Epstein Secrets

D described her as a very pretty Hispanic female in her early twenties, with long brown hair, and approximately 5'5" to 5'6" tall. WILD stated 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

wn hair, and approximately 5'5" to 5'6" tall. WILD stated 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 Investigation on 08/07/2007 a: West Palm Beach, Florida Rica 31E-MM-108062

WILD provided the following additional or clarifying information not previously documented in earlier FD-302s: JEFFREY EPSTEIN and his assistants, SARAH and ADRIANA(identified as SARAH KELLEN and ADRIANA MUCINSKA) would contact WILD to set up appointments for EPSTEIN's massages. According to WILD,

S [5][6] Despite a grand jury's vaunted right to every man's evidence, it must, nev- ertheless, vesper a valid claim of privilege. United States . Calandra, 414 U.S. 338, 346, 94 S.Ct. 13, 38 L.Ed.2d 561 (1974). But the party who invokes the privilege bears the burden of establishing that it ap- plies

ree computers were his private papers. As set forth in the Recarey Declaration, one of the computers was in an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act of production doctrine would not have protected Epstein from producing the computers if they had rem

n an area that appears to be the office of Sarah Kellen and another was in the pool cabana. 4. The act o

its operation generally is unrestrained by the technical procedural and evidentiary rules governing the conduct of criminal trials." United States I Calandra , 414 U.S. 338, 343 (1974). Courts are "mindful of the policy that `nowhere is the public's claim to each person's evidence stronger than in the con

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

351 F. Supp. 121 (S.D.N.Y. 2004) 243 United States v. Butler, No. 04 Cr. 340, 2004 WL 2274751 (S.D.N.Y. Oct. 7, 2004) 208, 211 United States v. Calandra, 414 U.S. 338 (1974) 110 United States v. Caming, 968 F.2d 232 (2d Cir. 1992) 165 xi EFTA00099952 United States v. Campo Flores, No. 15 Cr.

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

351 F. Supp. 121 (S.D.N.Y. 2004) 243 United States v. Butler, No. 04 Cr. 340, 2004 WL 2274751 (S.D.N.Y. Oct. 7, 2004) 208, 211 United States v. Calandra, 414 U.S. 338 (1974) 110 United States v. Caming, 968 F.2d 232 (2d Cir. 1992) 165 xi EFTA00077617 United States v. Campo Flores, No. 15 Cr.

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

351 F. Supp. 121 (S.D.N.Y. 2004) 243 United States v. Butler, No. 04 Cr. 340, 2004 WL 2274751 (S.D.N.Y. Oct. 7, 2004) 208, 211 United States v. Calandra, 414 U.S. 338 (1974) 110 United States v. Caming, 968 F.2d 232 (2d Cir. 1992) 165 xi EFTA00039432 United States v. Campo Flores, No. 15 Cr.

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

21 (S.D.N.Y. 2004) 160 EFTA00095077 United States v. Butler, No. 04 Cr. 340, 2004 WL 2274751 (S.D.N.Y. Oct. 7, 2004) 139, 141 United States v. Calandra, 414 U.S. 338 (1974) 78 United States v. Caming, 968 F.2d 232 (2d Cir. 1992) 112 United States v. Campo Flores, 15 Cr. 765 (PAC), 2016 WL 5946

Tapes or transcripts of any and all proceedings before the Grand Jury on Wednesday, July 19, 2006, referring or relating to Jeffrey Epstein and/or Sarah Kellen, including but not limited to witness testimony, statements made by any member of the State Attorney's Office, and instructions given by any member

rring or relating to Jeffrey Epstein and/or Sarah Kellen, including but not limited to witness testimony,

ng its investigation. See United States v. R. Enters., Inc.. 498 U.S. 292. 297-98, Ill S.Ct. 722, 726, 112 L.Ed.2d 795 (1991); United States v. Calandra, 414 U.S. 338, 94 S.Ct. 613, 38 L.Ed.2d 561 (1974). "A grand jury investigation 'is not fully carried out until every available clue has been run

United States hereby opposes Epstein's motion and moves for an order to compel the appearance of witnesses and production of the requested items. 'Sarah is one of Epstein's personal assistants. -5- EFTA00179104 ARGUMENT I. THE UNITED STATES DOES NOT OPPOSE THE MOTION TO INTERVENE, IN PART. The

ts operation generally is unrestrained by the technical procedural and evidentiary rules governing the conduct of criminal trials." United States v. Calandra, 414 U.S. 338, 343 -10- EFTA00179109 (1974). Courts are "mindful of the policy that `nowhere is the public's claim to each person's evidence stro