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 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected] Co-counsel.for Plaintiff Jane Doe Isidro M. Garcia, Esq. Garcia L

brucereinhaiilaw.com Counsel.for Defendant Sarah Kellen Salt Lake City, UT 84112 801-585-5202 801-585-

l Women's Center to Comply with Subpoena Duces Tecum (DE 421) and Defendant, EPSTEIN'S, Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum as to Jane Doe no. 4, and state: I. On December 2, 2009, Epstein filed a Motion to Compel Presidential Women's Center to Comply with Subpoena Duce

AL WOMEN'S CENTER TO COMPLY WITH SUBPOENA DUCES TECUM (DE 431) AND DEFENDANT EPSTEIN'S MOTION TO COMPEL PRESIDENTIAL WOMEN'S CENTER TO COMPLY WITH SUBPOENA DUCES TECUM AS TO JANE FOE NO.4 (DE 443) Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his undersigned attorneys, hereby files his Notice

[email protected] Counsel for Defendant Sarah Kellen 4 Fort Lauderdale, FL 33301 Phone: 954-524-282

brucereinhartlaw.com Counsel for Defendant Sarah Kellen 4 Fort Lauderdale, FL 33301 Phone: 954-524-282

ompel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe No. 4, and states: I. On Dec

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 08-80893 Paul G. Cassell, Esq. ProHac Vice 332 South 1400 E, Room 101 Salt Lake City, UT 84112 801-585-5202 801-585-6833 Fax [email protected]

brucereinhartlaw.com Counsel for Defendant Sarah Kellen 08-80893 Paul G. Cassell, Esq. ProHac Vice 33

l Women's Center to Comply with Subpoena Duces Tecum (DE 421) and Defendant, EPSTEIN'S, Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum as to Jane Doe no. 4, and state: I. On December 2, 2009, Epstein filed a Motion to Compel Presidential Women's Center to Comply with Subpoena Duce

three computers were his private papers. As set forth in the Recarey Affidavit, one of the computers was in an area that appears to be the office of Sarah Kellen and another was in the pool cabana. (Recarey Aff. at ¶ _.) Video surveillance also showed Sarah Kellen working on that computer. ( Id. at ¶ _.) it

n an area that appears to be the office of Sarah Kellen and another was in the pool cabana. (Recarey Aff.

by himself.") (quoting Fisher I United States , 425 U.S. 391, 409-10 (1976); and citing United States I Doe , 465 U.S. 605 (1984)); In ?V Grand Jury Subpoena Duces Tecum , 1 F.3d 87, 90 (2d Cir. 1993) ("While we have previously left undecided the question of whether the Fifth Amendment protects the contents of priva

0/2008 17 08/20/2008 34 08/25/2008 18 08/27/2008 19 08/28/2008 NOTICE OF REMOVAL Filing fee $350 Receipt#: 724505, filed by Jeffrey Epstein. Sarah Kellen.(rb) (Entered: 07/21/2008) ORDER of Instructions. Signed by Judge William J. Zloch on 7/22/2008. (bc) (Entered: 07/22/2008) MOTION for Hearing Defenda

Marra on 06/15/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 06/15/2009) ORDER granting 37 Motion for Default against Defendant Kellen. Signed by Judge Kenneth A. Marra on 6/16/2009. (ir) Modified text on 6/18/2009 (wc). (Entered: 06/17/2009) NOTICE of Reliance on by Jeffrey Epstei

orowitz, Adam) (Entered: 12/21/2009) 12/29/2009 443 RESPONSE/REPLY to 442 Response to Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum and Incorporated Motion to Compel Presidential Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe 4 by Jeffrey Epstein. (Attachme

ZORRO RANCH RD PAUL VISOSKI. STANLEY, NM 87056-9783 LAWRENCE JR VISOK. LAWRENCE P 1635 SW SILVER PINE WAY APT Fl PALM CITY, FL 34990-4732 4: KELLEN, SARAH L 27 HIGH TECH BLVD 241-53-XXXX 5/1979 BONK, SARAH L THOMASVILLE, NC 27360- VICKERS, SARAH 5560 KENSINGTON, SARAH BINK. SARAH 92 GREE

documents that "might allow them to protect those very rights." (Id. at 15). By way of illustration, Petitioners offer the case of In re Grand Jury Subpoena Duces Tecum, where the Eighth Circuit broadly stated that "the general duty of public service calls upon government employees and agencies to favor disclosure