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,

enabling the client to conform his conduct to the dictates of the law and to present le- gitimate claims and dt enses f if litigation ensues. See Upjohn Co. I United States, O 2011 Thomson Reuters. No Claim to Orig. US Gov. Works. https://web2.westlaw.com/print/printstream.aspx?vi-2.0&mt=EleventhCircuit

[email protected],rtla'?',com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

cereinha,rtla'?',com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

201 F.R.D. 272 (D.D.C. 2001); See also, Salter v. Upjohn Co., 593 F.2d 649, 651 (5th Circ. 1979)(It is very u

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

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. I United States , 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records . . . in the hands of an attorney—or

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

_00059577 CONFIDENTIAL - PURSUANT TO FED. R.CCIN(F IDENTIAL DB-SONY-0022401 EFTA 00170127 EFTA01296795 Page 71 2015 U.S. Dist. LEXIS 87203, * Upjohn Co. v. United States, 449 U.S. 383, 402, 101 S. Ct. 677, 66 L. Ed. 2d 584 (1981)); see also In re Doe, 662 F.2d 1073, 1080 (4th Cir. 1981) (even under c

United States hereby opposes Epstein's motion and moves for an order to compel the appearance of witnesses and production of the requested items. 'Sarah is one of Epstein's personal assistants. -5- EFTA00179104 ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The

tions, but does not prevent disclosure from the client's records the underlying factual information included in attorney-client communications. See Upjohn Co. v. United States, 449 U.S. 383, 395 (1981). For this reason, putting otherwise non-privileged business records ... in the hands of an attorney—or p