Epstein Secrets

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

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif. v. Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it

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

The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available

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

The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available

OW C.M.A., I I I I Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. $eated FILED UNDER SEAL' DEFENDANTS JEFFREY EPSTEIN AND SARAH KELLEN'S MOTION FOR STAY • This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's Office (by Assist

I I Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. $eated FILED UNDER SEAL' DEFENDA

by the corporations which are defendants in the civil case, the considerations . . . militating against disclosure are beside the point.") (citing Douglas Oil Co. of Calif. v. Petrol Stops Nw., 441 U.S. 211 (1979)). In response to such third-party subpoenas to law-enforcement witnesses, we anticipate that it

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

The Supreme Court has explained that a party seeking disclosure of grand jury materials must make a showing of a "particularized need." Id. (citing Douglas Oil Co. v. Petrol Stops Northwest, 441 U.S. 211, 222 (1979)). Petitioners cannot make such a showing. Moreover, the documents they seek to make available

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,

he invitation and made no submission. The court then entered an order granting the motions to co. quash. Applying the balancing test set forth in Douglas Oil Co. v. Petrol Stops Nonhwest, 441 U.S. 211, 99 S.Ct. 1667. 60 L.Ed.2d 156 (1979), the court found that the government had failed to establish a suffic

ZORRO RANCH RD PAUL VISOSKI. STANLEY, NM 87056-9783 LAWRENCE JR VISOK. LAWRENCE P 1635 SW SILVER PINE WAY APT Fl PALM CITY, FL 34990-4732 4: KELLEN, SARAH L 27 HIGH TECH BLVD 241-53-XXXX 5/1979 BONK, SARAH L THOMASVILLE, NC 27360- VICKERS, SARAH 5560 KENSINGTON, SARAH BINK. SARAH 92 GREE

F.3d at 1347. "The district court has 'substantial discretion' in determining whether grand jury materials should be released." Id. at 1349 (quoting Douglas Oil Co. v. Petrol Stops N.W., 441 U.S. 211, 223, 99 S. Ct. 1667, 60 L. Ed. 2d 156 (1979)). For internal use only SDNY_GM_00059572 CONFIDENTIAL - PURSUANT