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cJble c-ause affidc1_vits ar1d case fiiing packages .thus. far resulting, from the Palm Beach Police Dep~rtmehfs i,nve~tig~tion ofJeffr~y E:p~te.in, Sarah Kellen and Haley Robson. Th·e submission ofthese documf;ints· are bottfi!'I re~ponse to Assistant State Attorney Lanna Belohlavek's requestfar themand to s
left the kitchen leaving^^^lone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. ^|^vas instructed to follow Kellen upstairs. I^Becalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there wa
e. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as Sarah. She was led upstairs to the main bedroom known to her as Jeff Epstein’s bedroom. Sarah arranged the massage table and covered the table with a sheet
stayed only in panties as she thd prepared the room for the massage. Epstein entered the.room wearing family.=3—=££=« eighteen oroide,, htterviews by Sarah KeUen, and massage routine when they went to work forbP ■ 1H come to Epstein’s house and were made appointments for the females to work or pstein. @ @ t0 R
ou, 18 sir. 19 THE WITNESS: You're welcome. 20 MR. GARCIA: I just have a couple here. 21 GROSS-EXAMINATION. 22 BY MR. GARCIA: 23 Q. Chief, my name is Sid Garcia, I represent 24 one of the plaintiffs in,the case. 1 think we met 25 before in another case, another deposition years Page 154 1 to get an idea — 2 A
ric examination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV -80811 ), as to time, subject m
xamination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV -80811 ), as to time, subject m
y, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his cli
ourt inspect the documents in camera in order to assess whether, in fact, continued closure is proper. 3 See, e.g.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v. Epstein, Case No. 08-80811 (S.D. Fla. July 25, 2008) (filed publicly Jan. 7, 2009). 09/12/2079 CONFIDENTIAL Agency to
See, e.g.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v. Epstein, Case No.
is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe 11, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of "emotional t
d on FLSD Docket 09/17/2009 Page 8 of 8 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 ecfObrucereinhartlaw.com 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:
brucereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq
is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of "emotional t
/2009 Spencer Kuvin Jacquie Johnson Attachment:Kellen & Trump subpoena Joint W/P Priv. 15999.16007
exner Joint-privilege 02994 06/10/2009 Bradley J. Edwards Mercedes C. Estrada Preservation of evidence Joint-privilege 07060 10/16/2009 Sid Garcia Bradley J. Edwards v. Epstein Joint-privilege 06202 07/13/2009 Richard Willits Bradley J. Edwards Scheduling various depositions regarding E
/2009 Spencer Kuvin Jacquie Johnson Attachment:Kellen & Trump subpoena Joint W/P Priv. 15999-16007
exner Joint-privilege 02994 06/10/2009 Bradley J. Edwards Mercedes C. Estrada Preservation of evidence Joint-privilege 07060 10/16/2009 Sid Garcia Bradley J. Edwards L.M. v. Epstein Joint-privilege 06202 07/13/2009 Richard Willits Bradley J. Edwards Scheduling various depositions regard
y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section
od morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE COURT: Good morning. 13 MR. WILLITS: Good morning, Your Honor. Richard 14 Willits, here on behalf of the plaintiff C
the exact same crimes and exact same evidence being reviewed by the U.S. Attorney's office when he was employed there. Specifically, he represented Kellen (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry
HE COURT: Good morning. MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane Doe. THE COURT: Good morning. MR. GARCIA: Good morning, Your Honor. Sid Garcia for Jane Doe II. THE COURT: Good morning. MR. WILLITS: Good morning, Your Honor. Richard Willits, here on behalf of the plaintiff C.M.A.. THE CO
Entities connected to both Sarah Kellen and Sid Garcia

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONLarry Visoski
PERSONNadia Marcinkova
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONJack Scarola
PERSONBruce E. Reinhart
PERSON
Prince Andrew
PERSON
Lake Worth
LOCATIONScott Rothstein
PERSON
United States
LOCATIONRichard Horace Willits
PERSON
George W. Bush
PERSON