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(b) Defendant Jeffrey Epstein is a citizen of the U.S. Virgin Islands,' 
(c) Defendant 
is a citizen of New York. (Am. Compl. ¶ 5.) 
3. Defendant 
was fraudulently joined to defeat diversity. 
"A non-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 mother and natural guardian for Jane Doe b I" with jurat executed 
in Georgia before a Georgia notary), DE 4-2, Jane Doe No. I v. Epstein, Case No. 08-
80069-Civ-Marra (1/29/08); Intervenor's Complaint, at ¶ 2 (filed by "Jane Doe's Mother" 
and stating that "Jane Doe's Mother is a citizen and resident of the State of Georgia."), 
DE 5-2, Jane Doe No. I v. Epstein, Case No. 08-80069-Civ-Marra (1/29/08); Petition for 
Removal of Disability of Non-Age, at ¶¶ I, 2, 7 (filed "on behalf of S.D.G.," alleging that 
"The mother is 
, and her address is .... Ga.," and stating that 
"S.D.G. is also t e unnamed party in a lawsuit filed by her father on her behalf in the 
U.S. District Court for the Southern District of Florida, Case No. 08-80069, which was 
filed without the consent of the mother"), In re Sandberg v. Gonzalez Case No. 50 2008 
DR 001141 (Palm Beach Co. Family Ct.) (1/31/08). If this turns out to be the case, there 
is complete diversity, regardless ofillin 
citizenship. Although the Eleventh Circuit 
has recently indicated that a district court may not conduct jurisdictional discovery under 
such circumstances, another division of this Court has since allowed it. Compare Lowery 
v. Ala. Power Co., 483 F.3d 1184, 1215-16, 1221 (11th Cir. 2007) (holding that 
jurisdictional discovery to determine citizenship upon removal is inappropriate), with 
Calixto v. BASF Constr. Chemicals, LLC, slip op., Case No. 07-60077-CIV-ZLOCH, 
2008 WL 1840717, *1 (S.D. Fla. Apr. 22, 2008) (ordering that parties "shall engage in 
jurisdictional discovery for the Court to determine the citizenship of BASF and whether it 
has subject-matter jurisdiction over this action"). 
' 
The Amended Complaint erroneously states that Jeffrey Epstein is a citizen of New 
York. 
8 
Lewis Tsinn. 
3059 Gum Mimic Sum 140, Cocoon Glow, Mow 33133 
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Oct. 15, 2007) (Moreno, J.) (citing Riley v. Merrill Lynch, Pierce, Fenner & Smith, 
Inc., 292 F.3d 1334, 1337 (11th Cir. 2002)); accord, e.g., Tedder v. F.M.C. Corp., 
590 F.2d 1 15, 117 (5th Cir. 1979) (denying motion to remand where two resident 
defendants were joined for the fraudulent purpose of defeating federal jurisdiction). 
In this case, the plaintiff relies on her original allegations to support three causes of 
action against 
: civil conspiracy (Am. Compl. ¶¶ 20-23); Intentional 
Infliction of Emotional Distress (Am. Compl. ¶¶ 23-28); and civil RICO (Am. 
Compl. ¶¶ 29-34). These allegations, however, do not support these claims, or 
any other theory of liability that would allow recovery against 
. Cf. 
Parks v. The New York Times Co., 308 F.2d 474, 477 (5th Cir. 1962) (observing 
that "determination of fraudulent joinder is to be based on whether there was a real 
intention on colorable grounds to procure a joint judgment") (emphasis added).8
(a)Nonresident defendants have a right of removal. 
The removal statute was enacted specifically "to protect defendants." Legg v. 
Wyeth, 428 F.3d 1317, 1325 (11th Cir. 2005). Cf., e.g., Picquet v. Amoco Prod. 
Co., 513 F. Supp. 938, 941 (M.D. La. 1981) (explaining that courts developed the 
fraudulent-joinder doctrine to protect "the right [of removal] granted to 
8 
In Bonner v. City of Prichard, 661 F.2d 1206, 1207 (11th Cir. 1981) (en bane), the 
Eleventh Circuit Court of Appeals adopted as binding precedent all decisions of the 
former Fifth Circuit rendered prior to October 1, 1981. 
