Epstein Secrets

3059 Grand Avenue Suite 340 Coconut Grove , FL 33133 USA Phone: (305)442-1101 Fax: 442-6744 Attorney to be Noticed Email: [email protected] Sarah Kellen Guv Alan Lewis Defendant Lead Attorney Lewis Tein 3059 Grand Avenue Suite 340 Coconut Grove , FL 33133 USA Phone: (305)442-1101 Fax: 442-6744 A

ffrey Epstein, Haley Robson. (Attachments: # 1 exhibits. # 2 exhibits)(jgn) (Entered: 07/21/2008) MOTION for Hearing Defendants Jeffrey Epstein and Sarah Kellen's Request for Oral Argument by Sarah Kellen. Jeffrey Epstein. (Tein. Michael) (Entered: 07/25/2008) MOTION for Extension of Time to File Answer Defen

y to be Noticed Email: [email protected] Sarah Kellen Guv Alan Lewis Defendant Lead Attorney Lewis

Incorporated Memorandum of Law by Jeffrey Epstein. (Pike. Michael) (Entered: 06/09/2010) 06/14/2010 162 Emergency MOTION for Protective Order by Jane Doe II. Associated Cases: 9:08-cv-80119-KAM et al.(ots) (Entered: 06/14/2010) 06/14/2010 163 NOTICE by Jane Doe re (565 in 9:08-cv-80119-KAM) MOTION for

e pain and suffering, costs of psychological care and treatment, and loss of earning capacity .... (lnterrog. No. 10). 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

on of emotional distress. Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 11 of 12 Doe 2 v. Epstein Page No. 11 Kellen, Case No. 502008CA025129 MB Al, 15th Judicial Circuit, In and For Palm Beach County, State of Florida, which granted Defendant's motion to compel th

d 21 herein.) Composite Exhibit C is a portion the transcript from a March 3, 2009 hearing on Defendant's motion to compel discovery in the case of Jane Doe II v. Epstein, and Kellen, Case No. 502008CA020614 MB AF, 15th Judicial Circuit Court, In and For Palm Beach County, State of Florida. Again, the Circ

e pain and suffering, costs of psychological care and treatment, and loss of earning capacity .... (lnterrog. No. 10). 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

ff. See Composite Exhibits B and C hereto. Composite Exhibit B are the Orders, dated February 23, 2009, entered in the case of A.G. v. Epstein, and Kellen, Case No. 502008CA025129 MB Al, 15th Judicial Circuit, In and For Palm Beach County, State of Florida, which granted Defendant's motion to compel th

d 21 herein.) Composite Exhibit C is a portion the transcript from a March 3, 2009 hearing on Defendant's motion to compel discovery in the case of Jane Doe II v. Epstein, and Kellen, Case No. 502008CA020614 MB AF, 15th Judicial Circuit Court, In and For Palm Beach County, State of Florida. Again, the Circ

ric examination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV -80811 ), as to time, subject m

xamination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV -80811 ), as to time, subject m

the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is

FL; Michael James Pike, Pike & Lustig, LLP, West Palm Beach, FL; Robert Deweese Critton, Jr., Critton Luttier & Coleman, West Palm Beach, FL. For Sarah Kellen, Defendant (9:08-cv-80811-KAM): Bruce Reinhart, LEAD ATTORNEY. Bruce E. Reinhart, P.A., West Palm Beach, FL; Jack Alan Goldberger, LEAD ATTORNEY. A

uttier & Coleman, West Palm Beach, FL. For Sarah Kellen, Defendant (9:08-cv-80811-KAM): Bruce Reinhart, L

; Joseph Laurence Ackerman, Jr., Fowler White Burnett, P.A., West Palm Beach, FL; Michael James Pike, Pike & Lustig, LLP, West Palm Beach, FL. For Jane Doe II, Plaintiff (9:09-cv-80469-KAM): Bradley James Edwards, LEAD ATTORNEY, Edwards Pottinger LLC, Fort Lauderdale, FL; Isidro Manuel Garcia, LEAD ATTORN

ourt inspect the documents in camera in order to assess whether, in fact, continued closure is proper. 3 See, e.g.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v. Epstein, Case No. 08-80811 (S.D. Fla. July 25, 2008) (filed publicly Jan. 7, 2009). 09/12/2079 CONFIDENTIAL Agency to

See, e.g.. "Defendants Jeffrey Epstein and Sarah Kellen's Motion for Stay," C.M.A. v. Epstein, Case No.

verned discovery. 9. Interestingly, in Jane Doe 11, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition. This is despite her claims of "emotional trauma" set forth in her complaint. Jane Doe No. 11 is also a Plai

0/2008 17 08/20/2008 34 08/25/2008 18 08/27/2008 19 08/28/2008 NOTICE OF REMOVAL Filing fee $350 Receipt#: 724505, filed by Jeffrey Epstein. Sarah Kellen.(rb) (Entered: 07/21/2008) ORDER of Instructions. Signed by Judge William J. Zloch on 7/22/2008. (bc) (Entered: 07/22/2008) MOTION for Hearing Defenda

Marra on 06/15/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 06/15/2009) ORDER granting 37 Motion for Default against Defendant Kellen. Signed by Judge Kenneth A. Marra on 6/16/2009. (ir) Modified text on 6/18/2009 (wc). (Entered: 06/17/2009) NOTICE of Reliance on by Jeffrey Epstei

: Other Docket: Jurisdiction: 03/24/2009 Judge Kenneth A Marra Personal Injury (360) Federal Question None None Federal Question Litigants Jane Doe II Plaintiff Jeffrey Epstein Defendant Class Code: CLOSED Closed: Yes Statute: 28:1331 Jury Demand: Plaintiff Demand Amount: $0 NOS Description

d on FLSD Docket 09/17/2009 Page 8 of 8 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 ecfObrucereinhartlaw.com Counsel for 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:

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

ontinue to attempt to control how discovery is conducted in this case and how this court has historically governed discovery. 9. Interestingly, in Jane Doe II, the state court case, attorney Sid Garcia took the deposition of the Defendant and his client, Jane Doe II, was present throughout the deposition.

Chinta [COR LD NTC] Mary Jo White US Attorney for SDNY 100 Church Street 19TH Floor New York. NY. USA 10007 DEFENDANT ATTORNEY(S): Yaroshefsky, Ellen [COR LD NTC] Cardozo Law Clinic 55 Fifth Avenue New York, NY, USA 10003 Confidential - This report is not to be disseminated or photocopied to an

Confidential Due Diligence Report UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA (West Palm Beach) Doe II v. Epstein et al PLAINTIFF: Jane Doe II DEFENDANT: Epstein, Jeffrey AMICUS: United States of America WITNESS: Jean Luc Bruhnel Material DOCKET CASE NUMBER: 9:09cv80469 FILING DATE: 3/

/2009 Spencer Kuvin Jacquie Johnson Attachment:Kellen & Trump subpoena Joint W/P Priv. 15999.16007

/02/2009 Bradley Edwards Katherine Ezell RE:Meeting w/Stanley Arkin Joint W/P Priv. 06861-06863 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv. 06876.06879 05/12/2009 Bradley Edwards Stuart Mermelstein RE:Jane Doe II v. Epstein Joint W/P Priv. 06891-06897 05/