Epstein Secrets

.. (Interrog. No. 10). Case 9:08-cv-80119-KAM Document 362 Entered on FLSD Docket 10/21/2009 Page 8 of 11 12. Jane Doe 2 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

8 of 11 12. Jane Doe 2 also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p

lanation for why victim exhibited behavioral manifestations of sexually abused child.). 14. In further support of Defendant's motion, See Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), as it is on point to the discovery issues in this action, and the rele

e pain and suffering, costs of psychological care and treatment, and loss of earning capacity .... (lnterrog. No. 10). 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

on of emotional distress. Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 11 of 12 Doe 2 v. Epstein Page No. 11 Kellen, Case No. 502008CA025129 MB Al, 15th Judicial Circuit, In and For Palm Beach County, State of Florida, which granted Defendant's motion to compel th

anation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 {Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the discovery iss

e pain and suffering, costs of psychological care and treatment, and loss of earning capacity .... (lnterrog. No. 10). 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

ff. See Composite Exhibits B and C hereto. Composite Exhibit B are the Orders, dated February 23, 2009, entered in the case of A.G. v. Epstein, and Kellen, Case No. 502008CA025129 MB Al, 15th Judicial Circuit, In and For Palm Beach County, State of Florida, which granted Defendant's motion to compel th

anation for why victim exhibited behavioral manifestations of sexually abused child.). In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as Exhibit A as it is on point to the discovery iss

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 exchange f

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

ces may be held to prevent mere discovery, is not applicable in this instance, where Plaintiff has placed her past sexual history at issue. Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5 DCA 1997), rev. th denied,719 So.2d 286 (Fla. 1998)(allowing discovery of plaintiff’s employment history which included pros

& 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 By: ROB,-,1--.,.D--+:--,,.l'f--_+1---- Florida Bar No. 2241 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURM

brucereinhartlaw.com Counsel for Defendant Sarah Kellen By: ROB,-,1--.,.D--+:--,,.l'f--_+1---- Florida

08-cv-80119-KAM Document 104 Entered on FLSD Docket 05/19/2009 Page 9 of 13 Page9 States v. Bear Stops. 997 F.2d 451 (8th Cir. 1993); Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998). The information sought in 4(e) is relevant and discoverable even if no

THERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants. NOTICE OF REMOVAL July 18, 2008 STEVEN M. LARIMORF CLERK D.S. DIST. CT. S.O. OF FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441

stroy diversity jurisdiction, and to prevent any application of 18 § 3509(k), a mandatory stay provision applicable in federal court 2 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section

e, prostitutes who sued a house of prostitution (as an "enterprise") for inflicting systematic and repetitive abuse on them, over time. See Baku v. Ruzzo, 703 So. 2d 1076, 1077 (Fla. 5th DCA 1997) (offering an example of a civil RICO claim against the operators of an alleged "house of prostitution,"