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

ea 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 & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). . .. Cou1is have long held that ' [ w]hile the standard of relevancy [in discovery] is a liberal one, it is

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

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

is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Indeed the

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.

ea 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 & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Indeed the 2000 Amendment to Rule 26 has effectively limited the scope of discoverable information to those

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

udge 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 Tobacco, 959 F.2d 1566, 1570 (I Ith Cir. 1992) .... Courts have long held that '[w]hile the standard of relevancy [in discovery] is a liberal one, it is not

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 EFTA00222

e, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor

uestion, Plaintiffs' Motion as it relates to this request is denied. While the scope of discovery is broad, it is not without limits. Washington 1. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992). Indeed the 2000 Amendment to Rule 26 has effectively limited the scope of discoverable information to those