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

im's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue of unwelcomeness of sexual advances at

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

m's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf. Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962- 63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant Case 9:08-cv-80119-KAM Document 67 Entered

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

9:08-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 10 of 13 Doe 101 v. Epstein Page 10 usually be irrelevant. Cf Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue ofunwelcomeness of sexual advances at w

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

m's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf. Burns v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962- 63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue of unwelcomeness of sexual advances at

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

im's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf. Bums v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962- 63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant to issue of unwelcomeness of sexual advances at

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

im's sexual behavior and/or predisposition in the workplace may perhaps be relevant, non-work place conduct will usually be irrelevant. Cf. Bums v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962- 63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant EFTA00221697 Case 9:08-cv-80119-KAM Document