EFTA00234068

dase 9:08-cv-80811-WJZ 
Document 1 
Entered on FLSD Docket 07)21:2008 FIFF4tyi Rik  D.C. 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO.: 
C.M.A., 
08-80811-Civ-ZLOCH/SNOW 
Plaintiff, 
vs. 
JEFFREY EPSTEIN and 
Defendants. 
NOTICE OF REMOVAL 
July 21, 2008 
STEVEN M. LARIMORE 
CLERK U.S. DIST. CT. 
5.0. OF FLA. MIAMI 
In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, 
Jeffrey Epstein and 1 
hereby remove this action' from Palm Beach 
County Circuit Court to the United States District Court for the Southern District 
of Florida, and respectfully state as follows: 
1. 
This case is within the original jurisdiction of this Court. 
This case is properly removable because it falls within the original 
jurisdiction of the United States District Court for the Southern District of Florida. 
See 28 U.S.C. § 1332(a)(1) (establishing that federal district courts have original 
I 
C.M.A. v. Epstein et aL, Case No. 50 2008 CA 005240 XXXX MB (Fla. 15th Cir. Ct. 
filed Feb. 21, 2008). 
Lewis.tein n. 
3059 Gray MINUE, Sum 340, COCONUT GROVE, FLORIDA 33133 
14440 
EFTA00234068

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Case 9:08-cv-80811-WJZ 
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Entered on FLSD Docket 07/21/2008 
Page 2 of 40 
jurisdiction over cases where the amount "in controversy [is more than $75,000] . . 
. and [when the controversy] is between citizens of different states"). 
2. 
The amount in controversy in this action exceeds $75,000. 
The Complaint contains a generic prayer for relief? It is clear, however, that 
the plaintiff seeks more than $75,000 in damages. This case seeks damages in 
connection with alleged sexual misconduct. (Compl. ¶¶ 6-7.) 
The Complaint 
alleges that M. 
has "suffered mental anguish, mental pain and suffering, 
psychic trauma, and a loss of the capacity for the enjoyment of life." (Compl. ¶ 9.) 
These are serious allegations. Cf., e.g., Woods v. Southwest Airlines, Co., 523 F. 
Supp, 2d 812, 820 (N.D. III. 2007) (determining, in the context of diversity 
jurisdiction, that the $75,000 threshold had been satisfied, and "clearly 
[surpassed]," based on "the nature of the injuries alleged" in the complaint); see 
also Williams v. Best Buy Co., Inc., 269 F.3d 1316, 1319 (11th Cir. 2001) ("When 
[a] complaint does not claim a specific amount of damages, removal from state 
court is proper if it is facially apparent from the complaint that the amount in 
controversy exceeds the jurisdictional requirement."). 
2 The Complaint seeks damages for "[more than] . . . S15,000." (Compl. ¶ 1.) This 
boilerplate is routinely used in Florida pleading practice to trigger application of section 
26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for 
filing in Florida's Circuit Court (as opposed to County Court). 
2 
Lewis. 'Lein 
n. 
3059 G.0.90AviNut, Stun 340, COCONW Gotovt, FLOMDA 33133 
20340 
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Further, the allegations by this plaintiff are virtually identical to allegations 
made in four separate civil actions, filed by four different plaintiffs, against Mr. 
Epstein in federal court.3 In each of those actions, the plaintiffs are seeking 
damages in excess of $50 million - - well over the $75,000 amount-in-controversy 
requirement for diversity jurisdiction. See Jane Doe No. 2 at D.E. 1 ¶ 4; Jane Doe 
No. 3 at D.E. 1 ¶ 4; Jane Doe No. 4 at D.E. 1 ¶ 4; Jane Doe No. Sat D.E. 1 ¶ 4. 
3. 
There is complete diversity. 
Diversity jurisdiction requires complete diversity. 
Carden v. Arkoma 
Assocs., 494 U.S. 185, 187 (1990) ("Since its enactment, we have interpreted the 
diversity statute to require `complete diversity' of citizenship." (citing Strawbridge 
v. Curtiss, 7 U.S. (3 Cranch) 267, 267-68 (1806))); see also MacGinnitie v. Hobbs 
Group, LLC, 420 F.3d 1234, 1239 (11th Cir. 2005) (stating that "[c]omplete 
diversity requires that no defendant in a diversity action be a citizen of the same 
state as any plaintiff"). As demonstrated below, this case satisfies the statutory 
requirement of complete diversity. 
(a) 
Plaintiff 
M
.
 
