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

-polar disorder are more than simple allegations of emotional distress thus placing plaintiffs mental condition at issue). See also United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)( dealing with "admissibility of other acts of sexual abuse by individuals Case 9:08-cv-80119-KAM Document 362 E

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

in her complaint, and whether she suffered injury and damages as a result of the other claimed sexual misconduct with males. See United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's se

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 Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax:

brucereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

iated with those complex medical issues. Accordingly, the Motions for Protective Order should be denied and/or stricken. See also United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(dealing with "admissibility of other acts of sexual abuse by individuals other than the defendant to explain why a vic

& 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

at same right in the instant matters. 8 Case 9:08-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

Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. Counsel tor vetwn-ciant JOU Bruce Reinhart, Esq. Counsel for Defendant Sarah Kellen Respectfully su By: ROB JR., ESQ. Florida Bar No. 2241 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN

Bruce Reinhart, Esq. Counsel for Defendant Sarah Kellen Respectfully su By: ROB JR., ESQ. Florida Ba

t in the instant matters. 8 EFTA00221762 Case 9:08-cv-80119-KAM Document 104 Entered on FLSD Docket 05/19/2009 Page 9 of 13 Page 9 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

e pain and suffering, costs of psychological care and treatment, and loss of earning capacity. ... (Interrog. 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.C. 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

d in her complaint, and whether she suffered injury and damages as a result of the other claimed sexual misconduct with males. See United States v. Bear Stops 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's sex

ional distress. EFTA00221700 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

lingly or not willingly engaged in sexual activity that has been photographed, or filmed by means of movie, dvd or videotapes. See United States v. Bear Stops, 997 F.2d 451 (8th Cir. 1993)(Defendant charged with sexual abuse of six year old boy was entitled to admission of evidence relating to victim's se