Epstein Secrets

llars. The Second Amended Complaint states that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p

The Second Amended Complaint states that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p

.5); see also Edwin v. Price, 778 F.2d 668, 669 (I Ith Cir. 1985) (citing Lefkowitz v. Turley, 414 U.S. 70, 7

ach. Once at the mansion, Jane was introduced to Sarah Kellen, who led her up a flight of stairs to the room w

nce at the mansion, Jane was introduced to Sarah Kellen, who led her up a flight of stairs to the room w

l. 3, §10, cl. 1. U.S. v. Seigel, 153 F.3d 1256 (I Ith Cir. 1998); U.S. v. Edwards, 162 F.3d 87 (3d Cir. 1998

Case 9:08-cv-80119-KAM Document 510 Entered on FLSD Docket 03/29/2010 Page 4 of 8 RICO Case Statement" to argue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "involvement in the scheme." See DE #486 at 2. 14. As Jane Doe's RICO claim was dismissed

ment" to argue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because

9 Omnibus Order,2 "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Williamson Tobacco, 959 F.2d 1566, 1570 (I Ith Cir. 1992) .... Courts have long held that '[w]hile the standard of relevancy [in discovery] is a liberal one, it is not so liberal as to allow a party

/31/2009 Page 15 of 20 alleges and the Magistrate Judge's Order acknowledges allegations of a scheme where 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

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

civil or criminal, formal or informal, where the answers might incriminate him in future criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (I Ith Cir. 1985), citing Lefkowitz v. Turley. 414 U.S. 70, 77 (1973)). The privilege is accorded "liberal construction in favor of the right it was intended t