Epstein Secrets

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

ghs the harm to the defendant if the injunction issues; and (4) that the injunction will not disserve the public interest. See N. Am. Med. Corp. v. Axiom Worldwide, Inc., 522 F.3d 1211, 1217 (11th Cir. 2008). An injunction is a drastic and extraordinary remedy which should be granted sparingly and only after the mov

to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino

z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants

suffered by the opposing party if the injunction issued; and (4) an injunction would not disserve the public interest. See North Am. Med. Corp. v. Axiom Worldwide, Inc., 522 F.3d 1211, 1217 (11th Cir. 2008).12 Because a preliminary injunction is an extraordinary and drastic remedy, it is not to be granted until the

to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino

z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants

suffered by the opposing party if the injunction issued; and (4) an injunction would not disserve the public interest. See North Am. Med. Corp. v. Axiom Worldwide, Inc., 522 F.3d 1211, 1217 (11th Cir. 2008).12 Because a preliminary injunction is an extraordinary and drastic remedy, it is not to be granted until the

to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino

B AD Plaintiff, VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. . 91 c. C AMENDED COMPLAINT 61

suffered by the opposing party if the injunction issued; and (4) an injunction would not disserve the public interest. See North Am. Med. Corp. v. Axiom Worldwide, Inc., 522 F.3d 1211, 1217 (11th Cir. 2008),I2 Because a preliminary injunction is an extraordinary and drastic remedy, it is not to be granted until the