9 
LeNyiA,Tyin 
3059 GPM° AVTOPX. Swig 340, COCOINI 69091, halm 33133 
9 91310 
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[defendants] by . . . Congress"). In this case, by reconstituting her original federal 
lawsuit and refiling it in state Court, the plaintiff has clearly sought to avoid the 
strictures of the mandatory stay of this case that federal law requires under 18 
U.S.C. § 3509(k).9
In federal court, pursuant to 18 U.S.C. § 3509(k), this action must be 
automatically stayed pending final disposition of an ongoing parallel criminal 
action against Mr. Epstein. See 18 U.S.C. § 3509(k) (providing that a parallel civil 
By filing in state court, the plaintiff's attorney has also evidently sought to avoid the 
clear command of our local rules forbidding public comment about the merits of a 
pending lawsuit. Compare S.D. Fla. Local Rule 77.2(7) ("A lawyer or law firm 
associated with a civil action shall not during its investigation or litigation make or 
participate in making an extrajudicial statement, other than a quotation from or reference 
to public records, which a reasonable person would expect to be disseminated by means 
of public communication if there is a reasonable likelihood that such dissemination will 
interfere with a fair trial and which relates to (a) Evidence regarding the occurrence or 
transaction involved. (b) The character ... of a party .... (d) The lawyer's opinion as to 
the merits of the claims . . . •"), with Ricci—Leopold Home Page, http:// 
www.riccilaw.com (click on "Breaking News," then access the hyperlink entitled, 
03/13/08 - Consumer Justice Attorney Ted Leopold Files Case to aid Jane Doe in seeking 
justice against sexual predator Jeffrey Epstein and his associates. ) (describing character 
of party defendant Epstein as a "sexual predator" (a term defined by Florida criminal 
statutes) and quoting the plaintiff's attorney "Ted Leopold, managing partner" as 
characterizing Epstein as "an extremely powerful and wealthy man," with "vast 
resources," who acted "in the vilest way" at his "lavish mansion" with "lurid fantasies" 
and inflicting "untold damage," and opining that he should "be held accountable;" also 
quoting the plaintiff's attorney as opining that. Tiflis case is both about justice and 
making sure that a wealthy and powerful man knows that he is not above the law;" also 
quoting the plaintiff's attorney's view of the evidence that plaintiff "continues to endure 
emotional trauma daily") (Web site last visited July 17, 2008). 
10 
3059Gtao Avom, Sore 340,Cocoma Giver, 'taut.% 33133 
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action arising from an alleged sexual assault of a minor "shall be stayed until the 
end of all phases of [any] criminal action") (emphasis added). In this case, there is 
a parallel federal criminal grand jury action pending in the Southern District of 
Florida, In re Grand Jury, No. FGJ 07-103(WPB) (S.D. Fla.), which arises out of 
the same allegations pled here. Thus, in resorting to fraudulent joinder, the 
plaintiff has sought to avoid any application of this otherwise controlling statute. 
Cf. Doe v. Francis, No. 5:03 CV 260 MCR/WCS, 2005 WL 517847, at *1-2 (N.D. 
Fla. Feb. 10, 2005) (staying civil diversity action over plaintiffs' objections on 
grounds that "the language of 18 U.S.C. § 3509(k) is clear that a stay is required in 
a case . . . where a parallel criminal action is pending which arises from the same 
occurrence involving minor victims") (emphasis added). 
Even outside the context of a mandatory federal statute, "the Supreme Court 
has] admonished [that] 'the Federal courts should not sanction devices intended to 
prevent a removal to a Federal court where one has that right, and should be 
equally vigilant to protect the right to proceed in the Federal court.' Legg, 428 
17.3d at 1325 (citing Wecker v. Nat? Enameling & Stamping Co., 204 U.S. 176, 
186 (1907)). See also id. (observing that "Congress 'did not extend [to defendants 
a right of removal] with one hand, and with the other give plaintiffs a bag of tricks 
11 
n rt. 