is a citizen of Florida. (Compl. ¶ 2.) 
3 See Jane Doe No. 2 v. Jeffrey Epstein, No. 08-CV-80119-1CAM (S.D. Fla. filed Feb. 6, 
2008); Jane Doe No. 3 v. Jeffrey Epstein, No. 08-CV-80232-KAM (S.D. Ha. filed Mar. 
5, 2008); Jane Doe No. 4 v. Jeffrey Epstein, No. 08-CV-80380-KAM (S.D. Fla. filed Apr. 
14, 2008); Jane Doe No. 5 v. Jeffrey Epstein, No. 08-80381-CV-KAM (S.D. Fla. filed 
Apr. 14. 2008). 
3 
Lewis Tein ro. 
3059 Como An,. . Soar 340. CCCONVI Gaavt, toitos 33133 
3040 
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(b) 
While the Complaint suggests that Mr. Epstein might be a citizen of 
New York or Florida, he is, in fact, a citizen of the U.S. Virgin Islands. 
(Epstein All. Ex. A.)4
(c) 
Contrary to the allegations in the Complaint, Defendant Sarah Kellen 
is a citizen of New York, not Florida. (Kellen Stmt. Ex. B.) 
4. 
This Notice satisfies the procedural requirements of 28 U.S.C. § 
1446. 
First, in accordance with 28 U.S.C. § 1446(6), this Notice is timely. Only 
defendant Epstein has been served with process. Defendant 
has not yet 
been served. See Hill Dermaceuticals, Inc. v. RX Solutions, United Health Group, 
Inc., No. 6:08-cv-330-Or1-31KRS, 2008 WL 1744794, at •3 (M.D. Fla. Apr. 11, 
2008) (concluding that removal petition was timely where it was filed within 30 
days after the last defendant was served). 
Second, in accordance with section 1446(d), defendants have served this 
Notice of Removal on July 21, 2008. 
Third, in accordance with section 1446(b), all of the defendants join this 
Petition and consent to removal. 
4  District courts may consider affidavits and other evidence to support removal 
jurisdiction. See Sierminski v. Transouth Fin. Corp., 216 F.3d 945, 949 (11th Cir. 2000). 
4 
Lewis :Fs in m. 
30S9 GRANO Amax, Sum 340, CCCONV? Goon, FLOOOM 33133 
4 cot 40 
EFTA00234071

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• Case 9:08-cv-80811-WJZ 
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5. 
The State Court docket has been filed. 
All papers filed in the State Court are attached to this Removal Petition. 
Conclusion 
Because this is a civil action between citizens of different states, excluding 
any fraudulently joined parties, and the amount in controversy exceeds $75,000, 
exclusive of interests and costs, this Court has original jurisdiction over this action 
pursuant to 28 U.S.C. § 1332(a)(1). 
WHEREFORE, the defendants, Jeffrey Epstein and 
remove 
this case from Palm Beach Circuit Court to the United States District Court for the 
Southern District of Florida. 
Respectfully submitted, 
LEWIS TEIN, P.L. 
3059 Grand Avenue, Suite 340 
Coconut Grove, Florida 33133 
Tel: 305 442 1101 
Fax: 305 442 67 4
By:
GUY A. 
A. L WIS 
Fla. Bar No. 623740 
[email protected] 
MICHAEL R. TEIN 
Fla. Bar No. 993522 
[email protected] 
5 
Lewis rein pi. 
3059 Gamo Avi out, Sun 340, COCOMPI Gmosa, Li mom 33133 
50140 
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ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Avenue South, Suite 1400 
West Palm Beach, Florida 33401 
Tel. 561 659 8300 
Fax. 561 835 8691 
By: 
Jack A. Goldberger 
Fla. Bar No. 262013 
[email protected] 
Attorneys for Defendant Jeffrey Epstein 
BRUCE E. REINHART, P.A. 
250 South Australian Avenue 
Suite 1400 
West Palm Beach, Florida 33401 
Tel. 561202 6360 
Fax. 561 828 0983 
By: 
, 
14.(0, cot 
Bruce E. Reinhart 
Fla. Bar No. 10762 
[email protected] 
Attorneys for Defendant Sarah Kellen 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that the foregoing document is being served this day, 
July 21, 2008, on counsel of record identified on the service list by U.S. Mail. 
Michael R. Tein 
6 
Lewis "rein al 
3059044PeAvoiut, Suns 340. COCONUT GROW. fICOIOA 33133 
Got 40 
EFTA00234073

