Epstein Secrets

ach. Once at the mansion, Jane was introduced to Sarah Kellen, who led her up a flight of stairs to the room w

nce at the mansion, Jane was introduced to Sarah Kellen, who led her up a flight of stairs to the room w

observed in his opinion for **1498 the Court in Weaver v. Graham, 450 U.S. 24, 101 S.Ct. 960, 67 L.Ed.2d

of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COM

. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAIN

finition of criminal conduct or increasing the punishment for the crime." Lynce v. Mathis 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting Weaver v. Graham, 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)). U.S. v. Siegel 153 F.3d 1256, 1259 (11th Cir. 1998). In improperly attempting to

13 Entered on FLSD Docket 05/06/2009 Page 2 of 29 Jane Doe II v. Epstein. et al. Page 2 50 2008CA020614 MBAF, Jane Doe II v. Jeffrey Epstein, and Sarah Kellen, (hereinafter "state action"). In attempting to allege a claim under 18 U.S.C. §2255, Plaintiff improperly relies on the §2255, as amended, effect

ENDNOTES: 1 In paragraph 11 of her Complaint, Jane Doe II alleges that — "From about June, 2003 until about February, 2005, Defendants, EPSTEIN and KELLEN persuaded, induced, or EFTA00222839 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 28 of 29 Jane Doe II v. Epstein,

nition of criminal conduct or increasing the punishment for the crime." Lynce v. Mathis, 519 U.S. 433, 117 S.Ct. 891, 137 L.Ed.2d 63 (1997) (quoting Weaver v. Graham, 450 U.S. 24, 29, 101 S.Ct. 960, 67 L.Ed.2d 17 (1981)). U.S. v. Siegel,153 F.3d 1256, 1259 (11th Cir. 1998). In improperly attempting to

y is identical. 8. C.M.A. I. Epstein, 08-CV-80811-KAM: This suit was filed in state court and removed to federal court. Plaintiff sued Epstein and Sarah Kellen (Epstein's assistant). Kellen is represented by Bruce Reinhart. CMA's initial Complaint alleged sexual abuse and intentional infliction of emotiona

n, 08-CV-80811-KAM: This suit was filed in state court and removed to federal court. Plaintiff sued Epstein and Sarah Kellen (Epstein's assistant). Kellen is represented by Bruce Reinhart. CMA's initial Complaint alleged sexual abuse and intentional infliction of emotional distress. CMA later filed a

y it' by altering the definition of criminal conduct or increasing the punishment for the crime." Lynce I. Mathis 519 U.S. 433, 441 (1997) (quoting Weaver,. Graham 450 U.S. 24, 29 (1981)). United States'. Sim!, 153 F.3d 1256, 1259 (11th Cir. 1998) (emphasis added; internal alterations omitted). Even t

ot yet obtained Jane Doe #18's telephone records, we were able to identify her telephone number, and there are twenty telephone calls that appear on Sarah Kellen's phone records. All of those calls were outgoing (meaning Kellen called Jane Doe #18.) The telephone calls range in date from August 27, 2003 throu

each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's assistant—usually Kellen—in the kitchen. The assistant normally would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage

se to criminal pen- alties and (2) the elimination of de- fenses available when the crime was committed, are plainly not in issue here. It is true Weaver, id. at 29, 101 S.Ct. at 964 also speaks in terms of the challenged law "disadvantag[ing] the offender affected by it." But that characterization