3059 GRAMIANINW. Sun 340. COCONUT GM1/41. Won* 33133 
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to overcome it'" (quoting McKinney v. Bd. of Trustees of Maryland Cmty. Colt, 
955 F.2d 924, 928 (4th Cir. 1992))). 
To protect a nonresident defendant's right of removal, a federal court will 
"determine the matter of jurisdiction" by examining "the true situation both as to 
parties and causes of action." 
Bernblum v. Travelers' Inc. Co., 9 F. Supp. 34, 35 
(W.D. Mo. 1934) (emphasis added). See also id. (observing that "[t]he federal 
courts will . . . strike out the fiction injected into a case by a party to prevent 
removal"). In accordance with these principles, a plaintiff cannot destroy diversity 
jurisdiction simply by conjuring up a nondiverse defendant; there must be at least 
some "possibility that the state law might impose liability on [the nondiverse] 
defendant under the circumstances alleged in the complaint." Florence v. Crescent 
Res., LLC, 484 F.3d 1293, 1299 (11th Cir. 2007) (citations omitted). See also, 
Holloway v. Morrow, No. 07-0839-WS-M, 2008 WL 401305, at *5 (S.D. Ala. Feb. 
I I, 2008) (emphasizing that "`[t]he potential for legal liability must be reasonable, 
not merely theoretical" (quoting Legg v. Wyeth, 428 F.3d 1317, 1325 n.5 (11th 
Cir. 2005))) (emphasis added). 
In this case, the plaintiffs have tried to whip Jane Doe's original, one-
defendant complaint into a froth that looks non-federal. Cf. Owens v. Swan, 962 F. 
Supp. 1436, 1439 (D. Utah 1997) (noting that "although plaintiffs' amended 
12 
Lewis.Teinii.
3039Gamy Avinim, Sun 340, COCOMUIGNOW, FlOOIDA 33133 
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complaint contains four claims for relief, the first and second claims state only one 
cause of action") (emphasis added). Using her original allegations and adding 
nothing, Jane I)oe has tried to add claims against 
for civil 
conspiracy (Am. Compl. ¶¶ 20-23), Intentional Infliction of Emotional Distress 
(Am. Compl. ¶¶ 24-28), and civil RICO (Compl. ¶¶ 29-34) in order to append a 
nondiverse defendant to her Complaint. These claims, however, are untenable 
under Jane Doe's own allegations, and therefore cannot be used to destroy 
diversity jurisdiction. 
(b) There is no ossibili 
that the plaintiff can establish a cause of 
action against 
under Florida law. 
(i) The conspiracy claim against Robson must fail. 
As a general rule, "[a]n actionable conspiracy [under Florida law] requires 
an actionable underlying tort or wrong." Wright v. Yurko, 446 So. 2d 1162, 1165 
(Fla. 5th DCA 1984) (citations omitted) (emphasis added).1°
10 
This case is governed by the general rule. CJ: Chztrnica v. Miami Jai-Alai, Inc., 353 
So. 2d 547, 550 (Fla. 1977) (noting that while there is "ordinarily . . . no independent tort 
for conspiracy," there is a narrow exception to this rule when "the plaintiff can show 
some peculiar power of coercion possessed by the conspirators by virtue of their 
combination") (emphasis added). See generally Liappas v. Augoustis, 47 So. 2d 582, 583 
(Fla. 1950) (observing that "'instances of conspiracy which is in itself an independent tort 
are rare and should be added to with caution" (quoting Fleming v. Dane, 22 N.E.2d 
609, 611, (Mass. 1939))) (emphasis added). Plainly, this case involves the general rule, 
not the narrow exception, because only one person could have caused Jane Doe's 
injuries. Cf. Martin v. Marlin, 529 So. 2d 1174, 1179 (Fla. 3d DCA 1988) (upholding 
13 
LemdASsi n re. 
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Here, Jane Doe cannot assert a cause of action for "violation of Chapter 800, 
Florida Statutes" (Am. Compl. ¶ 18) because there is no private right of action 
under that Chapter. See generally Am. Home Assurance Co. v. Plaza Materials 
Corp., 908 So. 2d 360, 374 (Fla. 2005) (observing that "not every statutory 
violation carries a civil remedy" (citing Villazon v. Prudential Health Care Plan, 
Inc.. 843 So. 2d 842, 852 (Fla. 2003))). See also, e.g., Miami Herald Publ 'g Co. v. 