Case 9:08-cv-80811-WJZ 
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Service List 
Richard H. Willits, Esq. 
Richard H. Willits, P.A. 
2290 10th Avenue North, Suite 404 
Lake Worth, Florida 33461 
Fax: 561-588-8819 
Counsel for Plaintiff C.M.A. 
7 
Lewis
3059 Gra* AMU, Sun 340, CoCCauT GA0vE, RONDA33133 
7 cot 40 
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EXHIBIT A 
Sot 40 
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AFFIDAVIT OF JEFFREY EPSTEIN 
I, Jeffrey Epstein, being duly sworn, do depose and state as follows: 
1. 
My name is Jeffrey Epstein, and I am over 18 years of age and 
otherwise competent to testify. 
2. 
I am a citizen and resident of the U.S. Virgin Islands. 
3. 
My permanent address is in the U.S. Virgin Islands. 
FURTHER AFFIANT SAYETH NAUGHT. 
Sworn before me this /1 day of July 2008 
Notary Public 
State of Florida 
My commission expires: 
NOTARY PU BLIC-r4;E OF FLORIDA 
poimeHna"nili
i‘ EC:ITArtA
mmis
iresN:lisiA: n nuG4:
Michael R. Tein 
.01tDoie8021.0LNIsc08 
90140 
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EXHIBIT B 
10 0100 
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STATEMENT OF 
I, Sarah Kellen, state as follows, based on my personal knowledge: 
I. 
1 am over 18 years of age and otherwise competent to testify. 
2. 
I am a citizen and resident of Ncw York, New York. 
3. 
My permanent address is in Ncw York, New York. 
4. 
I have not resided in Florida at any time during the pendency of .1cmc 
Dot v. Jeffrey Epstein, Case No. 50 2008 CA 00656 XXXX MB AR, including 
ay= the removal of that case to federal court. 
PURSUANT TO 28 U.S.C. § 1746,1 STATE UNDER PENALTY OF PERJURY UNDER 'I'HE 
LAWS OF THE UNITED STATES OF AMERICA THAT THE FOREGOING IS TRUE AND 
CORRECT. 
EXECUTED ON: 
JULY .19 
, 2008. 
SARAH KELLEN 
11 0140 
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STATE COURT 
PLEADINGS 
EFTA00234079

Case 9:08-cv-8081 trcINJZ r DOCAVG01 
CtitgrgientND 
Docket 07/21/2008 
Page 13 of 40 
IN THE CIRCUIT COURT OP THE 
FIFTEENTH JUDICIAL. CIRCUIT, TN AND 
FOR PALM BEACH COUNTY, FLORIDA. 
Ill
ilaintiff, 
Va. 
JEFFREY EPSTE/N, and 
Defendants. 
CASE NO.: 
4)2008CA 0052 4 0 XXXX ME (IP 
COMPLAINT 
Plaintiff,'III. sues the Defendants, JEFFREY EPSTEIN and SARAH KELLEN, and alleges: 
t. 
This is an action for damages in excess of Fifteen Thousand Dollars ($15,000.00), 
=elusive of costs and interest. 
2. 
Al all times material hereto, the Plaintitillilwas and is a resident of Palm 
Beach County, Florida. Plaintiff is a female who is presently twenty-one years old. 
3. 
The Plaintiff is unsure of the residency of defendant JEFFREY ES PSTEIN, because 
he has residences in New York, Florida, New Mexico, and also outside of the 
continental United States. 
a
4. 
The defendant, 
was n resident of Florida. 
is 01 
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EFTA00234080

