 
Vs. 
JEFFREY EPSTEIN 
and 
Defendants. 
NOTICE OF REMOVAL 
July 18, 2008 
STEVEN M. LARIMORE 
CLERK U.S. GIST. CT. 
S.D. OF FLA. • MIAMI 
In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, 
Jeffrey Epstein, 
, and 
hereby remove this action) from 
Palm Beach County Circuit Court to the United States District Court for the 
Southern District of Florida, and respectfully state as follows: 
Introduction 
Six months ago, this plaintiff filed virtually the identical lawsuit in this 
Court. See Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed 
Doe v. Epstein et at, Case No. 50 2008 CA 006596 XXXX MB (Fla. 15th Cir. Ct. 
filed Mar. 6, 2008). 
Lewis 'Fein PI. 
3059 GuADAvinui. Surf 340,ECcONLIT Glow, Ft0INDA 3311) 
I ol 316 
EFTA00180407

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 2 of 100 
Jan. 24, 2008) (the "First Federal Action"). The First Federal Action named 
Jeffrey Epstein as the sole tortfeasor, made the identical operative allegations as 
the instant Amended Complaint, and demanded damages of $50 million. (The 
amount of the demand against Epstein is evidently the product of recent reports in 
the press that Epstein is wealthy.) 
The First Federal Action was quickly followed by a series of substantially 
identical "Jane Doe" lawsuits, all filed by the same attorney in a three-month span. 
Compare Jane Doe #1 v. Epstein, Case No. 08-cv-80069-KAM (S.D. Fla. filed 
Jan. 24, 2008), with Jane Doe #2 v. Epstein, No. 08-CV-80119-KAM (S.D. Fla. 
filed Feb. 6, 2008) (asserting identical causes of action based on the same operative 
allegations), Jane Doe 113 v. Epstein, No. 08-CV-80232-KAM (S.D. Fla. filed Mar. 
5, 2008) (same), Jane Doe #4I. Epstein, No. 08-CV-80380-KAM (S.D. Fla. filed 
Apr. 14, 2008) (same), and Jane Doe #5 v. Epstein, No. 08-80381-CV-KAM (S.D. 
Fla. filed Apr. 14. 2008) (same). 
On February 20, amid these filings, Jane Doe #1 was deposed in State of 
Florida v. Jeffrey Epstein, 502006CF009454AXXXMB (Fla. 15th Cir. Ct., filed 
Jul. 19, 2006), a parallel state-court criminal action. During that deposition, she 
made numerous admissions that completely undermined the allegations against 
Epstein that she had pled in her complaint. A copy of her deposition, with names 
2 
Lewis "rein 
. 
„.. 
3059 Gnaw AVON,. Sun 340. Cocoon', 
ICO3DA 33133 
3 o4315 
EFTA00180408

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 3 of 100 
redacted, is attached hereto (Exhibit A). Two days later, counsel for Jane Doe # I 
filed a notice of voluntary dismissal without prejudice in the First Federal Action. 
See Doe #1 v. Epstein, Case No. 08-CV-80069-KAM, DE 9. 
Two weeks later (March 6, 2008), having changed lawyers, Jane Doe #1 
refiled her complaint in Florida Circuit Court as the instant case, adding two 
nominal defendants: Mr= 
Mr. Epstein's personal secretary, and MI 
one of Jane Doe #1's contemporaries. These defendants have nothing to 
do with the plaintiff's case against Mr. Epstein, except that the presence of Ell 
MIEas a defendant in this new case, because she is a citizen of Florida (Am. 
Compl. ¶ 4), would ostensibly prevent complete diversity? 
As discussed below, however, 
was named in the refiled 
lawsuit only to destroy diversity jurisdiction, and to prevent any application of 18 
U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 
2 
Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a 
nonresident defendant for purposes of diversity jurisdiction and removal. 
3 
Section 3509(k) of Title 18, United States Code, provides as follows: 
If, at any time that a cause of action for recovery of compensation for 
damage or injury to the person of a child exists, a criminal action is pending 
which arises out of the same occurrence and in which the child is the 
victim, the civil action shall be stayed until the end of all phases of the 
criminal action and any mention of the civil action during the criminal 
proceeding is prohibited. As used in this subsection, a criminal action is 
pending until its final adjudication in the trial court. 
3 
LewisTein 
3059 GA00•3AvoN1, 3031340, 600:00.rt 64064, 10:0100 33133 
301316 
EFTA00180409

