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be able to depose Story Cowles ("Cowles") becatise: (1) Cowles visited Epstein in jail with a "third party visitors," such as Nadia Marcinkova and Sarah Kellen, which eliminated any confidentiality; (2) Epstein may have discussed transfer of assets with Cowles; (3) Cowles may have discussed the cases agains
Exhibit I to Jane Doe's Response. Jane Doe make this untenable conclusion because of a visitor's log which indicates that Ms. Marcinkova and/or Ms. Kellen visited Mr. Epstein on some of the same days Cowles visited Mr. Epstein. A cursory review of the Exhibit I will show that Cowles often visited Mr.
ement with Epstein. See Edwards Aff. ~15. What information? Edwards cites none. c. Cowles is at Epstein's house almost every day of the week with Sarah Kellen or Epstein or both and knows of and interacted with the visitors to Epstein's house. See Edwards Aff. ~~16, 18. Has Edwards personally been
dant's actions," citing Unique Caterers, Inc. v. Rudy's Farm Co., 338 So. 2d 1067, 1071 (Fla. 1976)).
llars. The Second Amended Complaint states that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p
The Second Amended Complaint states that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p
against being required to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir
s scheme, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino
me, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino
ege against being required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9 Cir.
A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel for Defendant Sarah Kellen Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 [email protected] Counsel for Plaintiff in Related Case No. 08- 80893 Paul G
brucereinhartlaw.com Counsel for Defendant Sarah Kellen Fort Lauderdale, FL 33301 Phone: 954-522-3456
k in the chain of evidence used to prosecute him. Rudy- Glanzer v. Glanzer, 232 F.3d at 1263(the "privil
or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor girls to his homes in Palm beach, New York and St. Thomas, with the promise of money in Case 9:08-
me, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino
f minors to sexual activity,” ring hollow. See 1 Rudy-Glanzer v. Glanzer, 232 F.3d at 1263 (the “privil
A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, 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
ndant's actions," citing Unique Caterers, Inc. v. Rudy's Farm Co., 338 So. 2d 1067, 1071 (Fla. 1976))
[email protected] Counsel.for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq
brucereinhartlaw.com Counsel.for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq
against being required to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir
or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor girls to his homes in Palm beach, New York and St. Thomas, with the promise of money in EFTA00222
e, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor
ege against being required to produce or testify. Rudy-Glanzer I. Glanzer, 232 F.3d 1258, 1263 (9th Cir
t, all calendars, agendas, daily diaries, or other records of appointments, travel, meetings and the like, kept by or on behalf of Jeffrey Epstein, Sarah Kellen, Adriana Ross, Lesley Groff, and/or Nadia Marcinkova. This request includes information that is kept in physical "hard copy" and/or electronic form
, kept by or on behalf of Jeffrey Epstein, Sarah Kellen, Adriana Ross, Lesley Groff, and/or Nadia Marcink
ld 2553.79 6 W72mmwegestiMtips 41190.09 7 Sad &Rudy has 0 Aldose EIC paynato1 11 hencsotilloctPlart
l Stuart said the depanty In the odorant sentences was arse/ The USW Saws Moneys Oda dee *dyed not lo charge any ol Eolith's possible co-compmica • Sarah Kellen, Actlans Rom Lesley Groff end Nada Misrartove The agreement was negotiated In pert by New York howywegm ezignInal deem. Quemoy Geoid Larogn on Its
ment that lets Epstein and co-conspirators Sarah Kellen, Adrian& Ross, Lesley Groff and Nadia Marcinkova
SULTS BRACEWELL FREE Webinar - Wed., April 13 &GIULIANI Abc...1 Vol Lin'? • :v...p .f.seatar VIN JUST
Entities connected to both Sarah Kellen and Rudy Giuliani

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
Marc Rich
PERSON
Prince Andrew
PERSONJane Doe
PERSON
Donald Trump
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONLarry Visoski
PERSON
George W. Bush
PERSON
Virginia Giuffre
PERSONNadia Marcinkova
PERSON
United States
LOCATIONLeon Black
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Paul Cassell
PERSON
Joe Biden
PERSON
Kenneth Marra
PERSON