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0119-KAM Document 510 Entered on FLSD Docket 03/29/2010 Page 4 of 8 RICO Case Statement" to argue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "involvement in the scheme." See DE #486 at 2. 14. As Jane Doe's RICO claim was dismissed with prejudice, any
at the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "involvement
gue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "
y Jane Doe's Motion. 18. In Perry, plaintiff sought to collect under a homeowner's insurance policy following the destruction of her home by fire. State Farm asserted an arson defense. State Farm filed a motion pursuant to 5 U.S.C. §552a(b)(l l) seeking to require the Social Security Administration to te
orking sites, and e-mails. Request No. 16. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Request No. 17. Any and all docume
communications between Jeffrey Epstein and Nada Marcinkova, including, but not limited to, letters, notes, t
nt." See generally, F.T.C. supra, at fn.4, citing United States v. Premises Located at Route 13 946 F.2d 749, 756 (11th Cir.1991) (citing Pervis v. State Farm and Cas. Co., 901 F.2d 944, 948 (11th Cir.1990)). See also S.E.C. v. Keith Group of Companies, Inc. 1998 WL 1670405 (S.D. Fla. 1998)("When a party i
irls to his mansion. Epstein's key "lieutenant" in the organization was MI who served as both his scheduler and a recruiter/procurer of the girls. Marcinkova also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse and prost
imitations and guideposts as set forth in BMW of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Liqoet Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of th
Entities connected to both Nadia Marcinkova and State Farm

Jeffrey Epstein
PERSON
Sarah Kellen
PERSON
Ghislaine Maxwell
PERSONLarry Visoski
PERSON
United States
LOCATIONJane Doe
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONJack Goldberger
PERSONLeon Black
PERSON
Marc Rich
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Alexander Acosta
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Alfredo Rodriguez
PERSON