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or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor girls to his homes in Palm beach, New York and St. Thomas, with the promise of money in EFTA00728
e, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor
hiring of investigators and, assuming certain parameters are met, also protect the information obtained thereby as work-product. See Alachua Gen'l Hosp.. Inc. v. Zimmer USA. Inc. 403 So.2d 1087 (Fla. 1s' DCA 1981) In re Faro Technologies Securities Litigation 2008 WL 205318 (M.D. Fla. 2008); Fed. R. Civ.
or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor girls to his homes in Palm beach, New York and St. Thomas, with the promise of money in EFTA00650
e, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor
hiring of investigators and, assuming certain parameters are met, also protect the information obtained thereby as work-product. See Alachua Gen'l Hosp.. Inc. v. Zimmer USA. Inc. 403 So.2d 1087 (Fla. 15' DCA 1981). In re Faro Technologies Securities Litigation 2008 WL 205318 (M.D. Fla. 2008); Fed. R. Civ.
0312010 Page 5 of 10 reveals that Plaintiff alleges with whom Defendant conspired, stating that he "conspired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these acts and to avoid police detection." See ¶ 15. Additionally, Plaintiff sufficiently alleges the identi
ired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these act
O statement are accepted as true, the alleged "enterprise" would clearly not act independently of Epstein, the RICO Defendant. See Boca Raton Comm. Hosp.. Inc. v. Tenet Healthcare Corp., 502 F.Supp.2d 1237, 1253 (S.D. Fla.2007) (the key to "distinctiveness" depends less on whether the enterprise members ar
Entities connected to both Sarah Kellen and Hosp.. Inc.

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
United States
LOCATION
George W. Bush
PERSON
Scarlett Johansson
PERSON
Oliver Stone
PERSONthe Eleventh Circuit
ORGANIZATIONChambers
PERSON
Anderson
PERSONFLSD Docket
ORGANIZATIONJANE DOE NO
PERSON
the United States Supreme Court
ORGANIZATIONGibson
PERSONTwombly
PERSON
Dennis
PERSON
Murphy
PERSONBonner v. City of
LOCATIONthe Florida Supreme Court
ORGANIZATIONBell Atlantic Corp.
ORGANIZATION