Epstein Secrets

ach. Once at the mansion, Jane was introduced to Sarah Kellen, who led her up a flight of stairs to the room w

nce at the mansion, Jane was introduced to Sarah Kellen, who led her up a flight of stairs to the room w

ted States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil

of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COM

. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAIN

sed minimum. As explained by the Landqraf court, supra at 280, and at 1505,2 2 In Landaraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before EFTA00201268 Case 9:08-cv-80811-KAM Document 78

13 Entered on FLSD Docket 05/06/2009 Page 2 of 29 Jane Doe II v. Epstein. et al. Page 2 50 2008CA020614 MBAF, Jane Doe II v. Jeffrey Epstein, and Sarah Kellen, (hereinafter "state action"). In attempting to allege a claim under 18 U.S.C. §2255, Plaintiff improperly relies on the §2255, as amended, effect

ENDNOTES: 1 In paragraph 11 of her Complaint, Jane Doe II alleges that — "From about June, 2003 until about February, 2005, Defendants, EPSTEIN and KELLEN persuaded, induced, or EFTA00222839 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 28 of 29 Jane Doe II v. Epstein,

of the amount of actual damages a plaintiff has suffered and proven. The new 3 In Landoraf, the United States Supreme Court affirmed the judgment of the Court of Appeals and refused to apply new provisions of the Civil Rights Act of 1991 to conduct occurring before the effective date of the Act. The Court determined

st Appellant, but instead, recited numerous allegations based on double and triple hearsay directed toward filing charges against a defendant named Sarah Kellen. See A.6 (Palm Beach Police Department - Probable Cause Affidavit of J. Recarey, dated May 1, 2006). Furthermore, the Florida State Attorney express

, dated May 1, 2006). Furthermore, the Florida State Attorney expressly rejected the claims asserted in the police affidavit (which sought to charge Kellen as an accomplice to Appellant) by determining that there was not sufficient probable cause and not charging Appellant with the serious second-degre

ard looked into all of this, made their recommendation, found him to have 130 points and I see no reason to disturb that." A.96:11-13 (Pr.). While the Court of Appeals has recognized that a Board-generated case summary may constitute "reliable hearsay" upon which the Court may base a SORA risk calculation, the law

nt's name is MS we took a look at her 17 cell phone records and the majority of the times that 18 Mr. Epstein would fly into Palm Beach Mrs. ms. Kellen 19 would contact many of our underage victims either prior 20 to coming into Palm Beach, the day of, the day before, 21 even the day after, and

Court of the Virgin Islands, the United States Court of Federal Claims, the Tax Court of the United States, the Court of International Trade, and the Court of Appeals for the Armed Forces. (Added Pub.L. 91-452, Title II, § 201(a), Oct. 15. 1970, 84 Stat 926, and amended Pub.L. 95-406, § 25. Sept 30, 1978, 92 Sta