5
Shared Docs
5
Same-Page
10 / 5
Mentions
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
st levied her accusations more than a decade ago. The Palm Beach FBI and the United States Attorney's Office for the Southern District of Florida ("USAO-SDFL") interviewed Accuser-4 in or around 2007 during their three- year investigation of Epstein's alleged sexual abuse (the "Florida Investigation"). And
ed 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, Adrian& Ross, Lesley Groff, or Nadia Mareinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office,
rs of Epstein, including but not limited to Sarah Kellen, Adrian& Ross, Lesley Groff, or Nadia Mareinkova
mber 24, 2007, after a year-long investigation, the Department of Justice, through the United States Attorney for the Southern District of Florida ("USAO-SDFL"), entered into the NPA with Mr. Epstein. The NPA immunized Mr. Epstein from five distinct potential federal charges that "may have been committed
to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants
have limited the USAO-SDFL' s capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants
have limited the USAO-SDFL' s capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
B AD Plaintiff, VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. . 91 c. C AMENDED COMPLAINT 61
have limited the USAO-SDFL's capacity to prosecute Epstein in the Southern District of Florida for his federal offenses against Petitioners,17 the USAO-SDFL did not bargain away the possibility of federal criminal charges being instituted in other districts based on the alleged sexual acts that Epstein c
Entities connected to both Sarah Kellen and USAO-SDFL

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Prince Andrew
PERSON
Alan Dershowitz
PERSONMichael J. Pike
PERSON
George W. Bush
PERSON
Salt Lake City
LOCATIONLeon Black
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Virginia Giuffre
PERSONMaria Farmer
PERSON
Alexander Acosta
PERSON