Epstein Secrets

of 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM IN RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO DISMISS FIRST AMEDNED COM

. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT EPSTEIN'S REPLY TO PLAIN

formation previously lawfully disclosed (prior to the commencement of any civil or administrative proceeding under this chapter) to the public by a Federal, State, or local governmental entity or by the plaintiff in a civil action under this chapter. 2 See §552a(g)(4), in bold, for relevant section of statut

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

onal Recognizance or an "Release on personal recognizance," means release on the following conditions appear at all subsequent judicial proceed a Federal, State, or local crime," id. y made in writing (in a report rarely range cover sheet), but it is not e orally in open court because there was es Officer

1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (2) In or around 2001, Defendant SARAH ICELLEN led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001

in exchange for posing for nude photographs. (13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that auJant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane 1.J1 Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who w

or arrest, he was on pro- bation, or parole, or on other release pending trial, sentencing, appeal, or completion of sentence for an offense under Federal, State, or local law; and "(4) the nature and seriousness of the danger to any person or the community that would be posed by the person's re- lease. In