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01 561-202-6360 Fax: 561-828-0983 [email protected] Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Leopold, Kuvin, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax: 561-515-2610 Counsel for Plaintiff in Related Case No. 08
lanation for why victim exhibited behavioral manifestations of sexually abused child.). 14. In further support of Defendant's motion, See Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), as it is on point to the discovery issues in this action, and the rele
hat? 16 A. I do now. 17 Q. You agree that court is a very serious 18 matter? 19 A. Yes. 20 Q. And you're here with your lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently filed a lawsuit in federal court against Jeffrey Epstein, Illillif you know t
e, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Baku v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"
hat? 16 A. I do now. 17 Q. You agree that court is a very serious 18 matter? 19 A. Yes. 20 Q. And you're here with your lawyer 21 Mr. Leopold, right? 22 A. Yes. 23 Q. And you know that Mr. Leopold recently 24 filed a lawsuit in federal court against Jeffrey Epstein, 25 seeking fif
, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Bala: v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"
Entities connected to both Leopold and Ruzzo

Jeffrey Epstein
PERSONJack Goldberger
PERSONJane Doe
PERSON
Palm Beach Gardens
LOCATION
Bradley Edwards
PERSONSpencer Kuvin
PERSONTheodore J. Leopold
PERSON
Sarah Kellen
PERSON
Lake Worth
LOCATIONRichard Horace Willits
PERSONJack Scarola
PERSON
Adam D. Horowitz
PERSON
Kenneth Marra
PERSONBruce E. Reinhart
PERSONMichael J. Pike
PERSONScott Rothstein
PERSONJack Patrick Hill
PERSON
Virginia Giuffre
PERSONMermelstein & Horowitz
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATION