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paid contractors, and representing the businesses of women in Epstein's circle. In 2012, he signed corporation paperwork for the design business of Sarah Kellen, an alleged co-conspirator of Epstein whom Palm Beach cops were ready to charge in their 2006 probe. (Kellen was a named accomplice in Epstein's 20
rwork for the design business of Sarah Kellen, an alleged co-conspirator of Epstein whom Palm Beach cops were ready to charge in their 2006 probe. (Kellen was a named accomplice in Epstein's 2008 plea deal, which shielded her from prosecution.) EFTA01654943 As The Daily Beast has previously revealed
e the federal judge overseeing the case and indicated Indyke would be deposed "in both his personal capacity and as a co- EFTA01654941 executor of the Epstein Estate," and would "offer extremely relevant testimony" relating to her claims. "Indeed, we have reason to believe he has firsthand knowledge of Jeffrey
onship grew closer as the years went on. In fact, during the criminal investigation into Epstein in 2005, Staley flew on Epstein's plane along with Sarah Kellen and Nadia Marcinkova, individuals who had bank accounts through Epstein at JP Morgan and who were publicly identified as Epstein's co-conspirators
ailed the involvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. Some articles reported that Kellen and Marcinkova had invoked their Fifth Amendment right against self-incrimination. 212. Additionally, press reports during this time noted allegati
19-JSR Document 36 Filed 01/13/23 Page 72 of 130 and the identities of the individual Class members are ascertainable through records maintained by the Epstein Estate and JP Morgan, including but not limited to JP Morgan's records for Epstein-related accounts (e.g., account ledgers reflecting payments from Epstei
benefitted 107 EFTA00162227 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Acting through its officers and employees (including Staley), JP Morgan itself directly committed and pe
ally include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Actin
of Epstein's Enterprise, including the receiving and sending money to other entities they held. 117. Since they were appointed as Co-Executors of the Epstein Estate in 2019, Defendants Indyke and Kahn have approved the release of Estate funds to pay for the legal fees and costs of persons who—like the Co-Execut
Entities connected to both Sarah Kellen and the Epstein Estate

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONLarry Visoski
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
Richard Kahn
PERSONLeon Black
PERSON
Virginia Giuffre
PERSONDarren Indyke
PERSONJanusz Banasiak
PERSON
Palm Beach
LOCATIONMaria Farmer
PERSONthe Southern District
LOCATION
Bella Klein
PERSON