Epstein Secrets

1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (2) In or around 2001, Defendant SARAH ICELLEN led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001

in exchange for posing for nude photographs. (13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that auJant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane 1.J1 Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who w

alto Shapiro United States, 335 U.S. 1, 19, 68 S.Ct. 6, 1385, 92 L.Ed. 1787 (1948) (following rule of construction of Mike). More recently, in Kastigar, the Court up- held the constitutionality of 18 U.S.C. 6002 on the ground that use immunity "is coextensive with the scope of the privi- lege again

certain charges pending in Alabama. Be cause it disputed the very existence of a grant of immunity, the government object- ed to the holding of a Kastigar hearing as unwarranted. Faced with this disputed claim of an un- written grant of immunity, the magistrate did not hold a traditional Kastigar hea

U.S.C. §2422, along with pre-2006 amended text. See Exhibit B hereto - copy of Plaintiff's Second Amended Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's plan and scheme (which) reflected a particular pattern and method" in the alleged recruiting of girl

ed Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p

the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administra

U.S.C. §2422, along with pre-2006 amended text. See Exhibit B hereto - copy of Plaintiff's Second Amended Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's plan and scheme (which) reflected a particular pattern and method" in the alleged recruiting of girl

ed Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p

the validity of a claim of privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can be asserted in any proceeding, civil or criminal, administra

led calls. Robson and Miller's telephone records have been subpoenaed and analyzed. They show a large number of calls between their cell phones and Sarah Kellen's cell phone and Epstein's house in Palm Beach. Their records also show calls to other girls who they are known to have brought to Epstein's house.

MONY AND THE REQUESTED IMMUNITY. The most difficult part of this prosecution will be proving the knowledge and intent of the targets. For example, Kellen could assert that she knew that she was setting up massages for Epstein, but she believed that they were regular massages. All of the targets are li

ividuals. They are, however, similarly situated, so I have joined both requests for immunity in this memorandum. -1- EFTA00190247 proffer with a "Kastigar letter" or testifying before the grand jury with a "pocket immunity" letter. Both witnesses are represented by counsel. Miller is an openly hostile

Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on thei

faiia Gerald Lefcourt Letter that he cannot accept service for Eric Gany 8/28/2007 A. Marie Villafaiia Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on their behalf 8/30/2007 Jeff Sloman, Andrew Laurie, Drew Oosterbaan, John McMillan, Karen Atkinson

in employees — Janusz Banasiak Both initially asked for immunity. After speaking with Banasiak's attorney, r. anasi was satisfied with a standard Kastigar letter, but Ms. Mucinska's attorney was insistent on formal immunity, and as noted above, so was Individual #28. I don't believe that, prior to thi

WOW' provided the following additional or clarifying information not previously documented in earlier FD-302s: JEFFREY EPSTEIN and his assistants, SARAH and -(identified as and would contact ma to set up appo intments for EPS EIN's massages. According to was would call and say that EPSTEIN was

imony solely as, a victim/witness. During our last conversation regarding Ms. , you indicated that she was unwilling to speak with us pursuant to a Kastigar letter and that she also was unwilling to speak with.the grand jury and intends to invoke the Fifth Amendment if questioned. Please confer with her

estigation named "Operation Leap Year." II. BACKGROUND Operation Lea Year involves the investi ation of Jeff E stein and five of his assistants, Kellen, , and The targets would arrange "sexual massages" for Epstein when he wou travel to a m eac or Mi rk, and many of those "sexual massages" were pe

No. 08-80736-CV-MARRA EXHIBIT B-130 P-008365 EFTA00225363 has been approached by the FBI to provide information via an informal proffer with a "Kastigar letter" or testifying before t djury with a "pocket immunity" letter. is represented by counsel in New York. has never spoken to any law enforceme