Epstein Secrets

r as the years went on. In fact, during the criminal investigation into Epstein in 2005, Staley flew on Epstein's plane along with Sarah Kellen and Nadia Marcinkova, individuals who had bank accounts through Epstein at JP Morgan and who were publicly identified as Epstein's co-conspirators in trafficking offens

nvolvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. Some articles reported that Kellen and Marcinkova had invoked their Fifth Amendment right against self-incrimination. 212. Additionally, press reports during this time noted allegations that Epste

w on Epstein's plane along with Sarah Kellen and Nadia Marcinkova, individuals who had bank accounts th

e other Class members. 284. This action has been brought and may properly be maintained as a class action against JP Morgan pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is easily ascertainable from JP Morgan's r

s underlying the NPA and to varying degrees detailed the involvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. 195. The names of these women and other alleged co-conspirators were 49 EFTA00162006 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 50

3 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecution for exte

1/13/23 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecuti

ther Class Members. 313. This action has been brought and may properly be maintained as a class action against Deutsche Bank pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is readily and easily ascertainable from D

elephone/flight/grand jury information for Contains information and Anticipation of Litigation; Improper P-003545 a number of victim/witnesses, Nadia documents subject to Invocation; Overriding Need; Claims Against Marcinkova, and Adriana Mucinska investigative privilege. Public Prosecutor, At

ipation of Litigation; Improper P-003545 a number of victim/witnesses, Nadia documents subject to Invocation; Overriding Need; Claims Against Marcinkova, and Adriana Mucinska investigative privilege. Public Prosecutor, Attorney Conduct at Issue; Also contains information and documents subject to

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

servations. or bookings rifler issuance shall constitute a consent to the above, and an °ottoman! on his her pad to convey the contents Introit" lo Nadia travel companions or group mondwro. 13 Proof of kkinlity niqu tad a,i inlarnalronal naval Wirhuirl prows litonlilosillonai pm. podium m.‘earwry

orcement proceeding because it is not a "civil action" against the Government. To be sure, this Court has determined that convenience dictates that the Federal Rules of Civil Procedure "govern the general course of this proceeding." See DE 257 at 3. But that procedural determination does not alter the substance of this ca