Epstein Secrets

ree computers were his private papers. As set forth in the Recarey Declaration, one of the computers was in an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act of production doctrine would not have protected Epstein from producing the computers if they had rem

n an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act o

l 's offense-specific definition an exception for crimes that are `factually related' to a charged offense. Several of these courts have interpreted Brewer. Williams , 430 U.S. 387 (1977) and Maine. Moulton , 474 U.S. 159 — both of which were decided well before McNeil — to support this view, which res

0/2008 17 08/20/2008 34 08/25/2008 18 08/27/2008 19 08/28/2008 NOTICE OF REMOVAL Filing fee $350 Receipt#: 724505, filed by Jeffrey Epstein. Sarah Kellen.(rb) (Entered: 07/21/2008) ORDER of Instructions. Signed by Judge William J. Zloch on 7/22/2008. (bc) (Entered: 07/22/2008) MOTION for Hearing Defenda

Marra on 06/15/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 06/15/2009) ORDER granting 37 Motion for Default against Defendant Kellen. Signed by Judge Kenneth A. Marra on 6/16/2009. (ir) Modified text on 6/18/2009 (wc). (Entered: 06/17/2009) NOTICE of Reliance on by Jeffrey Epstei

enneth L. Ryskamp on 2/13/2009. (sh) (Entered: 02/13/2009) NOTICE of Attorney Appearance by William Chester Brewer, Jr on behalf of Jeffrey Epstein (Brewer, William) (Entered: 03/17/2009) ANSWER and Affirmative Defenses to Complaint by Jeffrey Epstein.(Brewer. William) (Entered: 03/17/2009) MOTION for

went there, I believe I 18 had met a blond woman. And I don't think she told me 19 her name at that point, but later I learned her name was 20 Sarah. And after I started to go back to 21 Jeff Epstein's house by myself, I met a woman named 22 who i saw often there. • 23 Q. Okay. And Sarah wa

17 A. Eleven. 18 Q. Who were you living with — who were you 19 living with when you went to Duncan Middle? 20 A. My grandmother. 21 Q. Ms. Brewer? 22 A. Yes. 23 Q. (Way. Who were you living with when you went 24 to Okeeheelee? 25 A. I was in between my grandmother and my Page 148 1 Q

United States hereby opposes Epstein's motion and moves for an order to compel the appearance of witnesses and production of the requested items. 'Sarah is one of Epstein's personal assistants. -5- EFTA00179104 ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The

l's offense-specific definition an exception for crimes that are 'factually related' to a charged offense. Several of these courts have interpreted Brewer v. Williams, 430 U.S. 387 (1977) and Maine v. Moulton, 474 U.S. 159 —both of which were decided well before McNeil — to support this view, which res