Epstein Secrets

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

imited number of exceptions to the general requirement of disclosure, which permit plaintiffs to proceed anonymously.” Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 685 (11th Cir. 2001) (internal citation omitted). “The 4 Although some Plaintiffs

d scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant’s mansion, the underage victim would be introduced to Sarah Kellen, Defendant’s assistant, who gathered the girl’s personal information, including her name and telephone number. Id. Kellen would then bring the girl

uld be introduced to Sarah Kellen, Defendant’s assistant, who gathered the girl’s personal information, including her name and telephone number. Id. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. Id. There were photog

eading requirement, one that does not require a plaintiff to plead with particularity every element of a cause of action. Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 683 (11th Cir. 2001). Instead, the complaint need only “contain either direct or inferential allegations respecting all the material

d scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant's mansion, the underage victim would be introduced to Sarah Kellen, Defendant's assistant, who gathered the girl's personal information, including her name and telephone number. Id. Kellen would then bring the girl

ld be introduced to Sarah Kellen, Defendant's assistant, who gathered the girl's personal information, including her name and telephone number. Id. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. Id. There were photogr

ading requirement, one that does not require a plaintiff to plead with particularity every element of a cause of action. Roe I. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 683 (I I th Cir. 2001). Instead, the complaint need only "contain either direct or inferential allegations respecting all the materi

d scheme reflected a particular pattern and method. Am. Compl. ¶ 11. Upon arrival at Defendant's mansion, the underage victim would be introduced to Sarah Kellen, Defendant's assistant, who gathered the girl's personal information, including her name and telephone number. Id. Kellen would then bring the girl

ld be introduced to Sarah Kellen, Defendant's assistant, who gathered the girl's personal information, including her name and telephone number. Id. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. Id. There were photogr

ading requirement, one that does not require a plaintiff to plead with particularity every element of a cause of action. Roe I. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 683 (I I th Cir. 2001). Instead, the complaint need only "contain either direct or inferential allegations respecting all the materi

Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl u

would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other furnishings. There were photograph

stain a recovery under some viable legal theory." Snow v. DirectTV, Inc., 450 F.3d 1314, 1320 (11th Cir. 2006) (quoting Roe v. Aware Woman Ctr. For Choice, Inc., 253 F.3d 678, 684 (11th Cir. 2001)). Moreover, a court should dismiss a complaint "when, on the basis of a dispositive issue of law, no constructi

0312010 Page 5 of 10 reveals that Plaintiff alleges with whom Defendant conspired, stating that he "conspired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these acts and to avoid police detection." See ¶ 15. Additionally, Plaintiff sufficiently alleges the identi

ired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these act

ading requirement, one that does not require a plaintiff to plead with particularity every element of a cause of action. Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 683 (11th Cir. 2001). Instead, the complaint need only "contain either direct or inferential allegations respecting all the material