Epstein Secrets

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

privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making

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 Case 9:08-

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

ified and to require him to answer if it clearly appears to the court that the witness asserting the privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making this Case 9:08-cv-80119-KAM Document 480 Entered on FLSD Docket 03/04/2010 Page 3 of 10 4 de

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

privilege is mistaken as to its validity.” In re Morganroth, 718 F.2d 161, 166-67 (6th Cir. 1983). In making

ree computers were his private papers. As set forth in the Recarey Declaration, one of the computers was in an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act of production doctrine would not have protected Epstein from producing the computers if they had rem

n an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act o

, 341 U.S. at 53; United States I Melchor Moreno , 536 F.2d 1042, 1049 (5th Cir. 1976); United States I Rue , 819 F.2d 1488 (8th Cir. 1987); In re Morganroth , 718 F.2d 161, 167 (6th Cir. 1983)). See also United States I Argomaniz , 925 F.2d 1349, 1355 (11th Cir. 1991) (court must review assertions of Fif

United States hereby opposes Epstein's motion and moves for an order to compel the appearance of witnesses and production of the requested items. 'Sarah is one of Epstein's personal assistants. -5- EFTA00179104 ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The

n, 341 U.S. at 53; United States v. Melchor Moreno, 536 F.2d 1042, 1049 (5th Cir. 1976); United States v. Rue, 819 F.2d 1488 (8th Cir. 1987); In re Morganroth, 718 F.2d 161, 167 (6th Cir. 1983)). See also United States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991) (court must review assertions of Fif