Epstein Secrets

to Epstein’s home by Epstein’s bodyguard, Igor Zinoview, and after his stay with Epstein, Brunel was driven from Epstein’s house to the airport by Sarah Kellen. See deposition of Janusz Banaziak at page 154-161 and 168-16 attached hereto as Exhibit “A.” MEMORANDUM OF LAW As is readily apparent from the

d alone? 22 A. Yes. 23 Q. Who else was in the house last week while 24 Mr. Brunel was in the house? 25 A. Nadia, Sarah, and Story, I think. Case 9:08-cv-80119-KAM Document 483 Entered on FLSD Docket 03/10/2010 Page 16 of 20 2d75a91d-3eaa-42b3-ae22-b5d3c7182d1e

ven from Epstein’s house to the airport by Sarah Kellen. See deposition of Janusz Banaziak at page 154-

efendant Epstein. Shortly after Brunel was served, counsel for Jane Doe was contacted by Tama Beth Kudman, Esq., a licensed attorney in Florida. Kudman stated that she represented Brunel with regard to the subpoena and that she would produce Brunel for deposition in West Palm Beach if Jane Doe woul

3059 Grand Avenue Suite 340 Coconut Grove , FL 33133 USA Phone: (305)442-1101 Fax: 442-6744 Attorney to be Noticed Email: [email protected] Sarah Kellen Guv Alan Lewis Defendant Lead Attorney Lewis Tein 3059 Grand Avenue Suite 340 Coconut Grove , FL 33133 USA Phone: (305)442-1101 Fax: 442-6744 A

ffrey Epstein, Haley Robson. (Attachments: # 1 exhibits. # 2 exhibits)(jgn) (Entered: 07/21/2008) MOTION for Hearing Defendants Jeffrey Epstein and Sarah Kellen's Request for Oral Argument by Sarah Kellen. Jeffrey Epstein. (Tein. Michael) (Entered: 07/25/2008) MOTION for Extension of Time to File Answer Defen

y to be Noticed Email: [email protected] Sarah Kellen Guv Alan Lewis Defendant Lead Attorney Lewis

tiff's MOTION for Order to Show Cause filed by Jean Luc Bruhnel. (Attachments: # 1 Exhibit, # 2 Exhibit)Associated Cases: 9:08-cv-80119-KAM et al. (Kudman, Tama) (Entered: 03/12/2010) 05/06/2010 107 Defendant's MOTION for Summary Judgment Including Supporting Memorandum of Law by Jeffrey Epstein. Re

information about Epstein's organization for procuring young girls was also blocked because Epstein's co-conspirators took the Fifth. Deposition of Sarah Kellen, March 24, 2010 (hereinafter "Kellen Depo.") (Deposition attachment #14); Deposition of Nadia Marcinkova, April 13, 2010, (Deposition attachment #9)

FBI. Epstein also threatened and harassed Sarah Kellen against cooperating against him as well. 21. Ed

IL" Before the deposition took place, Brunel's attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brune

0/2008 17 08/20/2008 34 08/25/2008 18 08/27/2008 19 08/28/2008 NOTICE OF REMOVAL Filing fee $350 Receipt#: 724505, filed by Jeffrey Epstein. Sarah Kellen.(rb) (Entered: 07/21/2008) ORDER of Instructions. Signed by Judge William J. Zloch on 7/22/2008. (bc) (Entered: 07/22/2008) MOTION for Hearing Defenda

Marra on 06/15/2009. Associated Cases: 9:08-cv-80119-KAM et al. (Ic3) (Entered: 06/15/2009) ORDER granting 37 Motion for Default against Defendant Kellen. Signed by Judge Kenneth A. Marra on 6/16/2009. (ir) Modified text on 6/18/2009 (wc). (Entered: 06/17/2009) NOTICE of Reliance on by Jeffrey Epstei

tiff's MOTION for Order to Show Cause filed by Jean Luc Bruhnel. (Attachments: # 1 Exhibit, # 2 Exhibit)Associated Cases: 9:08-cv-80119-KAM et al. (Kudman, Tama) (Entered: 03/12/2010) 05/28/2010 76 RESPONSE/REPLY to (545 in 9:08-cv-80119-KAM) Appeal of Magistrate Judge Decision to District Court, Pl

to Epstein's home by Epstein's bodyguard, Igor Zinoview, and after his stay with Epstein, Brunel was driven from Epstein's house to the airport by Kellen. See deposition of Janusz Banaziak at page 154-161 and 168-16 attached hereto as Exhibit 'A." MEMORANDUM OF LAW As is readily apparent from the fo

y Defendant Epstein. Shortly after Brunel was served, counsel for Jane Doe was contacted by Tama Beth Kudman, Esq., a licensed attorney in Florida. Kudman stated that she represented Brunel with regard to the subpoena and that she would produce Brunel for deposition in West Palm Beach if Jane Doe woul

ng the commission of a violation of federal law to a law enforcement officer, namely, Special Agents of the FBI. Epstein also threatened and harassed Sarah Kellen against cooperating against him as well. 21. | Edwards learned that the Palm Beach police department investigation ultimately led to the execution o

“II.” Before the deposition took place, Brunel’s attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brunel

” — categories Clinton and acquaintances of Clinton fall into; (f) flight logs showed that Clinton took many flights with Epstein, Ghislaine Maxwell, Sarah Kellen, and Adriana Mucinska, -- all employees and/or co-conspirators of Epstein’s that were closely connected to Epstein’s child exploitation and se

tegories Clinton and acquaintances of Clinton fall into; (f) flight logs showed that Clinton took many flights with Epstein, Ghislaine Maxwell, Sarah Kellen, and Adriana Mucinska, -- all employees and/or co-conspirators of Epstein’s that were closely connected to Epstein’s child exploitation and sexual ab

the commission of a violation of federal law to a law enforcement officer, namely, Special Agents of the FBI. Epstein also threatened and harassed Sarah Kellen against cooperating against him as well. 21. | Edwards learned that the Palm Beach police department investigation ultimately led to the execution o

FBI. Epstein also threatened and harassed Sarah Kellen against cooperating against him as well. 21. | E

“II.” Before the deposition took place, Brunel’s attorney (Tama Kudman of West Palm Beach) contacted Edwards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brunel