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 4 of 100 
Robson, besides having nothing to do with the substantive allegations of the 
plaintiff's $50,000,000 case, is a community-college student with no assets 
whatever. 
Even if this case purports to identify a new (and strategically nondiverse) 
tonfeasor, the refiled lawsuit is still directed against only one defendant—Jeffrey 
Epstein. Then and now, the operative allegations are the same: Jane Doe alleges 
that Jeffrey Epstein assaulted her "in violation of Chapter 800 of the Florida 
Statutes."4 (Am. Compl. ¶ 18.) To sharpen her lawsuit, the plaintiff says she is 
seeking damages in connection with a "conspiracy" (Am. Compl. ¶ 22), a "plan" 
(Am. Compl. ¶ 32), a "scheme" (Am. Compl. ¶ 32), and an "enterprise" (Am. 
Compl. ¶ 32), These theories of liability, however, cannot be supported by the 
allegations in the Amended Complaint. Even if everything in the Amended 
Complaint were true, recovery against 
, under any formulation, is 
impossible under Florida law. 
Focusing on the real parties to this controversy, the instant case could have 
(once again) been brought here in federal court—just like the four other "Jane 
18 U.S.C. § 3509(k) (emphasis added). 
4 Chapter 800, Florida Statutes, is entitled, "Lewdness; Indecent Exposure." 
4 
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Doe" lawsuits presently pending against Epstein, filed by this plaintiff's former 
lawyer. 
This case is properly removed to federal court, first, because there is 
complete diversity among the real parties-in-interest, second, because the amount 
in controversy exceeds $75,000, and third, because this Notice complies with the 
requirements of 28 U.S.C. § 1446. 
Discussion 
A. This case is properly removable because it falls within the original 
jurisdiction of the United States District Court for the Southern 
District of 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 though it was reconfigured to 
look like a state-court lawsuit, this action falls squarely within the bounds of the 
diversity-jurisdiction statute. See 28 U.S.C. § 1332(a)(1) (establishing that federal 
district courts have original jurisdiction over cases where the amount in 
controversy [is more than $75,0001 . . and [when the controversy] is between 
citizens of different states"). 
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I. The amount in controversy in this action exceeds $75,000. 
This case is a duplicate of the First Federal Lawsuit. In that case, Jane Doe 
pled "damages in excess of $50 million." See Doe v. Epstein, No. 08-80069-KAM 
(S.D. Fla. filed Jan. 24, 2008) (Compl. ¶ 6). That allegation is now deleted and the 
Amended Complaint substitutes a generic prayer for relief.5 It is clear, however, 
that Jane Doe still seeks more than $75,000 in damages. 
This case, precisely like the First Federal Action, seeks damages in 
connection with an alleged assault. (Am. Compl. ¶¶ 16-19.) 
The Amended 
Complaint alleges that Jane Doe "has suffered and will continue to suffer severe 
and permanent traumatic injuries, including mental, psychological, and emotional 
damages." (Am. Compl. ¶ 19.) These are the identical injuries Jane Doe asserted 
in the First Federal Action, and are no less serious simply because pled under a 
state-court caption. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. Supp. 2d 
812, 820 (N.D. III. 2007) (determining, in the context of diversity jurisdiction, that 
the $75,000 threshold had been satisfied, and "clearly [surpassed]," based on "the 
nature of the injuries alleged" in the complaint). 
5 The Complaint seeks damages for "[more than] . . . $15,000." (Am. Compl. ¶ 6.) This 
boilerplate is routinely used in Florida pleading practice to trigger application of section 
26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for 
filing in Florida's Circuit Court (as opposed to County Court). 
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To cement this point, the Eleventh Circuit Court of Appeals has said that 
"Ewlhen [a] complaint does not claim a specific amount of damages, removal from 
state court is proper if it is facially apparent from the complaint that the amount in 
controversy exceeds the jurisdictional requirement." Williams v. Best Buy Co., 
Inc., 269 F.3d 1316, 1319 (1 1 th Cir. 2001). This case meets that standard, and 
satisfies the first prong of diversity jurisdiction. 
2. There is complete diversity among the real parties to this 
controversy. 
Diversity jurisdiction requires complete diversity. 
Carden v. Arkoma 
Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the 
diversity statute to require `complete diversity' of citizenship." (citing Strawbridge 
V. Curtiss, 7 U.S. (3 Cranch) 267, 267-68 (1806))). See also MacGinnitie v. Hobbs 
Group, LLC, 420 F.3d 1234, 1239 (11th Cir. 2005) (stating that "[c]omplete 
diversity requires that no defendant in a diversity action be a citizen of the same 
state as any plaintiff"). As demonstrated below, this case satisfies the statutory 
requirement of complete diversity. 
(a) Plaintiff Jane Doe is a citizen of Florida. (Am, Compl. ¶ 1.) 6
'Jane Doe may, in fact, be a citizen of Georgia, not Florida, as she pled in her Amended 
Complaint. See New York Post, Jul. 1, 2008 (reporting that "On his way into court [for 
his state-court guilty plea on June 30], Epstein was served with a copy of a lawsuit by 
Doe, who has since moved to another state."); Jane Doc Depo. at 77, 112 (indicating that 
7 
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