011.pdf
74.1 KB
Extraction Summary
8
People
5
Organizations
5
Locations
4
Events
4
Relationships
4
Quotes
Document Information
Type:
Legal motion (motion to remand)
File Size:
74.1 KB
Summary
This document is a Motion to Remand filed on August 18, 2008, by Plaintiff Jane Doe against Jeffrey Epstein, Haley Robson, and Sarah Kellen. The plaintiff seeks to move the case back to Florida state court, arguing that federal diversity jurisdiction is invalid because both the Plaintiff and Defendant Haley Robson are Florida citizens. The motion details allegations that Robson recruited the plaintiff (a minor at the time) for Epstein's sexual abuse scheme and argues that Robson is a legitimate defendant, not 'fraudulently joined' solely to prevent federal jurisdiction.
People (8)
| Name | Role | Context |
|---|---|---|
| Jane Doe / Jane Doe No. 1 | Plaintiff |
A Florida citizen and victim who was recruited at age 14 to give massages to Epstein; alleges sexual assault, conspir...
|
| Jeffrey Epstein | Defendant |
Accused of sexual assault and soliciting prostitution; described as incarcerated in a Florida jail under an 18-month ...
|
| Haley Robson | Defendant |
A Florida citizen accused of recruiting underage girls (including Plaintiff) for Epstein; described herself as 'like ...
|
| Sarah Kellen | Defendant |
Named as a defendant and co-conspirator in the scheme to lure underage girls.
|
| Heidi Fleiss | Reference |
The 'Hollywood Madam' whom Haley Robson compared herself to.
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| Spencer T. Kuvin | Attorney |
Counsel for Plaintiff Jane Doe; filed the motion.
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| Guy Alan Lewis | Attorney |
Counsel for Jeffrey Epstein; served via CM/ECF.
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| Michael R. Tein | Attorney |
Counsel for Jeffrey Epstein; served via CM/ECF.
|
Organizations (5)
| Name | Type | Context |
|---|---|---|
| United States District Court, Southern District of Florida |
The federal court where the case was removed and where the motion to remand was filed.
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| Ricci-Leopold, P.A. |
Law firm representing the Plaintiff.
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| Lewis Tein |
Law firm representing Defendant Jeffrey Epstein.
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| New York Post |
Cited in a footnote regarding reports on Haley Robson.
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| Palm Beach Post |
Cited in a footnote regarding reports on Haley Robson.
|
Timeline (4 events)
2006-08-14
Palm Beach Post report stating Robson told detectives she was 'like a Heidi Fleiss'.
Palm Beach Post
2008-07-21
Defendants removed the case to federal court citing diversity of citizenship.
Federal Court
Defendants
2008-08-18
Plaintiff filed Motion to Remand case to state court.
Southern District of Florida
Jane Doe
Spencer T. Kuvin
Locations (5)
| Location | Context |
|---|---|
|
Location of Epstein's mansion where the alleged abuse occurred; location of Plaintiff's counsel.
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State of citizenship for Jane Doe and Haley Robson; location of the state court requested for remand.
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Mentioned in footnotes regarding Jane Doe's mother's residence and potential citizenship questions.
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Address of Defense counsel.
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Address of Plaintiff counsel.
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Relationships (4)
Robson was paid by Epstein to recruit underage girls and take them to Epstein’s Palm Beach mansion.
Robson recruited Plaintiff (14 years old) using false pretenses.
Plaintiff alleges Epstein sexually assaulted and abused her.
Robson described herself as 'like Heidi Fleiss'.
Key Quotes (4)
"Robson told detectives, 'I'm like a Heidi Fleiss.'"Source
011.pdf
Quote #1
"Defendant Robson was a vital part of the scheme to lure underage girls, including Plaintiff, to Epstein’s home in order to subject them to sexual abuse..."Source
011.pdf
Quote #2
"Plaintiff’s damages resulting from Defendants making her a victim to their intentional, outrageous, and criminal conduct in no way flow from her decision as a 14-year old girl to make some extra money by giving a massage."Source
011.pdf
Quote #3
"Defendant Robson recruited Plaintiff, as she had done numerous others, under the belief that Plaintiff was economically disadvantaged and would be unlikely to contact authorities..."Source
011.pdf
Quote #4
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