Epstein Secrets

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

668, 669 (I Ith Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accor

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

Docket 02/04/2010 Page 2 of 14 3 Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is acco

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 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 [email protected] Counsel for Plaintiff in Related Case No. 08- 80893 Paul G

brucereinhartlaw.com Counsel for Defendant Sarah Kellen Fort Lauderdale, FL 33301 Phone: 954-522-3456

e is no question that an individual is entitled to invoke the privilege against self-incrimination during a civil proceeding. See, M·, Lefkowitz v. Turley, 414 U.S. 70, 77 (1973) (explaining that the Fifth Amendment permits an individual "not to answer official questions put to him in any ... proceedin

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 Case 9:08-

me, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino

n FLSD Docket 03/04/2010 Page 2 of 10 - 3 in future criminal proceedings.” Edwin v. Price, 778 F.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accorded “liberal construction in favor of the right it was intended to secure,” Hoffman v. United Stat

[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

d 668, 669 (11th Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accor

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

where the answers might incriminate him in future criminal proceedings." 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 ava

/31/2009 Page 15 of 20 alleges and the Magistrate Judge's Order acknowledges allegations of a scheme where 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

re Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino

l, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (I Ith Cir. 1985), citing Lefkowitz v. Turley. 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction in favor of the right it was intended to secure," Hoffman v. United State

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

.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is acco

[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

d 668, 669 (11th Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). Thus, information is pr

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

.2d 668, 669 (11th Cir. 1985)(citing Lefkowitz v. Turley, 414 U.S. 70, 77 (1973)). The privilege is accor