Case 9:08-cv-80811-WJZ 
r aye ...ha) 
✓amc ...”0-01'wu ic. Li° 
Document 1 
Entered on FLSD Docket 07/21/2008 
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COUNTt
5. 
Plaintiff incorporates law this count the allegations of paragraphs I through 3. 
6. 
On numerous occasions while the Plaintiff was a minor, beginning when she was 
fourteen, the defendant, EFFREY E1'STEYN intentionally induced and/or seduced 
the Plaintiff into performing various acts of lewd and lascivious conduct and/or 
sexual performances in his presence. These acts all took place al the mansion owned 
by the defendant JEFFREY EPSTEIN which was located in Palm Beach, Florida. 
'7. 
On numerous occasions while the Plaintiff was a minor, the defendant, JEFFREY 
EPSTEIN performed various acts of lewd and lascivious conduct in the presence of 
the Plaintiff These acts all took place at the mansion owned by the defendant 
JEFFREY EPSTEIN which was located in Palm Beach, Florida. 
8. 
On numerous occasions while the Plaintiff was a minor, the defendant, JEFFREY 
EPSTEIN touched the Plaintiff's breasts and gen Rifle, These acts alt took place at the 
mansion owned by the defendant JEFFREY EPSTEIN which was located in Palm 
Beach, Florida 
9. 
As a result, the Plaintiff suffered mental anguish, mental pain and suffering, psychic 
trauma, and a loss of the capacity for the enjoyment of life. 
WHEREFORE, THE PLAINTIFF DEMANDS JUDGMENT FOR DAMAGES AGAINST 
JEFFREY EPSTEI N, IN AN AMOUNT IN EXCESS OF FIFTEEN THOUSAND DOLLARS, 
EXCLUSIVE OF COSTS AND INTEREST, AND FUR'FII ER DEMANDS TRIAL BY JURY. 
COV.NT n 
10. 
Plaintiff incorporates into this count the allegations of paragraphs I through 4, and 
paragraphs 6 through 9, 
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Case 9:08-cv-80811 
IDOCurifeltlif 11151 EReeeleenttli_°&IDO'Cket 07/21/2008 
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I I, 
For each and every occurrence of sexual abuse of the Plaintiff while she was a minor 
for which JEFFREY EPSTEIN was responsible, he was aided, assisted, and/or 
abetted to 
o lived at the Palm Beach mansion of JEFFREY 
EPSTEIN. Said acts included, but were not limited to, the following: 
a. 
She often called the Plaintiff, when the Plaintiff was a minor, to arrange for 
the Plaintiff to come to the Palm Beach mansion o 'JEFFREY EPSTEIN, for 
the ostensible purpose of providing "massages" to JEFFREY EPSTEIN, 
when she knew or should have known that Plaintiff had no credentials to 
provide massage therapy. 
b. 
She observed the Plaintiff being brought to the. Palm Beach mansion of 
JEFFREYEPSTEIN, when the Plaintiff was a minor, and sometimes escorted 
the Plaintiff to a room in that mansion where JEFFREY EPSTEIN was 
waiting, for the ostensible purpose of providing "massages" to JEFFREY 
EPSTEIN, when she knew or should have known that Plaintiff had no 
credentials to provide massage therapy. 
c. 
She sometimes paid the Plaintiff for the "sessions" with JEFFREY EPSTEIN. 
d. 
She made telephone calls to the Plaintiff, when the Plaintiff was a minor, to 
arrange for gifts to be sent to the 
e 
She took photographs of the Plaintiff, when the Plaintiff was a minor, which 
depicted the Plaintiff in the nude. She told the Plaintiff that the pictures were 
at the request of JEFFREY EPSTEIN, and paid the Plaintiff for posing for the 
photographs. 
12. 
As it result, the Plaintiff suffered mental anguish, mental pain and suffering, psychic 
trauma, and a loss of the capacity for the enjoyment of life. 
WHEREFORE, THE PLAINTIFF DEMANDS JUDGMENT FOR DAMAGES AGAINST 
SARAH KELLEN, IN AN AMOUNT IN EXCESS OF FIFTEEN THOUSAND DOLLARS, 
EXCLUSIVE OF COSTS AND INTEREST AND FURTHER DEMANDS TRIAL BY JURY. 
RICIIARD H. WILLITS, P.A. 
2290 le Avenue North, Suite 404 
Lake Worth, FL 33461 
Telephone: (569.5,8 -7,0 
FAX: (561) 58,8, 
By: 
• 
RICHARD H. WILLJTS 
Florida Bar No.: 139888 
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IS 01 
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EFTA00234083

