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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
uired to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privile
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
g required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9 Cir. 2000). Accordingly,
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
d testimony and information that may, directly or indirectly, furnish Plaintiff a clue or link in the chain of evidence used to prosecute him. Rudy- Glanzer v. Glanzer, 232 F.3d at 1263(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution
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
elate solely to Defendant’s net worth and are “unrelated to Defendant’s inducement of minors to sexual activity,” ring hollow. See 1 Rudy-Glanzer v. Glanzer, 232 F.3d at 1263 (the “privilege” against self-incrimination does Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 7
[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
quired to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privil
Entities connected to both Sarah Kellen and Glanzer

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONJack Scarola
PERSON
Alan Dershowitz
PERSONBruce E. Reinhart
PERSON
Lake Worth
LOCATION
United States
LOCATIONRichard Horace Willits
PERSONMichael J. Pike
PERSONScott Rothstein
PERSONJack Patrick Hill
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSON
Adam D. Horowitz
PERSON
George W. Bush
PERSON
Salt Lake City
LOCATION