This document is a Notice of Removal filed by defendants Jeffrey Epstein, Sarah Kellen, and Haley Robson, seeking to move a civil lawsuit filed by Jane Doe from the Circuit Court of the Fifteenth Judicial Circuit in Palm Beach County, Florida, to the United States District Court for the Southern District of Florida. The defendants argue that the non-diverse defendant, Haley Robson, was fraudulently joined solely to defeat diversity jurisdiction and prevent removal. Attached as Exhibit A is a deposition transcript of Jane Doe (whose name is redacted) taken on February 20, 2008, in a related criminal case, where she is questioned about her age, MySpace profiles, inconsistencies in her statements to police regarding sexual contact with Epstein, and her interactions with various attorneys and law enforcement officials.
This is a page from a deposition transcript involving attorneys Mr. Tein and Mr. Leopold. Tein questions a redacted witness about an incident at the 'Quarterdeck Tavern' where the witness's manager, Justin, allegedly lied to process servers to hide the witness. The page opens with a contentious exchange between the lawyers before a recess is taken.
This document is a page from a deposition transcript dated July 26, 2017. An attorney, Mr. Tein, questions an unnamed deponent about a photograph (marked 18-001), in which the deponent identifies themself and Tiffany Rich. Mr. Tein then characterizes Tiffany Rich as the deponent's friend from the Quarterdeck Tavern. Other attorneys, Mr. Leopold and Mr. Goldberger, are also present and interject to ensure the clarity of the record.
This is page 55 of a deposition transcript dated July 26, 2017. Attorney Mr. Tein questions a witness about an incident at the Quarterdeck Tavern where she allegedly asked co-workers to lie and switched name tags with a friend named Tiffany to avoid people serving papers. The witness denies asking anyone to lie but admits name tags were switched, claiming it was a coincidence common among staff. Attorneys Leopold and Goldberger discuss the marking of Exhibit 18-001 and photographs.
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