Epstein Secrets

9-KAM Document 402 Entered on FLSD Docket 11/09/2009 Page 5 of 26 561 -202-6360 Fax: 561-828-0983 ~brucereinhartlaw.com Counsel/or Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T, Kuvin, Esq, Leopold, Kuvin, P.A. 2925 PGA Blvd,, Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax:

effrey 15 to which he has no knowledge, 15 Epstein's friend, can you name anybody? 16 So yes, I'm instructing him not to answer, 16 A. Nadia, Sarah; Just people that we see 17 MR. CRIHON: Let me add in rny part, Is that I 17 routinely on the airplane. 18 think•· you're certainly not only ca

~brucereinhartlaw.com Counsel/or Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T, Kuvin, Esq

d beyond September of 2005. Therefore whatever information Mr. Zinoview may have, postdates that time. 5. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

nowledge of, Mr. Epstein prior to his employment with Mr. Goldberger. See Exhibit C. 5. Mr. Cowles did not know, nor did he have any knowledge of, Sarah Kellen prior to his employment with Mr. Goldberger. See Exhibit C. 6; While Mr. Cowles and Ms. Kellen have dated and continue to date, they specifically

d not know, nor did he have any knowledge of, Sarah Kellen prior to his employment with Mr. Goldberger. See Exhibit C. 6; While Mr. Cowles and Ms. Kellen have dated and continue to date, they specifically have not and do not discuss the facts of the cases against her and Mr. Epstein. See Exhibit C.

r conversations with hei· supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

Case 9:08-cv-80119-KAM Document 510 Entered on FLSD Docket 03/29/2010 Page 4 of 8 RICO Case Statement" to argue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "involvement in the scheme." See DE #486 at 2. 14. As Jane Doe's RICO claim was dismissed

ment" to argue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because

opriate and irrelevant and not reasonably calculated to lead to the discovery of admissible evidence." 24. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order,2 "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson