Epstein Secrets

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

s an attorney does not render everything he does for or with the client privileged." Gutter I E.I. DuPont de Nemours and Co. , 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) EFTA00223001 (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the

ot yet obtained Jane Doe #18's telephone records, we were able to identify her telephone number, and there are twenty telephone calls that appear on Sarah Kellen's phone records. All of those calls were outgoing (meaning Kellen called Jane Doe #18.) The telephone calls range in date from August 27, 2003 throu

each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's assistant—usually Kellen—in the kitchen. The assistant normally would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage

n 3142 (g). United States . King, 849 F.2d 485, 488 (11th Cir. 1988). Sciacca (unpublished opinion), Court File No. 03-80164-Cr-Hurley, at pp. 4-5 (S.D. Fl. Feb. 25, 2004). Here, the defendant's blatant disregard of the order of the Florida court regarding his contact with the victim shows his continu

onal girls were interviewed for the first time. During those interviews, the girls related that , Epstein's assistant, would contact the girls while Kellen and Epstein were still in Ncw York or elsewhere,' in order to arrange "massage" times upon his arrival in Palm Beach. The FBI also has collected th

he United States respectfully requests that, consistent with the guidelines enunciated in 18 U.S.C. § 2705(6) and the Court's equitable powers under S.D. Fl. Gen. R. 5.4(B), the Motion for Order of Disclosure under 18 U.S.C. § 2703 and the Order of Disclosure be sealed until the time for production of d

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

nited States in evaluating that claim, but Epstein has objected to the production of those documents. -17- EFTA00179116 Co., 1998 WL 2017926, *1 (S.D. Fl. May 18, 1998) (citations omitted). If an attorney (or his agent) was doing something other than rendering legal advice, neither the attorney-client