Ferre, 636 F. Stipp. 970 (S.D. Fla. 1985) (King, C.J.) (holding that violation of 
Florida's criminal extortion statute does not give rise to a civil cause of action for 
damages); Mantooth v. Richards, 557 So. 2d 646, 646 (Fla. 4th DCA 1990) (per 
curiam) (affirming dismissal of plaintiff's claim for parental kidnapping where 
"the mentioned statutes concern only criminal violations and do not afford a civil 
remedy") (citation omitted) (emphasis added); Wright v. Yurko, 446 So. 2d 1162, 
1 165 (Fla. 5th DCA 1984) (holding that "[a]n act which does not constitute a basis 
for a cause of action against one person cannot be made the basis for a civil action 
for conspiracy"). 
In this case, Jane Doe's claim under Count II (civil conspiracy) fails because 
it derives exclusively from Count I (violation of Chapter 800, Florida Statutes). Cf 
grant of summary judgment against claim for independent conspiracy, noting that 
'hen the concerted acts of the defendants do not create a greater harm than if the acts 
were committed by one person alone, then there can be no recovery"). 
14 
Lewis greinri 
3059 Game Avuitm, km. 140, (coma GOMMORIOA 33133 
14 of 316 
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Buchanan v. Miami Herald Publ'g Co., 230 So. 2d 9, 12 (Fla. 1969) (holding that 
where Count I of the complaint had failed to state a cause of action for malicious 
prosecution, there could be no civil-conspiracy claim in Count II "based on the 
allegations of Count I"). Because the statute she expressly pleads as the basis for 
Count I, Chapter 800, Florida Statutes, provides no civil remedy, Jane Doe cannot 
prevail on Count I. Therefore, she cannot prevail on her claim for conspiracy 
(Count II) to violate Chapter 800, Florida Statutes (Count I). 
(ii) The plaintiff cannot prevail against nondiverse defendant 
on her claim for Intentional Infliction 
of Emotional Distress (TIED). 
Even if the plaintiff, for the sake of argument, can assert an LIED claim 
against Jeffrey Epstein, the plaintiff still does not have a cause of action for LIED 
against 
First, the plaintiff cannot recover damages in connection 
with her own illegal conduct; and second, the plaintiff's purported LIED claim fails 
• as a matter of law. 
15 
Lewis Teinru.
3039 GIANDAvlowl. Suitt 340, COCONUT GLOW, f tOMDA 33133 
1$ of 11s 
EFTA00180421

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1. 
The plaintiff seeks damages in connection with her 
own illegal conduct. 
The plaintiff concedes that she went to Jeffrey Epstein's house "to give 
Epstein a massage for monetary compensation." (Am. Compl. ¶ 13.) The plaintiff 
also concedes, in the guise of an allegation, that 
"brought Jane Doe 
to Epstein's mansion in Palm Beach" to help the plaintiff execute her own plan. 
(Am. Compl. ¶ 13.) Yet, the plaintiff's plan was illegal: under Florida law, it is a 
crime "to practice massage" without a license. § 480.047, Ha. Stat. (1997). To say 
it another way, the plaintiff admits that she went to Mr. Epstein's house to commit 
a crime. 
Based on these allegations, it is clear that the plaintiff seeks damages in 
connection with her own illegal conduct; this is enough to support a finding of 
fraudulent joinder. See Florence v. Crescent Resources, LLC, 484 F.3d 1293, 1298 
n.3 (11th Cir. 2007) (acknowledging that "under some circumstances, application 
of an affirmative defense can support a finding of fraudulent joinder). This 
conclusion is supported by well-established principles. 
Under Florida law, a plaintiff cannot recover damages flowing from her own 
illegal conduct. See Hall v. Hall, 93 Fla. 709, 112 So. 622, 628 (1927) (referring to 
"the universal rule of our law that one in a court of justice cannot complain . . . of 
another's wrong whereof he was a partaker") (internal quotation marks and citation 
16 
Lewis 'Fein,. 
