Epstein Secrets

[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

d 1188, 1192 (Fla. 4th DCA 1985); and Doherty v. John Doe No. 22, 957 So.2d 1267 (4th DCA 2007). A reading

U.S.C. §2422, along with pre-2006 amended text. See Exhibit B hereto - copy of Plaintiff's Second Amended Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's plan and scheme (which) reflected a particular pattern and method" in the alleged recruiting of girl

ed Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p

dnote 2 for full text of §39.204, Fla. Stat.2 (¶'s Motion, p. 8-9). See Carson v. Jackson, 466 So.2d 1188, 1192 (Fla. 4th DCA 1985); and Doherty v. John Doe No. 22, 957 So.2d 1267 (4th DCA 2007). A reading of these cases establishes that §39.204 does not provide Plaintiff with a carte blanche access to D

Did you ever talk with her about a rumor that you had heard that a girl had intercourse with Jeffrey? A One day I was talking on the phone with Sarah and I addressed her with it, asking her OFFICIAL prDnI)PTWr evouTCE, LLC EFTA00085403 1 2 3 4 5 6 7 8 9 10 1 1 12 13 14 15 16 1

she went to Mr. Epstein's residence, that took her there the first time, that when she went upstairs she was paid $200 when she first got there by Sara Kellin. Then she goes upstairs, and Mr. Epstein comes in, he disrobes, puts on a towel, lays down on the massage table and she begins to massage him. She

a sexual activity for which a person can be charged with an offense? A Yes. Q How many telephone calls have you been able to document between John Doe Number 14 and A We have approximately 70 phone calls between and Jane Doe Number 14. Q And what about with A Approximately seven. Q And bec

ss - Shared Government Illegal Surveillance Refer to attached - Hand written note I enquired at the Interflora Florists, owner Kandice - Flowers on Ellen, Floral Trends, Port Pirie Kandice stated that she could not find the file on their computer base file or payment details of the sender and that s

were released. Two sets of additional sealed documents will be analyzed by a federal judge to determine whether they should also be made public. A "John Doe" asked the judge on September 3 to permanently keep the documents secret, claiming "unproven allegations of impropriety" could damage his reputatio

861 Thm P-007785 File folder entitled "EPSTEIN/KELLEN CELL PHONE RECORDS" containing documents receiv

y's Conduct is at Issue — If the attorney's conduct is a central issue in the case, the work-production protection does not apply. See, e.g., In re John Doe, 662 F.2d 1073, 1080 (4th Cir. 1981); Charlotte Moto• Speedway, Inc. v. International Ins. Co., 125 F.R.D. 127, 130 (M.D.N.C. 1989). E Rule 6(c) —