5
Shared Docs
5
Same-Page
10 / 8
Mentions
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
274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 248 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003
create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." Salameh, 152 F.3d at 120 (citations and internal quotation marks omitted). This rule also extends to plea agreements that use the term "United States." See
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
274, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 11 United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 248 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 2003
create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." Salameh, 152 F.3d at 120 (citations and internal quotation marks omitted). This rule also extends to plea agreements that use the term "United States." See
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
182, 190 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 4, 9 United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 163 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 4, 5, 161 xix EFTA00095086 United States v. Salerno, 481 U.S. 739 (1987) 104 United States v. Salmonese, 352 F.
create an affirmative appearance that the agreement contemplated barring districts other than the particular district entering into the agreement." Salameh, 152 F.3d at 120 (citations and internal quotation marks omitted). This rule also extends to plea agreements that use the term "United States." See
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
60 United States v. Lopez, 356 F.3d 463 (2d Cir. 2004) 18, 19, 20 United States v. Rooney, 37 F.3d 847 (2d Cir. 1994) 17, 18 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 14, 16 United States v. Torres, 719 F.2d 549 (2d Cir. 1983) 25 United States v. Van Thournout, 100 F.3d 590 (8th C
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
74, 282 United States v. Russo, 801 F.2d 624 (2d Cir. 1986) 5, 1 I United States v. Rutkoske, 506 F.3d 170 (2d Cir. 2007) 248 United States v. Salameh, 152 F.3d 88 (2d Cir. 1998) 5, 6, 245 United States v. Salerno, 481 U.S. 739 (1987) 151 United States v. Salmonese, 352 F.3d 608 (2d Cir. 200
Entities connected to both Sarah Kellen and Salameh

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
United States
LOCATION
Prince Andrew
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Alexander Acosta
PERSON
A. Marie Villafana
PERSONFBI
ORGANIZATIONMaria Farmer
PERSONDarren Indyke
PERSON