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Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08/18/2008 Page 1 of 11
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 08-80804-CIV-MARRA/JOHNSON
JANE DOE, a/k/a,
JANE DOE NO. 1,
Plaintiff,
vs.
JEFFREY EPSTEIN, HALEY
ROBSON, and SARAH KELLEN,
Defendants.
________________________________/
MOTION TO REMAND
Plaintiff Jane Doe moves the Court to remand this action to state court for lack of
subject matter jurisdiction and states as follows:
1. Although Plaintiff Jane Doe, a Florida citizen, sues Haley Robson, also a Florida
citizen, in this action, Defendants removed the case to federal court on July 21,
2008, citing diversity of citizenship as the basis for federal subject matter
jurisdiction.
2. Defendants claim that Haley Robson, who has described herself as Heidi Fleiss
(the Hollywood madam), 1 has “nothing to do with the plaintiff’s case against Mr.
1
See New York Post, Oct. 1, 2007 (reporting “Some of the girls, legal documents indicate,
were recruited by Haley Robson, now 21, who described herself as ‘like Heidi Fleiss,’ the
notorious Hollywood madam.”); Palm Beach Post, Aug. 14, 2006 (reporting that
Defendant “Robson told detectives, ‘I'm like a Heidi Fleiss.’”).
Case 9:08-cv-80804-KAM Document 11 Entered on FLSD Docket 08/18/2008 Page 2 of 11
Epstein,” (Notice of Removal, DE 1, p. 3) and that Plaintiff fraudulently joined
her in this action to prevent complete diversity. 2
3. As demonstrated in Plaintiff’s amended complaint, however, Defendant Robson
was a vital part of the scheme to lure underage girls, including Plaintiff, to
[…]