Epstein Secrets

ment ¶ 25d). Scheduling Massage Appointments "[S]ometimes Sarah [Kellen] would be ... in New York and scheduled [Accuser-4] to come and work, but Sarah Kellen's primary role was to schedule ... [Accuser-4] to come and perform the massages." (Ex. C at 25:2-6). "[O]n or about April 23th, 2004, Defendant Sar

Accuser-4 is identified in the S2 Indictment as Minor Victim-4. EFTA00103762 at the time, Sarah Kellen, facilitated her sexual abuse, and it was Kellen or Epstein himself—not Ms. Maxwell—who purportedly called her to schedule massage appointments, sent her gifts, and encouraged her to recruit other

RETRIAL MOTIONS RELATING TO THE S2 SUPERSEDING INDICTMENT Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 150 East 10th Avenue Denver, Colorado 80203 Phone: Bobbi C. Stemheim Law Offices of Bobbi C.

rd Avenue New York, NY 10022 Phone: Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C

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

week while running his company. Borgerson declined to comment on his relationship with Maxwell when contacted by the Daily Mail. Maxwell's lawyer, Jeff Pagliuca, has not responded to requests for an interview with her by the news outlet. Jeffrey Epstein's Curious Ties to His Brother's Real-Estate Business N

tacted by the Daily Mail. Maxwell's lawyer, Jeff Pagliuca, has not responded to requests for an interview w

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

week while running his company. Borgerson declined to comment on his relationship with Maxwell when contacted by the Daily Mail. Maxwell's lawyer, Jeff Pagliuca, has not responded to requests for an interview with her by the news outlet. II EFTA00094398 SDNY News Clips, Wednesday, August 14, 2019 Jeffrey

tacted by the Daily Mail. Maxwell's lawyer, Jeff Pagliuca, has not responded to requests for an interview w

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

week while running his company. Borgerson declined to comment on his relationship with Maxwell when contacted by the Daily Mail. Maxwell's lawyer, Jeff Pagliuca, has not responded to requests for an interview with her by the news outlet. Jeffrey Epstein's Curious Ties to His Brother's Real-Estate Business N

tacted by the Daily Mail. Maxwell's lawyer, Jeff Pagliuca, has not responded to requests for an interview w

ed of supplying young girls for him to abuse face probe as it's revealed Ghislaine Maxwell moved house 36 times in a year before she was caught • Sara Kellen, Adriana Ross, Lesley Groff and Nadia Marcinkova are under investigation for their role in Epstein's sex-trafficking ring, according to reports •

involved in a sexual relationship with the financier. 2/11 EFTA00075159 CaseastcS04014310ttenElDbdthileat7107g412CF 0:Oe' :1413 /20g€Fe58209161 Kellen worked as an assistant for Jefferey Epstein and was named in his 2008 plea agreement as 'potential co-conspirators' Nada Marcinkova who now goes by

on' by law enforcement, Cohen claimed her phone had been hacked and she had to preserve the phone as evidence. MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mark Cohen. In their filings to the court Maxwell's lawyers had argued that she is at increased risk o

. MAXWELL'S LEGAL TEAM: Pictured l-r: Jeffrey S. Pagliuca,Christian R Everdell, Laura A. Menninger and Mar

levant and harassing questions Plaintiff posed to her concerning her adult, consensual sexual activities. In other words, depositions of Marcincova, Kellen and Epstein would serve Plaintiff's goal to make a convoluted legal argument, not to actually seek discoverable information. In light of this, the

XWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S RESPONSE IN OPPOSITION TO MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395 Case 1:15-cv-07433-RWS Document 189 Filed 06/06/16 Page 2 of 11 Defendant Ghislaine Maxwell ("Ms.

DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. EFTA00097395

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er. Q. Okay. Do you remember the photographs? MR. PAGLIUCA: Object to form and foundation. THE WITNESS: Not

which is the same argument we had yesterday. So in my view, your Honor, that leaves the bifurcated trial motion, which has been fully briefed, the Kellen and Marcinkova issue, and the police report issue. So by my count, we have those thr I also have on my calendar that our motion to preclude -- or t

GAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (2

EMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT

RSIGHT_011433 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: Ex

that was at page 288 and thereabouts. At page 387: I witnessed the same thing -- all the girls did -- the same thing I had to do was go and report to Sarah Kellen, Leslie Groff, and Ghislaine Maxwell. Ghislaine was the main lady. So again, we have an allegation by our client that Ms. Maxwell was a part of a l

: In reply, your Honor, I think you can just see from the upset there what's going to be happening at this trial. This is the direct quote from Mr. Pagliuca. "Fantastical conspiracy". That's going to be the argument from the other side. They're obviously entitled to advance that argument. But that's wh

l Scott E. Kalb Anatole Kaletsky Paul-Bernhard Kellen Ajay Kalsi Baba N. Kalyani Abdullah Saleh Kem

aasschen Gregory R. Page Reed Paget Stephen G. Pagliuca Dinesh C. Paliwal Mark Palmer Marco Panara Vi