Epstein Secrets

No. 2 v. Epstein Page 15 Request No. 15. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes,

Citing to U.S. v. Lot 5. Fox Grove, supra, the Southern District Court, Florida, in Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), stated — The Eleventh Circuit has also created a test for these circumstances. stating that where there exists a concurrent civil and criminal proceeding, a court must stay a ci

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

the appearance of witnesses and production of the requested items. ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The Eleventh Circuit has ruled that a target of a grand jury investigation should be allowed to intervene once the claim of attorney-client privilege between the subpoen

! !24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRA/JOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, Defendant. Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedinas

. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, Defendant. Jeffrey Epstein's Motio

). Citing to U.S. v. Lot 5, Fox Grove supra, the Southern District Court, Florida, in Ventura v. Broskv 2006 WL 3392207 (S.D. Fla. 2006), stated — The Eleventh Circuit has also created a test for these circumstances, stating that where there exists a concurrent civil and criminal proceeding, a court must stay a ci