3059 Gump Avesiut, Sint 340. CocoNci 640vt., ROMA 31133 
16 
316 
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omitted) (emphasis added); Turner v. Anderson, 704 So. 2d 748, (Fla. 4th DCA 
1998) ("[N]o public policy should allow appellant to recover damages as a result of 
engaging in criminal conduct such as occurred in this case."). Cf. Ewell v. Daggs, 
108 U.S. 143, 149 (1883) (stating that "`[n]o court will lend its aid to a [plaintiff] 
who founds [a] cause of action upon an immoral or an illegal ace") (quoting 
Holman v. Johnson, 98 Eng. Rep. 1120 (K.B. 1775)); see also id. (explaining that 
this policy is "'not for the sake of the defendant, but because [the courts] will not 
lend their aid to such a plaintiff" (quoting Holman, 98 Eng. Rep. 1120)) 
(emphasis added); Balas v. Ruzzo, 703 So. 2d 1076, 1082 (Fla. 5th DCA 1997) 
(Harris, J., concurring) (remarking in the context of an action brought against an 
alleged prostitution house that "the court should continue its tradition of not 
interceding in civil conflicts involving transactions that are either illegal or are 
against public policy"). 
Based on the foregoing, the plaintiff cannot blame someone else 
for the consequences of her own criminal conduct. Cf. Feld & Sons, Inc. 
v. Pechner, Dorfman, Wolffe, Rounick and Cabot, 458 A.2d 545, 552 (Pa. Super. 
Ct. 1983) (holding that law-firm clients could not recover damages flowing from 
their own criminal acts, even though clients' lawyers had suggested the unlawful 
conduct to begin with). See also Turner v. Anderson, 704 So. 2d 748, 751 (Fla. 4th 
17 
Lewis 'Fein 31 
3059 Gump Amon, Stun 340, COCOWT GiGYI, FIOC 33133 
IT c4 316 
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DCA 1998) (approving reasoning in Feld & Sons, holding that "no public policy 
should allow [a plaintiff] to recover damages as a result of engaging in criminal 
conduct" where the plaintiff had provided false testimony at an arbitration 
proceeding). 
2. 
The plaintiff's LIED claim fails as a matter of law. 
To state a cause of action for LIED, a complaint must allege four elements: 
1) deliberate or reckless infliction of mental suffering; (2) outrageous conduct; (3) 
the conduct caused the emotional distress; and (4) the distress was severe. Metro. 
Life Ins. Co. v. McCarson, 467 So. 2d 277, 278 (Fla. 1985). Whether conduct is 
outrageous enough to support a claim of intentional infliction of emotional distress 
is a question of law, not a question of fact. Liberty Mut. Ins. Co. v. Steadman, 968 
So. 2d 592, 595 (Fla. 2d DCA 2007) (citations omitted). 
In this case, without reaching the question of "outrage," the plaintiff has 
failed to show that 
conduct - - allegedly arranging an illegal 
sexual massage that the plaintiff herself agreed to perform - - itself caused the 
plaintiff to suffer any emotional distress. Even if the alleged agreement was 
fraudulently induced, the plaintiff's LIED claim flows from Epstein's alleged 
conduct, not the joint conduct of Robson and Doe in planning the massage. 
18 
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(iii) The plaintiff cannot prevail on her claim for civil remedies 
for criminal practices or racketeering ("civil RICO") pled in 
Count IV. 
A cause of action under section 772.104, Florida Statutes ("Civil Remedies 
for Criminal Practices") requires a showing of direct injury. Even assuming for 
the sake of argument that Jane Doe can establish that the defendants engaged in a 
"pattern of criminal activity," she cannot establish that she was directly injured by 
those activities. 
Section 772.104 allows someone to bring a civil RICO claim only if "he or 
she has been injured by reason of any RICO violation. § 772.104, Fla. Stat. 
(2007). Here, the allegations in Count IV, even if they are true, do not add up to a 
civil RICO claim because there is no proximate cause between the purported 
"pattern of criminal activity" and Jane Doe's alleged injuries. 
