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e No. 21. 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,
ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.
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,
ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.
communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes,
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
ents that are attorney-client and work product privileged in that it seeks "all documents obtained in discovery or investigation relating either to the Florida Criminal Case or the Federal Criminal Case ... ." In addition, such documents are privileged and confidential as they are the subject of a pending investigation.
Entities connected to both Sarah Kellen and the Florida Criminal Case

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSONJack Goldberger
PERSONNadia Marcinkova
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
United States
LOCATIONMichael J. Pike
PERSON
Adam D. Horowitz
PERSONRobert D. Critton
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Jean-Luc Brunel
PERSONHaley Robson
PERSONStuart S. Mermelstein
PERSON
Jeffrey Marc Herman
PERSONFisher
PERSONJANE DOE NO
PERSONU.S. Mail
ORGANIZATIONthe State Court
ORGANIZATION