Epstein Secrets

D described her as a very pretty Hispanic female in her early twenties, with long brown hair, and approximately 5'5" to 5'6" tall. WILD stated that SARAH KELLEN, another of EPSTEIN's assistants, or EPSTEIN would usually contact her. KELLEN would telephone and ask if she was available or if she had any other

wn hair, and approximately 5'5" to 5'6" tall. WILD stated that SARAH KELLEN, another of EPSTEIN's assistants, or EPSTEIN would usually contact her. KELLEN would telephone and ask if she was available or if she had any other Investigation on 08/07/2007 a: West Palm Beach, Florida Rica 31E-MM-108062

WILD provided the following additional or clarifying information not previously documented in earlier FD-302s: JEFFREY EPSTEIN and his assistants, SARAH and ADRIANA(identified as SARAH KELLEN and ADRIANA MUCINSKA) would contact WILD to set up appointments for EPSTEIN's massages. According to WILD,

notes had in the first place before reaching the `waiver' issue. Accordingly, and because I do not believe that the ork-product *243 doctrine of Hickman Taylor, 329 U.S. 495, 67 S.Ct. 385, 91 L. . 451 (1947), can be extended wholesale from its historic role as a limita- tion on the nonevidentiary m

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

)(3) was adopted in 1970 to codify the holding in Hickman v. Taylor, 1 329 U.S. 495 (1947). 10 involving co

.A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel/or 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/or Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

; Lake Shore Radiator, Inc. v. Radiator Express Warehouse, 2008 WL 842989 (M.D. Fla. 2007)(protecting investigative materials as work-product); and Hickman v. Taylor, 329 U.S. 495, 508, 67 S.Ct. 385, 91 L.Ed. 451 (1947)(noting, among other things and subject to exception, that work-product includes inf

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 exchange f

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

ation need not be admissible at trial if the discovery appears reasonably calculated to lead to the discovery of admissible evidence." Id.; see also Hickman v. Taylor, 329 U.S. 495, 507-508 (1947); Farnsworth v. Proctor and Gamble Co., 758 F.2d 1545, 1547 (11th Cir. 1985)(the Federal Rules of Civil Proced

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

discovery of admissible evidence." Id.; see also Hickman Case 9:08-cv-80119-KAM Document 242 Entered o

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

n hidden in an attorney's file and where production of those facts is essential to that preparation of one's case, discovery may properly be had." Hickman I Taylor , 329 U.S. 495, 511 (1947). Furthermore, the "work product rule protects work done by an attorney in anticipation of, or during, litigation

ZORRO RANCH RD PAUL VISOSKI. STANLEY, NM 87056-9783 LAWRENCE JR VISOK. LAWRENCE P 1635 SW SILVER PINE WAY APT Fl PALM CITY, FL 34990-4732 4: KELLEN, SARAH L 27 HIGH TECH BLVD 241-53-XXXX 5/1979 BONK, SARAH L THOMASVILLE, NC 27360- VICKERS, SARAH 5560 KENSINGTON, SARAH BINK. SARAH 92 GREE

t from and broader than the attorney-client privilege." United States v. Nobles, 422 U.S. 225, 238, 95 S. Ct. 2160, 45 L. Ed. 2d 141 (1975) (citing Hickman, 329 U.S. at 508). In fact, the Eighth Circuit went on to consider the application of the work product doctrine and concluded that it did not apply