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U.S.C. §2422, along with pre-2006 amended text. See Exhibit B hereto - copy of Plaintiff's Second Amended Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's plan and scheme (which) reflected a particular pattern and method" in the alleged recruiting of girl
ed Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HIPAA). Federal Rule of Evidence 401 provides that - "'Relevant evidence'" means evidence having any tendency to make the existence of any fa
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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,
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HI PAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these
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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
mation is privileged pursuant to Rule 501, Fed. Evid., and §90.503, FIa.Evid. Code. In addition, such information is protected by the provisions of the Health Insurance Portability and Accountability Act (HI PAA). Interrogatory No. 9. List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at any time during the period of these
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Mutual Connections (46)
Entities connected to both Sarah Kellen and the Health Insurance Portability and Accountability
Jeffrey Epstein
PERSON3,807 w/ Sarah·5 w/ the
Ghislaine Maxwell
PERSON408 w/ Sarah·3 w/ the
JD
Jane Doe
PERSON349 w/ Sarah·4 w/ the
JG
Jack Goldberger
PERSON310 w/ Sarah·4 w/ the
NM
Nadia Marcinkova
PERSON266 w/ Sarah·3 w/ the
Kenneth Marra
PERSON192 w/ Sarah·4 w/ the
Alan Dershowitz
PERSON188 w/ Sarah·4 w/ the
United States
LOCATION167 w/ Sarah·3 w/ the
MP
Michael J. Pike
PERSON161 w/ Sarah·3 w/ the
Adam D. Horowitz
PERSON149 w/ Sarah·4 w/ the
the Southern District
LOCATION117 w/ Sarah·2 w/ the
Atterbury Goldberger & Weiss
ORGANIZATION105 w/ Sarah·4 w/ the
Jean-Luc Brunel
PERSON93 w/ Sarah·3 w/ the
HR
Haley Robson
PERSON85 w/ Sarah·3 w/ the
SM
Stuart S. Mermelstein
PERSON78 w/ Sarah·3 w/ the
Jay Lefkowitz
PERSON79 w/ Sarah·2 w/ the
Jeffrey Marc Herman
PERSON32 w/ Sarah·3 w/ the
FI
Fisher
PERSON24 w/ Sarah·2 w/ the
HU
Hubbell
PERSON22 w/ Sarah·2 w/ the
Luttier & Coleman
ORGANIZATION20 w/ Sarah·2 w/ the