In a doomed attempt to satisfy the extremely high burden of pleading civil 
RICO under Florida law, the Amended Complaint lists a series of violations rooted 
in Florida's prostitution statutes. (Am. Compl. 1 31.) According to the Amended 
Complaint, the defendants participated in a criminal enterprise . .. or conspir[acy]" 
(Am. Compl. ¶ 30) over an unspecified length of time "to repeatedly find and 
bring [Jeffrey Epstein] underage girls . . . in order for Epstein to solicit, coerce, 
entice, compel, or force such girls in acts of prostitution and/or lewdness" (Am. 
19 
Lielt i tTSinn• 
3059 GuADAviran, Suill 340, Comm? Goc/v1, Ftomim 33133 
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Compl. ¶ 32). The alleged "pattern of criminal activity" comprises violations of 
Chapter 796, Florida Statutes—the chapter that proscribes various crimes of 
prostitution.13
These allegations do not tie directly into Jane Doe's alleged psychic injuries. 
In contrast to a cognizable RICO claim, this action concerns only an isolated 
occurrence. More important, the alleged injuries in this case are pled to have 
resulted from an alleged sexual assault, an assault "in violation of Chapter 800 of 
the Florida Statutes" (Am. Compl. ¶ 18)—not anything having to do with the 
facilitation of prostitution, or more succinctly, the violation of Florida's 
prostitution law. 
Civil RICO claims are extraordinarily difficult to plead successfully. There 
are examples in the case law of RICO claims stemming from a prostitution 
enterprise, but they are vastly different from what plaintiff pleads here. They 
involve, for example, prostitutes who sued a house of prostitution (as an 
"enterprise") for inflicting systematic and repetitive abuse on them, over time. See 
Bolas v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example 
of a civil RICO claim against the operators of an alleged "house of prostitution," 
I) 
The Amended Complaint alleges a "pattern of criminal activity" comprising the 
following criminal violations: §§ 796.03, 796.07(2)(f), 796.07(2)(h), 796.045, and 
796.04, Fla. Stat. (Am. Compl. ¶ 31.) 
20 
Lewis Tein 
3059 Gun. An Rut, Wm 340, Cocosur GIOVI, FIORICIA 33133 
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where petitioners alleged that they had "suffered emotional pain, anguish, 
humiliation, insult, indignity, loss of self-esteem, inconvenience, hurt and 
emotional distress" as a result of being forced repeatedly, over time, to "perform 
sexual acts to retain their employment"). Here, even if the Amended Complaint 
can be read to plead that the defendants schemed to solicit other massages from 
other people (see, e.g., Am. Compl. ti 9, I I, 12, 32), those activities are not 
alleged in any way to have impacted Jane Doe. Cf., e.g., Palmas Y Bambu, S.A. v. 
E.I. Dupont De Nemours & Co., Inc., 881 So. 2d 565, 570 (Ha. 3d DCA 2004) 
(holding that "'indirect injuries, that is injuries sustained not as a direct result of 
predicate acts . . . will not allow recovery under Florida RICO."' (quoting 
O'Malley v. St. Thomas Univ., Inc., 599 So. 2d 999, 1000 (Fla. 3d DCA 1992))) 
(emphasis added). 
Because the Amended Complaint does not satisfy the direct-injury 
requirement under Florida's RICO law, Jane Doe has failed to allege a cause of 
action against 
for violation of section 772.103, Florida Statutes. 
B. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446. 
1. This notice of removal is timely. 
In accordance with 28 U.S.C. § 1446, this notice of removal is timely. Only 
defendant Epstein has been served with process. Defendants 
21 
Lewis 'rein ri 
3059 GIMP Arum, Sun 340, Coccroul GrOvt,Itemoit 33133 
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have not yet been served. In a multi-defendant lawsuit, removal is timely when 
effected within 30 days after the last defendant is served. See Hill Dermaceuticals, 
Inc. v. RX Solutions, United Health Group, Inc., No. 6:08-cv-330-Orl-31KRS, 
2008 WL 1744794, at *3 (M.D. Fla. Apr. 11, 2008) (concluding that removal 
petition was timely where it was filed within 30 days after the last defendant was 
served). 
2. Notice has been given, and state-court 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 authorized to 
represent that all of the defendants join this Petition and consent to removal. 
