Epstein Secrets

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. Ricci-Leopold, 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

tates, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6 th Ed.). See also Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth A

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

Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 6 of 37 Jane Doe No. 2 v. Epstein Page6 circumstances."); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth

stein Page 11 Bruce Reinhart, Esq. Bruce E. Reinhart, P.A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 Counsel for Plainti

Palm Beach, FL 33401 Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

States, 425 U.S. 391 (1976)• McCormick on Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6th Ed.). See also Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964Xthe Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth Am

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

Case 9:08-cv-80119-KAM Document 63 Entered on FLSD Docket 03/25/2009 Page 6 of 37 Jane Doe No. 2 v. Epstein Page 6 circumstances."). Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth

No. 2 v. Epstein Page 15 Request No. 15. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes,

the Fifth Amendment's "basic functions ... is to protect innocent men ... `who otherwise might be ensnared by ambiguous circumstances."); Mallov v. Hogan, 84 S.Ct. 1489, 1495 (1964Xthe Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the Fourteenth A

Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl u

would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photograph

attempted to put his hands down plaintiff's dress, and that there was an actual and intentional touching, sufficient to state a claim for battery); Hogan'. Tavzel, 660 So.2d 350 (Fla. 5th DCA 1995) (tortfeasor may be liable for battery for infecting another with a sexually transmitted disease); see a

! !24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRA/JOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, Defendant. Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedinas

. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, Defendant. Jeffrey Epstein's Motio

the Fifth Amendment's "basic functions ... is to protect innocent men ... 'who otherwise might be ensnared by ambiguous circumstances."); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process 7 EFTA00234827 owee9:A

) (FBI) <[email protected]>; Baker, Jennifer (DL) (FBI) <[email protected]>; Balias, Panagiotis (CD) (FBI) <[email protected]>; Bamberger, Ellen (NK) (FBI) <[email protected]>; Barrera, Cassi (DL) (FBI) <[email protected]>; Barstow, Callie (LA) (FBI) <[email protected]>; Bass,

I) <[email protected]>; 'CAMPBELL, STEPHEN E. (NO) (FBI' <[email protected]>; Carey, Kaitlan (NO) (FBI) <[email protected]>; Carney, Sarah M. (SU) (FBI) <[email protected]>: Carollo, Leonard (DN) (FBI) <[email protected]>; Cartledge, Chandra L. (CD) (FBI) <[email protected]

uad <HO-C11- [email protected]>; HO Cl2 SQUAD <[email protected]>; HO CI3 SQUAD <HO-CB- [email protected]>; HO 16 SQUAD <[email protected]>; Hogan, Jesse Wade (AN) (FBI) <[email protected]>; Holmes, Joseph Lawrence (DI) (FBI) <[email protected]>; Hopfer, Jason Scott (BS) (FBI) <JSHOPFER

discovered playwrights. I do not know whether it was my fate, my good luck, or my nose for finding good people to work with, but I was blessed that Ellen took me under her wing. After touring with her and a small theater troupe through Europe, Ellen insisted that I visit the Odin Theater, a small exp

Hogan, one of the greatest early American pro- fessional golf champions. The book was Ben Hogatt's Five Lessons: The Modern Fundamentals of Golf.21 Hogan wrote, "If you want to hit a good drive, if you are right-handed, just keep your awareness on the little finger of your left hand as you swing the