Epstein Secrets

[email protected] Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

brucereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore J. Leopold, Esq. Spencer T. Kuvin, Esq

R. 26.1 K (also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (

s scheme, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino

me, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino

ain discovery that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S

in presented, of no consequence. This is based on Plaintiffs’ representation that Jane Doe’s deposition lasted 8 hours. 2 2 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 exchange f

n lasted 8 hours. 2 2 help of his assistant Sarah Kellen, allegedly lured economically disadvantaged mino

ble under the circumstances and result in prejudice to Epstein by denying him the opportunity to obtain discovery that is central to his defense. See Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D. W.Va. 2009)(granting the defendant an additional one day of 7 hours to depose the plaintiff, rea

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

ne Doe No. 4's deposition. 15. Although the Court waived the seven hour time limit in S.D. Fla. L.R. 26.1 K (also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076 (S.D.W.Va. 2009) is illustrative and supports Epstein's request for additional time to depose Plaint

Subject: Re: To: "Jeffrey Epstein" jeevacationiagmail.com> From: Sent Sunday, November 6, 2011 6:12:43 PM 1. Will come to Paris on Thu and ask Sarah for specific time 2. Will contact Osborne and Burda to meet them in London From: Jeffrey Epstein [email protected]> Date: Sun, 6 Nov 2011 19:0

vacationiagmail.com> From: Sent Sunday, November 6, 2011 6:12:43 PM 1. Will come to Paris on Thu and ask Sarah for specific time 2. Will contact Osborne and Burda to meet them in London From: Jeffrey Epstein [email protected]> Date: Sun, 6 Nov 2011 19:09:07 +0100 To: Cc: Subject: Re: ok, con