Conclusion 
Because this is a civil action between citizens of different states, excluding 
any fraudulently joined parties, and the amount in controversy exceeds $75,000, 
exclusive of interests and costs, this Court has original jurisdiction over this action 
pursuant to 28 U.S.C. § 1332(a)( I ). 
22 
Le VO.p .,tilt1 
rl. 
3059 Game Avirout, SLUE 340, COCOONS GAOVI, FICODA 33133 
22 of all 
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WHEREFORE, the Defendants, Jeffrey Epstein, mom and 
MII remove this case from Palm Beach Circuit Court to the United States 
District Court for the Southern District of Florida. 
Respectfully submitted, 
LEWIS TEIN, A.L. 
3059 Grand Avenue, Suite 340 
Coconut Grove, Florida 33133 
Tel: 305 442 1101 
Fax: 305 442 6744 
By: lb* (ile: 
GUY A. LEWIS 
Fla. Bar No. 623740 
IN 
Fla. Bar No. 993522 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
Tel. 561 659 8300 
Fax. 561 835 8691 
By: 
Jack A. Goldberger 
Fla, Bar No. 262013 
Attorneys for Defendant Jeffrey Epstein 
23 
Lewis Teinn 
3059 Grao mum, Sum 340, Caowur Gam, tics 33133 
93 of 359 
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CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that the foregoing document is being served this day, 
July 18, 2008, on counsel of record identified on the service list by U.S. Mail. 
ir 
• 
14 lista 
Michael R. Tein 
24 
Lentyk.1:17fin ri. 
3059 Guido Avow', Sum 340, CocomviGeovt, flew 33333 
34 el 3111 
EFTA00180430

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Service List 
Theodore J. Leopold, Esq. 
Ricci-Leopold, P.A. 
2925 PGA Blvd., Suite 200 
Palm Beach Gardens, FL 33410 
Fax: 561 697 2383 
Counsel for Plaintiff Jane Doe 
Douglas M. McIntosh, Esq. 
Jason A. McGrath, Esq. 
McIntosh, Sawran, Peltz & Cartaya, P.A. 
Centurion Tower 
1601 Forum Place, Suite 1110 
West Palm Beach, Florida 33401 
Fax. 561 682-3206 
Counsel for Defendant 
Bruce E. Reinhart, Esq. 
Bruce E. Reinhart, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach, Florida 33401 
Fax. 561 828 0983 
Counsel for Defendant 
Robert D. Critton, Esq. 
Michael J. Pike, Esq. 
Burman, Critton, Luttier & 
Coleman, LLP 
515 N. Flagler Drive, Suite 400 
West Palm Beach, Florida 33401 
Fax. 561 515 3148 
Co-Counsel for Jeffrey Epstein 
25 
Lewis
 Pt 
3059 Csawt>Avitivt, Sung 340, Cocoma Gtaa, ham. 33133 
2544310 
EFTA00180431

Case 9:08-cv-80804-KAM 
Document 1 
Entered on FLSD Docket 07/21/2008 
Page 26 of 100 
EXHIBIT A 
EFTA00180432

Case 9:08-cv-80804-KAM 
ent 1 
Entered on FLSD Docket 07/21/2008 
Page 27 of 100 
nsor & Associates 
1cpaniny And Transcription. Inc 
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 
IN AND FOR PALM BEACH COUNTY, FLORIDA 
CASE NO. 2006 CF09454AXX 
STATE OF FLORIDA, 
JEFFREY EPSTEIN, 
Defendant. 
DEPOSITION OF 
Wednesday, February 20, 2008 
2:00 p.m. - 4:30 p.m. 
Palm Beach County Courthouse 
205 North Dixie Highway 
West Palm Beach, Florida 33401 
Reported By: 
Judith F. Consor, FPR 
Notary Public, State of Florida 
Consor & Associates Reporting and Transcription 
Phone - 561.682.0905 
Ph. 561.682.0905 - Fax. 561.682.1771 
1655 Palm Beach Lakes Blvd., Suite 500 - West Palm Beach, FL 33401 
27 of 316 
EFTA00180433