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olved the exact same crimes and same evidence being reviewed by the U.S. Attorney's office when he was employed there. Specifically, he represented Sarah Kellen (Epstein's number one co-conspirator who was actually named as such in the WA), his housekeeper (Louel la Ruboyo), his pilots Larry Morrison, Larry
wn hair, and approximately 5'5" to 5'6" tall. WAIMOstated that SARAH KELLEN, another of EPSTEIN's assistants, or EPSTEIN would usually contact her. KELLEN would telephone and ask if she was available or if she had any other ufluiscioeut, 08/07/2007 a West Palm Beach, Florida Filet 31E-MM-108062
ing, provided the following additional or clarifying information not previously documented in earlier FD-302s: JEFFREY EPSTEIN and his assistants, SARAH and -(identified as SARAH KELLEN and allaa) would contact WINIkto set up a pointments for EPSTEIN's massages. According to way, would call and
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe tha
in's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at the building. Former Israeli prime minister Ehud Barak, who was photographed outside Jeffrey's tow
tein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at
ent of an unfavorable verdict and will face them if and when a trial so results." Donziger called the charges "an act of Trump-style retribution" by Kaplan in an Aug. 1 tweet. Frisch, who runs his own firm, said a follow-up conference was set for late September but declined to comment on the case gener
tein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at
in's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at the building. Former Israeli prime minister Ehud Barak, who was photographed outside Jeffrey's tow
and his law firm Donziger Law were ordered in July to pay Chevron $3.4 million in attorneys' fees after Lewis agreed to hold him in civil contempt. Kaplan's appointment of the Seward & Kissel lawyers as special prosecutors isn't without precedent. A special prosecutor was appointed to investigate the l
in's alleged victims has claimed she was forced to have sex with Brunel.) Two other potential Jeffrey Epstein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at the building. Former Israeli prime minister Ehud Barak, who was photographed outside Jeffrey's tow
tein co- conspirators, Nadia Marcinkova and Sarah Kellen, both operated businesses that were registered at
m Donziger Law were ordered in July to pay Chevron $3.4 million in attorneys' EFTA00094383 fees after Lewis agreed to hold him in civil contempt. Kaplan's appointment of the Seward & Kissel lawyers as special prosecutors isn't without precedent. A special prosecutor was appointed to investigate the l
d 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, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Joseph berg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S
d 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, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
) 294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S.
d 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, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
) 294 United States v. Jones, 482 F.3d 60 (2d Cir. 2006) 259 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) passim United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 182 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 294 United States v. Kidd, 386 F. Supp.3d 364 (S.
d 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, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
ed States v. Jones, 482 F.3d 60 (2d Cir. 2006) 169 United States v. Josephberg, 459 F.3d 350 (2d Cir. 2006) 169, 170, 172, 173 United States v. Kaplan, 758 F. App'x 34 (2d Cir. 2018) 121 United States v. Kenny, 883 F. Supp. 869 (E.D.N.Y. 1995) 202 United States v. Kidd, 386 F. Supp.3d 364 (S.
not use non-public Government information for any purpose. 14. After opening my private practice on January 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of action to which the United States was not a party. At a later time, I was retained to represent seve
nuary 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of ac
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan ! DaintlerChrysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could beli
Entities connected to both Sarah Kellen and Kaplan

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
Marc Rich
PERSONJane Doe
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONLarry Visoski
PERSONNadia Marcinkova
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
United States
LOCATION
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONLeon Black
PERSON
Virginia Giuffre
PERSONScott Rothstein
PERSON
Richard Kahn
PERSON
Department of Justice
ORGANIZATION