Epstein Secrets

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

37 Jane Doe No. 2 v. Epstein Page 32 parties are implicated. See specified requests. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)lso fundamental is

rights to assert their constitutional right of privacy as guaranteed under the United States and Florida Constitutions. See generally Eisenstadt v. Baird, supra at 454-455 (The right encompasses privacy in one's sexual matters and is not limited to the marital relationship.). Ill. Conclusion Under

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

the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10

[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

the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn.

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

in the exception of §39.204. D. Third Party Privacy Rights Are Not a Basis to Deny Discovery The right to privacy discussed in Eisenstadt v. Baird, 405 U.S. 438, 454 (1972), has nothing to do with the discovery issues in this case. Eisenstadt concerns the distribution of a contraceptive devic

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

37 Jane Doe No. 2 v. Epstein Page 32 parties are implicated. See specified requests. As noted by the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)Iso fundamental is

to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino

z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants

lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "quIntil the party who has the power of avoidance elects to exercise it, the contract remains

to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino

z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants

lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "quIntil the party who has the power of avoidance elects to exercise it, the contract remains

to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino

B AD Plaintiff, VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. . 91 c. C AMENDED COMPLAINT 61

lection to affirm. Hendricks v. Stark, 99 Fla. 277, 285, 126 So. 293, 296-97 (Fla. 1930) (internal quotation omitted); see, e.g., United States v. Baird, 218 F.3d 221, 230-31 (3d Cir. 2000) (recognizing that "'[u]ntil the party who has the power of avoidance elects to exercise it, the contract remain