Epstein Secrets

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

in of a crime. (DE 242, p. 18) United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). 2 Case 9:

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

enuinely threatening questions.” United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). In ruling as

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

witness, (the trial court) can conclude that the witness could 'legitimately refuse to answer essentially all relevant questions." United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. Fla. 1980)); United States v. Tsui, 646 F.2d 365, 367-68 (9th Cir. 1981). This exception is narrow and is applicable w

/31/2009 Page 15 of 20 alleges and the Magistrate Judge's Order acknowledges allegations of a scheme where 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 exchange

re Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino

y threatening questions" which could furnish a link in the chain of evidence needed to convict Epstein of a crime. (DE 242, p.18) United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). b. The District Court Judge Court Should Reverse or Modify The Magistrate Judge's Order (DE 242) Relative to I

that Plaintiff’s interrogatories requesting that he identify employees may lead to evidence tending to incriminate him because one of his employees, Sarah Kellen, is identified in the Complaint. (Defendant Memorandum (DE 56), p. 18). This does not, however, support a blanket refusal to answer on Fifth Amen

criminate him because one of his employees, Sarah Kellen, is identified in the Complaint. (Defendant Mem

vilege where the trial court determines it to be legitimate based on the court’s knowledge of the case and the expected testimony. United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980); United States v. Tsui, 646 F.2d 365 (9th Cir. 1981). This is not a case, however, where this narrow exception

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

enuinely threatening questions.” United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). The danger Ep

[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

tein of a crime. (DE 242, p.18) United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). 5. As detai

criminate him because one of his employees, Sarah Kellen, is identified in the Complaint. (Defendant Memo

that Plaintiff's interrogatories requesting that he identify employees may lead to evidence tending to incriminate him because one of his employees, Sarah Kellen, is identified in the Complaint. (Defendant Memorandum (DE 56), p. 18). This does not, however, support a blanket refusal to answer on Fifth Amendm

rivilege where the trial court determines it to be legitimate based on the court's knowledge of the case and the expected testimony. United States,. Goodwin 625 F.2d 693, 701 (5th Cir. 1980); United States'. Tsui, 646 F.2d 365 (9th Cir. 1981). This is not a case, however, where this narrow exception sho

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

witness, (the trial court) can conclude that the witness could 'legitimately refuse to answer essentially all relevant questions." United States v. Goodwin 625 F.2d 693, 701 (5th Cir. Fla. 1980)); United States v. Tsui, 646 F.2d 365, 367-68 (9th Cir. 1981). This exception is narrow and is applicable wh

egations, to wit, a scheme and plan of sexual misconduct carried out at Epstein's various residences, and that at least one of Epstein's employees, Sarah Kellen, is alleged to have aided Epstein in his alleged sexual exploitation, then it is entirely reasonable for Epstein to assert that forcing him to testi

that at least one of Epstein's employees, Sarah Kellen, is alleged to have aided Epstein in his alleged

vilege raised as to these interrogatories valid, and asserted by Epstein only with reference to "genuinely threatening questions." United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. 1980). The danger Epstein faces by being forced to testify in this instance is "substantial and real, and not merely t