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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
nner v. City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11i° Cir. 1981) (en bane), the Eleventh Circuit adopted as binding precedent the decisions of the Fifth Circuit rendered prior to October 1, 1981. 3 EFTA_R1_00012688 EFTA01734468 Case 9:08-cv-80893-KAM Document 125 Entered on FLSD Docket 03/0312010 Page
33 10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 131 H3vlgiu2 THE COURT: What's next? MR. CASSELL: The motion on Kellen and Marcinkova, our motion to get in adverse inferenc THI Gi COURT: Yes. MR. CASSELL: If I can be heard on that, your Honor. THI ES COURT: Excuse me. Let me
ese two have been difficult to reach by subpoena, that's why we've taken their deposition. And so Mr. Epstein will testify live, he would invoke, Nadia Marcinkova and Sarah Kellen, the deposition has already been taken. And in our —- THI Gl COURT: What do you do about the statement that counsel just made a
Mr. Epstein will testify live, he would invoke, Nadia Marcinkova and Sarah Kellen, the deposition has a
of Maryland. That's a Fifth Circuit case from 1995, in which a bank officer was accused of dishonest and fraudulent acts and kind of bogus loans, and the Fifth Circuit allowed, Fifth Amendment invocations from the loan recipients to be used against him, reasoning that, well, in this kind of a case, the collusion t
idence. Another female, named Natasha, Natalia or Nadia LNU, who was described as tall with straight bro
e Constitution. Even in the case of In re Dean, 527 F.3d 391 (5th Cir. 2008), upon which the plaintiffs rely, the district court, after remand from the Fifth Circuit, denied the motion of the victims to invalidate the defendant's plea agreement as a remedy for the claimed violation of the Crime Victims' Rights A
Entities connected to both Nadia Marcinkova and the Fifth Circuit

Jeffrey Epstein
PERSON
Sarah Kellen
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONJane Doe
PERSON
Kenneth Marra
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Alan Dershowitz
PERSONJack Goldberger
PERSON
Lesley Groff
PERSON
Marc Rich
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
A. Marie Villafana
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON