021.pdf
730 KB
Extraction Summary
13
People
7
Organizations
5
Locations
3
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal pleading (opposition to remand motion)
File Size:
730 KB
Summary
This document is an 'Opposition to Remand Motion' filed by defendants Jeffrey Epstein and Sarah Kellen in September 2008 in the Southern District of Florida. The defendants argue that the case should remain in federal court because the plaintiff fraudulently joined co-defendant Haley Robson (a Florida resident) solely to destroy diversity jurisdiction. The filing contends that the plaintiff has no valid cause of action against Robson for civil conspiracy, intentional infliction of emotional distress (IIED), or civil RICO under Florida law, arguing that Robson's alleged actions do not meet the legal standards for these torts.
People (13)
| Name | Role | Context |
|---|---|---|
| Jane Doe No. 1 | Plaintiff |
Alleged victim of sexual assault; suing Epstein, Robson, and Kellen; resident of Florida (or possibly Georgia); depos...
|
| Jeffrey Epstein | Defendant |
Accused of sexual assault and RICO violations; incarcerated in a Florida jail at the time of filing; described by pla...
|
| Haley Robson | Defendant |
College student; described by plaintiff as a 'key player' and 'recruiter'; alleged to have described herself as 'Heid...
|
| Sarah Kellen | Defendant |
Co-defendant alongside Epstein and Robson; represented by Bruce E. Reinhart.
|
| Theodore J. Leopold | Attorney |
Counsel for Plaintiff Jane Doe; managing partner of Ricci-Leopold.
|
| Michael R. Tein | Attorney |
Counsel for Defendant Jeffrey Epstein; Lewis Tein, P.L.
|
| Guy A. Lewis | Attorney |
Counsel for Defendant Jeffrey Epstein; Lewis Tein, P.L.
|
| Jack A. Goldberger | Attorney |
Counsel for Defendant Jeffrey Epstein; Atterbury, Goldberger & Weiss, P.A.
|
| Robert D. Critton | Attorney |
Counsel for Defendant Jeffrey Epstein; Burman, Critton, Luttier & Coleman, LLP.
|
| Michael J. Pike | Attorney |
Counsel for Defendant Jeffrey Epstein; Burman, Critton, Luttier & Coleman, LLP.
|
| Bruce E. Reinhart | Attorney |
Counsel for Defendant Sarah Kellen.
|
| Douglas M. McIntosh | Attorney |
Counsel for Defendant Haley Robson.
|
| Jason A. McGrath | Attorney |
Counsel for Defendant Haley Robson.
|
Timeline (3 events)
2008-01-24
Original lawsuit filed (No. 08-CV-80069-KAM).
Southern District of Florida
2008-02-20
2008-09-05
Locations (5)
| Location | Context |
|---|---|
|
Jurisdiction of the court
|
|
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Location of defense attorney offices
|
|
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Location of Lewis Tein, P.L.
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Location of Ricci-Leopold, P.A.
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Site of alleged massage and assault
|
Relationships (3)
Plaintiff alleges Robson was a 'key player' and 'recruiter' who found and delivered underage girls to Epstein.
Named together as defendants in the lawsuit.
Plaintiff alleges Robson coordinated an illegal transaction with her and served as a go-between.
Key Quotes (5)
"The plaintiff suggests she is insulated from any fraudulent-joinder challenge so long as she has 'at least a possibility' of 'recover[ing] against Defendant Robson...'"Source
021.pdf
Quote #1
"Even in the light most favorable to the plaintiff, the allegations are insufficient to establish a cause of action under Florida law against Haley Robson."Source
021.pdf
Quote #2
"Resorting to unsworn, inadmissible, improper double-hearsay, the plaintiff proclaims that Robson 'has described herself as Heidi Fleiss' (DE 11 at 1), the 'notorious Hollywood madam'..."Source
021.pdf
Quote #3
"...the plaintiff acknowledges that she intended 'to give Epstein a massage for monetary compensation' (DE 1-3 at 103), even though she was unlicensed, untrained, and unqualified..."Source
021.pdf
Quote #4
"To plead a legal cause of action, the plaintiff still must allege a real, recognized tort."Source
021.pdf
Quote #5
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