Epstein Secrets

cJble c-ause affidc1_vits ar1d case fiiing packages .thus. far resulting, from the Palm Beach Police Dep~rtmehfs i,nve~tig~tion ofJeffr~y E:p~te.in, Sarah Kellen and Haley Robson. Th·e submission ofthese documf;ints· are bottfi!'I re~ponse to Assistant State Attorney Lanna Belohlavek's requestfar themand to s

left the kitchen leaving^^^lone in the kitchen. They returned a short time later. They all spoke briefly in the kitchen. ^|^vas instructed to follow Kellen upstairs. I^Becalled walking up a flight of stairs, lined with photographs, to a room that had a massage table in it. Upon entering the room there wa

e. Upon her arrival to the house she was introduced to Epstein in the kitchen of the house. She was also introduced to a white female known to her as Sarah. She was led upstairs to the main bedroom known to her as Jeff Epstein’s bedroom. Sarah arranged the massage table and covered the table with a sheet

stayed only in panties as she thd prepared the room for the massage. Epstein entered the.room wearing family.=3—=££=« eighteen oroide,, htterviews by Sarah KeUen, and massage routine when they went to work forbP ■ 1H come to Epstein’s house and were made appointments for the females to work or pstein. @ @ t0 R

the investigation and potential prosecution, relating to Jeffrey Epstein’s alleged sexual activities with minor females,” and assigned the matter to the Middle District of Florida U.S. Attorney’s Office for further consideration. The records included a declination of the matter due to the NPA. 7. U.S. Attorney’s Offi

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

980); United States I Landof, , 591 F.2d 36, 38 (9th Cir. 1978); In re Grand flay Proceedings , 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn , the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd , the court found tha

Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/or Sarah Kellen, including but not limited to witness testimony, statements made by any member of the State Attorney's Office, and instructions given by any member

rring or relating to Jeffrey Epstein and/or Sarah Kellen, including but not limited to witness testimony,

r, M. Alan Ccballos, Assk U.S. Attys., U.S. Attorney's Office. Jacksonville, Ha., for appellee. Appeals from the United States District Court for the Middle District of Florida. Before TJOFLAT and KRAVITCH, Circuit Judges, and TUTTLE, Senior Circuit Judge. TJOFLAT, Circuit Judge: Appellants appeal from an

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

. 1980); United States v. Landof, 591 F.2d 36, 38 (9th Cir. 1978); In re Grand Jury Proceedings, 73 F.R.D. 647, 651 (M.D. Fl. 1977)). In Blackburn, the Middle District of Florida applied the act of production privilege under the premise that Boyd was still binding precedent. Even applying Boyd, the court found that

861 Thm P-007785 File folder entitled "EPSTEIN/KELLEN CELL PHONE RECORDS" containing documents receiv

e documents being held by the U.S. Attorney's Office in the other district that is handling conflict matters. (It appears that this other office is the Middle District of Florida.) This appears to be improbable, because the conflict matters would presumably generate many documents covered by the victims' discovery