Epstein Secrets

[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

inst Defendant, Jeffrey Epstein". Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Accordingly, the privileges

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

ed claims in Counts I - Sexual Battery and Counts II - Intentional Infliction of Emotional Distress are also controlled by state law. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Accordingly, the privileges recognized under state law apply to this action under Rule 501. See, for example, 1550 Brickell A

of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION Defendant, JEFFREY EPSTEIN, ("EPSTEIN

Count I of Plaintiffs Complaint for failure to state a cause of action. Rule 12(b)(6), Fed.R.Civ.P. (2008). Count II is directed only to Defendant KELLEN, who has not yet been served. In support of dismissal, Defendant states: Plaintiff, CMA, attempts to assert a cause of action against EPSTEIN in Cou

1965). As jurisdiction is based on diversity, it is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. v. Tompkins 58 S.Ct. 817 (1938). On its face, Count I completely fails to allege either the necessary elements of any cause of action or the necessary underlyi

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

ed claims in Counts I - Sexual Battery and Counts II - Intentional Infliction of Emotional Distress are also controlled by state law. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Accordingly, the privileges recognized under state law apply to this action under Rule 501. See, for example, 1550 Brickell A

Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl u

would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photograph

tate a claim upon which relief can be granted. It is well settled that this Court is to apply Florida substantive law in this action. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Pursuant to Florida law, although the term "assault and battery" is most commonly referred to as if it were a legal unit, or a

) (FBI) <[email protected]>; Baker, Jennifer (DL) (FBI) <[email protected]>; Balias, Panagiotis (CD) (FBI) <[email protected]>; Bamberger, Ellen (NK) (FBI) <[email protected]>; Barrera, Cassi (DL) (FBI) <[email protected]>; Barstow, Callie (LA) (FBI) <[email protected]>; Bass,

I) <[email protected]>; 'CAMPBELL, STEPHEN E. (NO) (FBI' <[email protected]>; Carey, Kaitlan (NO) (FBI) <[email protected]>; Carney, Sarah M. (SU) (FBI) <[email protected]>: Carollo, Leonard (DN) (FBI) <[email protected]>; Cartledge, Chandra L. (CD) (FBI) <[email protected]

(DL) (FBI) <[email protected]>; Tilford, Timothy Coleman (NH) (FBI) <[email protected]>; To, Jane Yi Chen (SF) (FBI) <[email protected]>; Tompkins, Taylor Conrad (LR) (FBI) <[email protected]>; Toscano, Michelle Lee (NY) (FBI) <[email protected]>; TP- SQ19 <[email protected]>; TP-SQ