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or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, 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 f
me, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino
the likely benefit. Id. The party resisting discovery has a heavy burden of showing why the requested discovery should not be permitted. Rossbach v. Rundle, 128 F. Supp. 2d 1348, 1354 (S.D. Fla. 2000) (“The onus is on the party resisting discovery to demonstrate specifically how the objected- to informat
A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Leopold-Kuvin, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax:
brucereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq
. See also Fed.R.Civ.Pro. 26; Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 352 (1978); Dunbar v. U.S., 502 F.2d 206 (5th Cir. 1974); Rossbach v. Rundle, 128 F.Supp.2d 1348, 1354 (S.D. Fla. 200); Fed.R.Civ.Pro 33(b)(4)(Plaintiffs must show that the requests are unreasonable or burdensome, which they
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
ed discovery should not be permitted. Rossbach v. Rundle, 128 F.Supp.2d 1348, 1354 (S.D. Fla. 2000) (“The
Microsoft Word - Epstein combined articles.doc
six girls ages 14-16 for massages and sex at his home. She said they were paid $200 per session. Cops also allege that Epstein's personal assistant, Sarah Kellen, who hasn't been charged, set up the liaisons and put fresh sheets on the massage table and supplied massage oils. Police searched through Epstein's
Page: HOUSE_OVERSIGHT_021780 →o allege that Epstein's personal assistant, Sarah Kellen, who hasn't been charged, set up the liaisons and
Page: HOUSE_OVERSIGHT_021780 →the past 13 years that he ought to get off the case. "It looks like a departure from professionalism," Miami-Dade State Attorney Katherine Fernandez Rundle said of Reiter's letter. Following Epstein's indictment, Reiter referred the case to the FBI to determine whether the super-rich, super-connected de
Page: HOUSE_OVERSIGHT_021782 →Entities connected to both Sarah Kellen and Rundle

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
United States
LOCATIONLeon Black
PERSON
Bill Clinton
PERSONMaria Farmer
PERSON
Donald Trump
PERSON
John F. Kennedy
PERSON
Condoleezza Rice
PERSON
Joe Biden
PERSONFBI
ORGANIZATION
Department of Justice
ORGANIZATION
Woody Allen
PERSONHaley Robson
PERSON