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Case 9:08-cv-80804-KAM Document 22 Entered on FLSD Docket 09/15/2008 Page 1 of 8
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.
________________________________/
PLAINTIFF’S REPLY TO OPPOSITION TO REMAND
Plaintiff Jane Doe, a Florida citizen, properly sued Haley Robson, also a Florida
citizen, in this action. Contrary to Defendants’ contention, Defendant Robson was not
fraudulently joined because, when viewing the factual allegations in the light most
favorable to Plaintiff and resolving issues of Florida substantive law in favor of Plaintiff,
it is clear that Plaintiff has cognizable causes of action against Defendant Robson for civil
conspiracy, intentional infliction of emotional distress, and civil RICO. Accordingly, the
Court should remand this action to Florida state court.
A. Plaintiff is a Florida citizen
Plaintiff alleged in her complaint and testified in deposition that she is a Florida
resident. (Amended Complaint ¶ 1, DE 1, pp. 301; Deposition of Jane Doe, DE 1, pp.
31-32, 5:14-18, 6:6-10). In their notice of removal, Defendants cite a newspaper article
(from the same newspaper that Defendants chide Plaintiff for citing with regard to
Defendant Robson describing herself as the Hollywood madam Heidi Fleiss) in which it
Case 9:08-cv-80804-KAM Document 22 Entered on FLSD Docket 09/15/2008 Page 2 of 8
is reported that Plaintiff had moved to another state in order to intimate that Plaintiff
made fraudulent allegations regarding her residency. (DE 1, p. 7 n.6). Defendants then
chide Plaintiff in their opposition
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