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to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (215) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, SARAH ICELLEN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (216) On or ab
Section 853. If the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, SARAH a/k/a "Adriana Mucinska," and (1) cannot be located upon the exercise of due diligence; (2) has been transferred or sold to, or deposited with a
exchange for posing for nude photographs. (13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane,Doe #2, who was th
ts. In addition to the well-established state restitution statute, the defense offered a federal proposal that was similar to the resolution in the Boehm case, where the conduct was far more egregious. There, the defendant bought and distributed crack cocaine and cocaine to underage girls; admitted t
Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on thei
faiia Gerald Lefcourt Letter that he cannot accept service for Eric Gany 8/28/2007 A. Marie Villafaiia Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on their behalf 8/30/2007 Jeff Sloman, Andrew Laurie, Drew Oosterbaan, John McMillan, Karen Atkinson
e are several emails between myself and Jay Lefkowitz about the appointment of a GAL and the possibility of a restitution trust fund similar to the Boehm case out of Alaska. I obtained the trust fund agreement and spoke with the AUSA in 21 Mandatory restitution under § 3663A requires a conviction for
itation cases was a hot-button issue at the time. The District of Alaska USAO had a multi-victim child exploitation case with a wealthy defendant (Boehm) where they had set up a trust fund with a bank and a trustee. With Drew Oosterbaan's help, I explored setting up a similar situation in the Epstein
13. Epstein’s plan and scheme reflected a particular pattern and method. Upon arrival at Epstein’s mansion, Mr. Robson would introduce each victim to Sarah Kellen, Epstein’s assistant, who pathered the girl’s personal information, including her name and telephone number. Ms. Kellen would then bring the girl up
ntroduce each victim to Sarah Kellen, Epstein’s assistant, who pathered the girl’s personal information, including her name and telephone number. Ms. Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition to other fumishings. There were photographs o
impartial, independent representative be. appointed to administer that fund. Notably, such a restitution fund was created in a federal case, U.S. v. Boehm, Case No. 3:04CR00003 (D. Alaska 2004). The federal prosecutors here rejected this idea, and they insisted that an attorney representative, paid for
ed States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, t
rs of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova.
interest in maintaining their privacy; (6) Experience litigating in federal court in the Southern District of Florida; Your letter references U.& 'Boehm, No. 3:04CR00003 (D. Ala 2004) as a model for a restitution fund statement I asked our prosecutor to contact the AlffiA in that case. In that matter
Entities connected to both Sarah Kellen and Boehm

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
PERSONScott Rothstein
PERSONMichael J. Pike
PERSONRobert C. Josefsberg
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON