Epstein Secrets

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

ould 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 photograp

Dated: February 27, 2008 Respectfully submitted, By: s/ Adam D. Horowitz_ ______ . Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for

that Plaintiff’s interrogatories requesting that he identify employees may lead to evidence tending to incriminate him because one of his employees, Sarah Kellen, is identified in the Complaint. (Defendant Memorandum (DE 56), p. 18). This does not, however, support a blanket refusal to answer on Fifth Amen

criminate him because one of his employees, Sarah Kellen, is identified in the Complaint. (Defendant Mem

oduce responsive documents. Dated: April 20, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for

criminate him because one of his employees, Sarah Kellen, is identified in the Complaint. (Defendant Memo

that Plaintiff's interrogatories requesting that he identify employees may lead to evidence tending to incriminate him because one of his employees, Sarah Kellen, is identified in the Complaint. (Defendant Memorandum (DE 56), p. 18). This does not, however, support a blanket refusal to answer on Fifth Amendm

rrogatories and produce responsive documents. Dated: April 20, 2009 Respectfully submitted, By: s/ Stuart S. Mermelstein Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) [email protected] MERMELSTEIN & HOROWITZ, P.A. Attorneys for

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

ot well founded, and therefore should be denied. Dated: September 22, 2008. Respectfully submitted, By: s/ Jeffrey M. Herman Jeffrey M. Herman (FL Bar No. 521647) [email protected] Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitz@ herman

an and scheme reflected a particular pattern and method. The underage victim would be brought to Epstein's mansion, where she would be introduced to Sarah Kellen, Epstein's assistant. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other f

tern and method. The underage victim would be brought to Epstein's mansion, where she would be introduced to Sarah Kellen, Epstein's assistant. 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. The girl would then fi

EMAND Plaintiff demands a jury trial in this action on all claims so triable. Dated: September i V , 2008 Respectfully su By: Jeffrey M. Herman (FL Bar No. 521647) ihermanftermanlaw.com Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowitzahermanl

ed States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office,

rs of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova

ctfully request that the Motion to Stay be denied. Dated: February 13, 2008 Respectfully submitted, By: 5/ Jeffrey M. Herman Jeffrey.M. Herman (FL Bar No. 521647) ihermanOltermanlaw.com Stuart S. Mermelstein (FL Bar No. 947245) [email protected] Adam D. Horowitz (FL Bar No. 376980) ahorowi