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A. 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 33401 561-202-6360 Fax: 561-828-0983 [email protected] Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq. Leopold, Kuvin, P.A. 2925 PGA Blvd., Suite 200 Palm Beach Gardens, FL 33410 561-684-6500 Fax:
brucereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq
court restrict same in time or scope. Lahr v. Fullbright & Jaworski, LLP., 164 F.R.D 196, 202-204 (N.D. Texas 1995)(refusing to limit examination); Morton v. Haskell Co., No. 94-976-CIV-J-20, 1995 WL 819182, at *3 (N.D.Fla. Sept.12, 1995) (declining to limit duration of examination); See also Affidavi
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,
re silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5th Amendment and having a judgment (summary or otherwise) entered against him in the ci
! !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
re silly, unfounded and alleged violations which are not defined as violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's Fork" in his side - the undesirable choice of taking the 5h Amendment and having a judgment (summary or otherwise) entered against him in the civ
rrell Williams (Gn his Vivienne Westwood “Mountain” hat) and Anjelica Huston chatted HOUSE_OVERSIGHT_010718 --- PAGE BREAK --- Portia de Rossi and Ellen DeGeneres Michael Fassbender up Chinatown producer Robert Evans. Dom Perignon sent the champagne, proving that even behind private dinners, one can
Page: HOUSE_OVERSIGHT_010719 →or husband Sacha Gervasi were in attendance as well as Adrien Brody, David O. Russell, Oliver Stone, Danny Huston, Jean Pigozzi, Ben Silverman, Peter Morton, and Elon Musk. Harvey and Bob Weinstein along with Chopard honored their nominees, including the RADiUS-TWC’s _ Best Documentary winner 20 Feet fro
Page: HOUSE_OVERSIGHT_010721 →Entities connected to both Sarah Kellen and Morton

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSONLarry Visoski
PERSON
Bradley Edwards
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Scarola
PERSONBruce E. Reinhart
PERSON
United States
LOCATION
George W. Bush
PERSON
Lake Worth
LOCATIONRichard Horace Willits
PERSONJack Patrick Hill
PERSONMichael J. Pike
PERSON