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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
dings." Edwin v. Price, 778 F.2d 668, 669 (11 th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's
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
ceedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citing Lefkowitz v. Turlev 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's
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,
ceedings." Edwin v. Price 778 F.2d 668, 669 (11i' Cir. 1985), citing Lefkowitz v. Turley 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner 532 U.S. 17, 21, 121 S.Q. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's "b
! !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
eedings." Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985), citin Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available to those who claim innocence. One of the Fifth Amendment's
,REBECCA VAN DER GRIFT,PAUL J ASCHE,SARAH P KAHLE,KENT HOUSE,NADINE BRIG
BEACH BEESON,JOHN KRAUSS,K W RINKER,JOHN J DERRIN,MICHELLE SALTZMAN,SHI
Entities connected to both Sarah Kellen and Reiner

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
United States
LOCATIONMichael J. Pike
PERSONScott Rothstein
PERSON
George W. Bush
PERSON
Adam D. Horowitz
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSON
Salt Lake City
LOCATIONLeon Black
PERSONIsidro Manuel Garcia
PERSON