Case 9:08-cv-80811-Vybig 
Eb2,PUMPAtis/51 Erttliske6f20ocatilii9 Docket 07/21 /2008 
Page 17 of 40 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN AND 
FOR PALM BEACH COUNTY, FLORIDA 
CIVIL DIVISION 
c,;(? 486A00524u XXXX Mb AC 
JUDGE: 
C.M.A., 
Plaintiff, 
VS. 
JEFFREY EPSTEIN, and SARAH KELLEN, 
Defendants. 
II. TYPE OF CASE (Place an X in one box only. If the ease fits more than one type of case, 
select the most definitive.) 
DOMESTIC RELATIONS 
() Simplified dissolution 
( ) Dissolution 
() Support -IV-D 
( ) Support - Non IV-D 
( ) URESA -IV-D 
( ) URESA-Non IV-D 
( ) Domestic Violence 
( ) Other Domestic Relations 
TORTS 
OTHER C1VTI; 
( ) Professional Malpractice 
( ) Contracts 
( ) Products Liability 
( ) Condominium 
( ) Auto Negligence 
( ) lteal Property/ 
() Other Negligence 
Mortgage 
Foreclosure 
( ) Eminent 
Domain 
54 Other 
It Is J 
Trial Demanded in Complaint? 
i j YES 
( ) NO 
DATE:  ;Z-0.---0 51-
RICHARD H. WILLITS, P.A. 
2290 le l Avenue North, Suite 404 
Lake Worth, F1, 3 3 461 
Attorney for Plaintiff 
561.582-7 
RICHARD H. WILLITS 
Florida Bar U: 139888 
17 0140 
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EFTA00234085

Case 9:08-ov-80811 -vvaa Doeumenbeimi EnterredZificPESINThoket 07/21/2008 
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IN 
THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL, C IRCU , IN AND 
FOR PALM 13EACH COUNTY, FLORIDA. 
CASE NO.: 
Plaintiff, 
vs. 
JEFFREY EPSTEIN, a 
Defendants. 
2008 CA 005240 XXXX MBO 
SUMMONS 
1O DEFENDANT: 
JEFFREY EPSTEIN 
358 El Brillo Way 
Palm Beach, FL 33480 
nr 
9 east 71" Street 
New York, NY 10021 
IMPORTANT 
A lawsuit has been filed against you. You have 20 calendar days after this summons is served on 
you to file a written response to the attached complaint/petition with the Clerk of this Court. A 
phone call will not protect you. Your written response, including the case number given above and 
the names of the parties, must be filed if you want the Court to hear your side of the case. If you do 
not file your response on time, you may lose the case, and your wages, money, and property may 
thereafter betaken without further warning from the Court. There arc other legal requirements. You 
may want to call an attorney right away. If you do not know an attorney, you may cull an attorney 
referral service or a legal aid office (listed in the phone hook). 
If you choose to file a written response yourself, at the same time you file your written response to 
the Coun you must also mail or take a copy of your written msponse to the "Plaintifl/Plaintin 
Attorney" named below. 
RICHARD H. WILLITS, ESQ. 
Plaintiff/Plaintiffs Attorney 
2290 10°' Avenue North 
Suite 404 
Lake Worth, Florida 33461 
561-582-7600 
IS 0140 
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Case 9:08-cv-80811-Wta u Decumente1 7/51 Erdeft8riilfickgeitocl1et 07/21/2008 
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THE STATE OF FLORIDA 
TO EACH SHEIUFF OF THE STATE: You are commanded 
the complaint in this lawsuit on the ubovc-named defendant. 
DATED on 
FEB 212000 
(SEAL) 
, 2008 
to serve this sununons and a copy of 
SHARON R. BOCK 
Clerk & Comptroller 
P.O. Box 4667 
West Palm Beach, Florida 
33402-4667 
CLERK OF THE COURT 
AS DEPUTY CLER 
SHERI PAIGE 
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20 0140 
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