Epstein Secrets

arties, Jurisdiction and Venue COMES NOW the Plaintiff, C.M.A., and brings this First Amended Complaint against the Defendants, JEFFREY EPSTEIN and SARAH KELLEN, and states as follows: 1. This is an action for damages in excess of $75,000.00, exclusive of interest and costs. 2. This Complaint is brought

against the Defendants, JEFFREY EPSTEIN and SARAH KELLEN, and states as follows: 1. This is an action f

abuse of a minor child. The Defendant, JEFFREY EPSTEIN, at all times material to this cause of action, knew and should have known of the Plaintiff, C.M.A.'s minority. 17. In June 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, the Defendant, JEFFREY EPSTEIN, entered pleas of "g

8 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON C.M.A., Plaintiff, VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. TREATMENT DER REGARDING AND ND INCORPORATED MEMORANDUM OF LAW This matter came before the Court upon the Plaintiffs Motion For Pro

.A., Plaintiff, VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. TREATMENT DER REGARDING AND ND

uction of these confidential and private treatment records would only serve to further humiliate, embarrass, and victimize C.M.A . 9. Furthermore, C.M.A.'s treatment records from the Inc. and are protected by the psychotherapist-patient privilege pursuant to the Supreme Court's decision in Jaffee v.

Esq. Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. Counsel tor vetwn-ciant JOU Bruce Reinhart, Esq. Counsel for Defendant Sarah Kellen Respectfully su By: ROB JR., ESQ. Florida Bar No. 2241 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN

Bruce Reinhart, Esq. Counsel for Defendant Sarah Kellen Respectfully su By: ROB JR., ESQ. Florida Ba

xpert discovery must be completed on June 29, 2009 for C.M.A. 6. As to C.M.A., Jane Doe and Jane Does 2-7, each has objected to relevant discovery. C.M.A. has even refused to produce certain information that she agreed to produce in discovery. The foregoing delay tactics has prevented Epstein from co

NITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV- MARRA/JOHNSON C.M.A., Plaintiff(s), vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendant(s). NOTICE OF SERVING ANSWERS TO INTERROGATORIES COMES NOW the Plaintiff, C.M.A., by and through undersigned counsel, and hereby file

., Plaintiff(s), vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendant(s). NOTICE OF SERVING ANSWERS TO IN

e Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm Beach, FL 33401 Tel: (561) 202-6360 Subject matter: Defendant 3. C.M.A.'s attorneys: Jack Scarola, Esq. and Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm B

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-CIV-MARRA/JOHNSON C.M.A., Plaintiff(s), VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendant(s). / PLAINTIFF'S INITIAL DISCLOSURE COMES NOW the Plaintiff, C.M.A., by and through her undersigned attorneys, and hereby files he

, Plaintiff(s), VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendant(s). / PLAINTIFF'S INITIAL DISCLOS

Bruce E. Reinhart, P.A. 250 South Australian Avenue Suite 1400 West Palm Beach, FL 33401 Tel: (561) 202-6360 Subject matter: Defendant 3. do C.M.A.'s attorneys: Jack Scarola, Esq. and Jack P. Hill, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm B

& 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 ecf @brucereinhartlaw.com Counsel for Defendant Sarah Kellen Respectfully itted, By: ROBERT ia. CRITTON, JR., ESQ. Florida B r No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 mpi

brucereinhartlaw.com Counsel for Defendant Sarah Kellen Respectfully itted, By: ROBERT ia. CRITTON, J

is Court subsequently denied on December 12, 2008 (DE 28). The case was transferred from Judge Zloch to this division on September 3, 2008 (DE 21). C.M.A. filed her First Amended Complaint on February 10, 2009. (C.M.A. DE 39-40). Epstein's Motion to Dismiss same was filed on March 12, 2009. (C.M.A. DE

13 Entered on FLSD Docket 05/06/2009 Page 2 of 29 Jane Doe II v. Epstein. et al. Page 2 50 2008CA020614 MBAF, Jane Doe II v. Jeffrey Epstein, and Sarah Kellen, (hereinafter "state action"). In attempting to allege a claim under 18 U.S.C. §2255, Plaintiff improperly relies on the §2255, as amended, effect

ENDNOTES: 1 In paragraph 11 of her Complaint, Jane Doe II alleges that — "From about June, 2003 until about February, 2005, Defendants, EPSTEIN and KELLEN persuaded, induced, or EFTA00222839 Case 9:09-cv-80469-KAM Document 13 Entered on FLSD Docket 05/06/2009 Page 28 of 29 Jane Doe II v. Epstein,

A/JOHNSON, in Defendant's Motion to Dismiss directed to Plaintiff C.M.A.'s Amended Complaint, Plaintiff C.M.A.'s Response, and Defendant's reply to C.M.A.'s response (which has yet to be filed). In this action, Plaintiffs Complaint attempts to allege a cause of action pursuant to 18 U.S.C. §2255 - Civ

0/2008 17 08/20/2008 34 08/25/2008 18 08/27/2008 19 08/28/2008 NOTICE OF REMOVAL Filing fee $350 Receipt#: 724505, filed by Jeffrey Epstein. Sarah Kellen.(rb) (Entered: 07/21/2008) ORDER of Instructions. Signed by Judge William J. Zloch on 7/22/2008. (bc) (Entered: 07/22/2008) MOTION for Hearing Defenda

Marra on 06/15/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 06/15/2009) ORDER granting 37 Motion for Default against Defendant Kellen. Signed by Judge Kenneth A. Marra on 6/16/2009. (ir) Modified text on 6/18/2009 (wc). (Entered: 06/17/2009) NOTICE of Reliance on by Jeffrey Epstei

sponse in Opposition to Motion, filed by Jeffrey Epstein, 114 Motion for Protective Order filed by C.M.A., 121 Motion for Protective Order, filed by C.M.A., 137 Motion to Strike filed by Jeffrey Epstein. Signed by Magistrate Judge Linnea R. Johnson on 7/16/2009. (ail) (Entered: 07/17/2009) NOTICE of Co

y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor

the exact same crimes and exact same evidence being reviewed by the U.S. Attorney's office when he was employed there. Specifically, he represented Kellen (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry

r the 9 agreement is supposed to be admitted. Now, as to the amount of 10 damages, there are legal issues that will be before you and 11 under the C.M.A. cases that are getting before you, as to 12 whether it is 50 or 150. That has nothing to do with the NPA. 13 There are legal issues that are befor