Epstein Secrets

(3) claim and the § 772.103(4) conspiracy claim, with the additional note that the conspiracy was between Defendant, Jeffrey Epstein, Sarah Kellen, Nadia Marcinkova, and other persons whose identity is, at this time, unknown to Jane Doe. Epstein, Kellen, Marcinkova and others all conspired together to violate t

efendant, Jeffrey Epstein, Sarah Kellen, Nadia Marcinkova, and other persons whose identity is, at this time, unknown to Jane Doe. Epstein, Kellen, Marcinkova and others all conspired together to violate the provisions of § 772.103(3), doing so willfully and with full knowledge of the criminal activities

etween Defendant, Jeffrey Epstein, Sarah Kellen, Nadia Marcinkova, and other persons whose identity is,

as finding more minor girls to satisfy Epstein's criminal sexual appetite. 1 of 10 EFTA00177691 Case 9:08-cv-80893-KAM Document 14-2 Entered on FLSD Docket 10/03/2008 Page 2 of 10 Kellen also served as Epstein's scheduler, scheduling appointments for the minor girls to ostensibly do "work" when in fac

10 reveals that Plaintiff alleges with whom Defendant conspired, stating that he "conspired with others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these acts and to avoid police detection." See ¶ 15. Additionally, Plaintiff sufficiently alleges the identity of the other mino

, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these acts and to avoid polic

others, including his assistants Sarah Kellen and Nadia Marcinkova, to further commit these acts and to

is for the claim. Id. See Ashcroft v. labal 129 S.Ct. 1937, 1950 2 EFTA_R1_00012687 EFTA01734467 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/0312010 Page 3 of 10 (explaining "only a complaint that states a plausible claim for relief survives a motion to dismiss"). Rule 12(e) permits

Special Agents also did not explain that an agreement had already been signed that precluded any prosecution of Epstein's co-conspirators, including Marcinkova who had personally sexually abused Jane Doe I at the direction of Epstein. Because the plea arrangement had already been reached with Epstein, the

on case, telephone interviews with DOJ attorneys atty work-product Page 14 of 14 EFTA00185427 , Case 9:08-cv-80736-KAM Document 329 Entered on FLSD Docket 06/23/2015 Page 1 of 2 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Matthewman JANE DOE #1 AND JANE DOE

irls to his mansion. Epstein's key "lieutenant" in the organization was MI who served as both his scheduler and a recruiter/procurer of the girls. Marcinkova also served as a recruiter and helped Epstein satisfy his criminal sexual desires by, on occasion, directly participating in sexual abuse and prost

ECORD DATE March 19, 2009 FOR 0 rt E USX ONLY AMOUNT lifil6RECEIPT a 7.17(51G9te EFTA00175267 Case 9:09-cv-80469-KAM Document 31 Entered on FLSD Docket 06/01/2009 Page 1 of 11 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CIV- 80469 - MARRA/JOHNSON JANE DOE II, Plaintif