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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
not pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality.") (citation omitted); Liggett Group Inc., I Brown & Williamson Tobacco Corp. , 116 F.R.D. 205, 210 (M.D.N.C. 1986) (citations omitted) ( "For communications between an attorney and client . . . to be privileged, they must be
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
t pertinent here, the presence of third parties is sufficient to undermine the needed confidentiality.") (citation omitted); Liggett Group Inc., v. Brown & Williamson Tobacco Corp., 116 F.R.D. 205, 210 (M.D.N.C. 1986) (citations omitted) ("For communications between an attorney and client . . . to be privileged, they must be c
KMBT_C654e-20190114185410
onth, supports investigative journalism like this. CLICK TO SUBSCRIBE Several of the girls said they felt intimidated and frightened by Epstein and Sarah Kellen, the millionaire’s assistant and alleged scheduler of massages, who warned them not to talk to police, according to the police report. Dersho
Page: HOUSE_OVERSIGHT_016438 →supports investigative journalism like this. CLICK TO SUBSCRIBE Several of the girls said they felt intimidated and frightened by Epstein and Sarah Kellen, the millionaire’s assistant and alleged scheduler of massages, who warned them not to talk to police, according to the police report. Dershowitz, i
Page: HOUSE_OVERSIGHT_016439 →formation about the case. Contacted for this story, Reinhart, in an email, said he never represented Epstein — only Epstein’s pilots; his scheduler, Sarah Kellen; and Nadia Marcinkova, described by some victims as Epstein’s sex slave. Reinhart also pointed out that a complaint filed against him by victims’ law
Page: HOUSE_OVERSIGHT_016451 →Entities connected to both Sarah Kellen and Brown & Williamson Tobacco Corp.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSONBruce E. Reinhart
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Virginia Giuffre
PERSON
A. Marie Villafana
PERSON
Bill Clinton
PERSON
Alexander Acosta
PERSON
Donald Trump
PERSON
Scarlett Johansson
PERSONFBI
ORGANIZATION
Alfredo Rodriguez
PERSON