Epstein Secrets

be able to depose Story Cowles ("Cowles") becatise: (1) Cowles visited Epstein in jail with a "third party visitors," such as Nadia Marcinkova and Sarah Kellen, which eliminated any confidentiality; (2) Epstein may have discussed transfer of assets with Cowles; (3) Cowles may have discussed the cases agains

Exhibit I to Jane Doe's Response. Jane Doe make this untenable conclusion because of a visitor's log which indicates that Ms. Marcinkova and/or Ms. Kellen visited Mr. Epstein on some of the same days Cowles visited Mr. Epstein. A cursory review of the Exhibit I will show that Cowles often visited Mr.

ement with Epstein. See Edwards Aff. ~15. What information? Edwards cites none. c. Cowles is at Epstein's house almost every day of the week with Sarah Kellen or Epstein or both and knows of and interacted with the visitors to Epstein's house. See Edwards Aff. ~~16, 18. Has Edwards personally been

s no evidence to support her conclusions. Accordingly, the Court should disregard these unsupported statements in determining Epstein's Motion. See Frasher v. Fox Distributing of S.W. Fla., Inc., 813 So. 2d 1017, 1020 (Fla. 2d DCA 2002) (holding that an affidavit "must not be based on hearsay or the pl

A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Ricci-Leopold, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax:

brucereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

) (holding that a newspaper article, introduced to prove the truth of out of court statements contained therein, constitutes inadmissible hearsay); Frasher v. Fox Distributing of S.W. Fla., Inc., 813 So. 2d 1017, 1020 (Fla. 2d DCA 2002) (holding that an affidavit supporting a prejudgment writ of attach

f 24 Bruce E. Reinhart, P.A. ounse or ►e t 'ri Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

) (holding that a newspaper article, introduced to prove the truth of out of court statements contained therein, constitutes inadmissible hearsay); Frasher v. Fox Distributing of S.W. Fla.. Inc., 813 So. 2d 1017, 1020 (Ha. 2d DCA 2002) (holding that an affidavit supporting a prejudgment writ of attachm