Epstein Secrets

ric examination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV -80811 ), as to time, subject m

xamination in C.M.A. v. Jeffrey Epstein and Sarah Kellen (Case No. 08- CIV -80811 ), as to time, subject m

fendant's state plea conference of June 30, 2009, Palm Beach Circuit Court Judge Deborah Dale Pucillio explicitly instructe

Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at Epstein's mansion, the underage victim would be introduced to Sarah Kellen, Epstein's assistant, who gathered the girl's personal information, including her name and telephone number. Ms. Kellen would then bring the girl u

would be introduced to Sarah Kellen, Epstein's assistant, who gathered 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 furnishings. There were photograph

ng criminal action derived from the same underlying allegations. See 18 U.S.C. § 3509(k). Discussion The parallel state criminal action pending in Palm Beach Circuit Court is still in the discovery phase. State of Florida v. Jeffi-ey Epstein, Case No. 2006 CF 09454 AXX (Fifteenth Judicial Circuit, Palm Beach County).

r Florida, he is, in fact, a citizen of the U.S. Virgin Islands. (Epstein All. Ex. A.)4 (c) Contrary to the allegations in the Complaint, Defendant Sarah Kellen is a citizen of New York, not Florida. (Kellen Stmt. Ex. B.) 4. This Notice satisfies the procedural requirements of 28 U.S.C. § 1446. First, in

the allegations in the Complaint, Defendant Sarah Kellen is a citizen of New York, not Florida. (Kellen S

s original jurisdiction over this action pursuant to 28 U.S.C. § 1332(a)(1). WHEREFORE, the defendants, Jeffrey Epstein and remove this case from Palm Beach Circuit Court to the United States District Court for the Southern District of Florida. Respectfully submitted, LEWIS TEIN, P.L. 3059 Grand Avenue, Suite 340

information about Epstein's organization for procuring young girls was also blocked because Epstein's co-conspirators took the Fifth. Deposition of Sarah Kellen, March 24, 2010 (hereinafter "Kellen Depo.") (Deposition attachment #14); Deposition of Nadia Marcinkova, April 13, 2010, (Deposition attachment #9)

FBI. Epstein also threatened and harassed Sarah Kellen against cooperating against him as well. 21. Ed

Epstein became a convicted sex offender, he was not to have contact with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly stated that her no-co

l Stuart said the depanty In the odorant sentences was arse/ The USW Saws Moneys Oda dee *dyed not lo charge any ol Eolith's possible co-compmica • Sarah Kellen, Actlans Rom Lesley Groff end Nada Misrartove The agreement was negotiated In pert by New York howywegm ezignInal deem. Quemoy Geoid Larogn on Its

ment that lets Epstein and co-conspirators Sarah Kellen, Adrian& Ross, Lesley Groff and Nadia Marcinkova

2005. Plea bargain The appellate case stems from a decision by federal prosecutors not to charge Epstein if he pleaded guilty to state charges in Palm Beach Circuit Court for soliciting an underage girl for prostitution. He was sentenced to 18 months in jail and house arrest. Epstein moved back to New York City from