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man, ‘Sex Slave’ Visit Jailed Tycoon” published on August 13, 2008, reporting that “[d]uring his first month of confinement” Epstein was visited by Sarah Kellen, who allegedly escorted victims “upon their arrival at his Palm Beach waterfront home to an upstairs room, where she prepared the massage table and
sked prosecutors to approve warrants to arrest Epstein on four counts of unlawful sexual activity with a minor and to charge his personal assistanti Sarah Kellen, now 27i for her alleged role in arranging the visits. Police officials also wanted to charge Robsoni the self-described Heidi Pleiss, with
osecutors to approve warrants to arrest Epstein on four counts of unlawful sexual activity with a minor and to charge his personal assistanti Sarah Kellen, now 27i for her alleged role in arranging the visits. Police officials also wanted to charge Robsoni the self-described Heidi Pleiss, with lewd and
she wanted a sealed copy of the agreement filed in his case, and Goldberger concurred that he wanted it sealed. Belohlavek later signed off on it. The Florida Supreme Court has expressed "serious concern" and launched an all-out inquiry into sealing procedures across the state following media reports in 2006 of entire
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
e of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla
ntman, ‘Sex Slave’ Visit Jailed Tycoon” published on August 13, 2008, reporting that “[d]uring his first month of confinement” Epstein was visited by Sarah Kellen, who allegedly escorted victims “upon their arrival at his Palm Beach waterfront home to an upstairs room, where she prepared the massage table and p
onth of confinement” Epstein was visited by Sarah Kellen, who allegedly escorted victims “upon their arriv
iction And Authority. (1) The Court’s Supervision of the Grand Jury Process and Its Authority to Order Public Disclosure of the Epstein Evidence. 60. The Florida Supreme Court has noted that “in states such as Florida, where the grand jury is preserved, it is an important appendage of the court which impanels it. At the sam
[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
e of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla
U.S.C. §2422, along with pre-2006 amended text. See Exhibit B hereto - copy of Plaintiff's Second Amended Complaint. 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
ed Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p
ourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free fro
U.S.C. §2422, along with pre-2006 amended text. See Exhibit B hereto - copy of Plaintiff's Second Amended Complaint. 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
ed Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p
Fourteenth Amendment of the United States Constitution, but also under the Constitution of the State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989): The right of privacy, assured to Florida's citizens, demands that individuals be free fro
, including Plaintiff, Jane Doe, to engage in prostitution... ;" ale Amended Complaint at 133(a) (b) ". . . conspir(ind with others known (such as Sarah Kellen) and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct with minors, including Plaintiff Jane Doe, as d
. . conspir(ind with others known (such as Sarah Kellen) and unknown to travel in interstate commerce fo
n ordinary English one speaks of employing, being employed by, or associating with others, not oneself."). Both the United States Supreme Court and the Florida Supreme Court have required proof of a RICO "enterprise" that is separate and distinct from the person charged with the RICO violation. See United States v. Turk
0312010 Page 5 of 10 reveals that Plaintiff alleges with whom Defendant conspired, stating that he "conspired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these acts and to avoid police detection." See ¶ 15. Additionally, Plaintiff sufficiently alleges the identi
ired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these act
ice of Atty. Gen., Dept. of Legal Affairs v. Tenet, 420 F.Supp.2d 1288 (S.D. Fla. 2005) (citation omitted). Both the United States Supreme Court and the Florida Supreme Court have required proof of a RICO "enterprise" that is separate and distinct from the person charged with the RICO violation. See United States v. Turk
Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/or Sarah Kellen, including but not limited to witness testimony, statements made by any member of the State Attorney's Office, and instructions given by any member
rring or relating to Jeffrey Epstein and/or Sarah Kellen, including but not limited to witness testimony,
s is without a basis in Florida law. We find no evidence that the Florida courts derive an evidentiary privilege from Fla.Stat. § 905.27. Indeed, the Florida Supreme Court has noted that It)he rule of secrecy concerning matters transpiring in the grand jury room is not designed for the protection of witnesses b
Entities connected to both Sarah Kellen and the Florida Supreme Court

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONJack Scarola
PERSON
Paul Cassell
PERSON
United States
LOCATION
Prince Andrew
PERSONBruce E. Reinhart
PERSONScott Rothstein
PERSON
George W. Bush
PERSON
Lake Worth
LOCATIONMichael J. Pike
PERSONRichard Horace Willits
PERSON