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ralian Avenue, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 202-6360 Fax: (561) 828-0983 [email protected] Counsel for Co-Defendant, Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida
ereinhartlaw.com Counsel for Co-Defendant, Sarah Kellen Jack Scarola, Esq. Jack P. Hill, Esq. Searcy
an permeate everything: your sense of self, intimate relationships, sexuality, parenting, working, even your sanity.”)4 The U.S. Supreme Court in Coker v. Georgia, 433 U.S. 584, 597 (1977), discussed the grave nature of the crimes at issue in the cases against Defendant, stating: [Rape] is highly r
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
w a discovery request is overly broad, burdensome or oppressive, by submitting evidence or offering evidence which reveals the nature of the burden.” Coker v. Duke & Co., 1777 F.R.D. 682, 686 (M.D. Ala. 1998). Once the resisting party meets its burden, the burden shifts to the moving party to show the i
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
evidence which reveals the nature of the burden.” Coker v. Duke & Co., 1777 F.R.D. 682, 686 (M.D. Ala. 19
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
ng the 1967 interview, when he was represented by counsel only in the state proceeding, are not barred in this federal proceeding."); United States' Coker , 433 F.3d 39 (1st Cir. 2005) (same). See also United States I Loll , F. Supp. 2d 2007 WL 1521487, *7 (M.D. Fl. May 23, 2007) ("Lall's state and
Entities connected to both Sarah Kellen and Coker

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONJack Scarola
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSONBruce E. Reinhart
PERSON
Lake Worth
LOCATION
United States
LOCATIONRichard Horace Willits
PERSONMichael J. Pike
PERSONJack Patrick Hill
PERSON
George W. Bush
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSON
Adam D. Horowitz
PERSON