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2003, Defendant took nude photographs of Jane Doe #2, who was then a sixteen-year-old girl. 9 EFTA00225224 (12) In or around 2003, Defendant KELLEN made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. . i. (13) In or around 2003, Defendant told Jane Doe #2 tha
ound 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a sixteen-year-old girl. (16) In or around 2003, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. • 4.• (17) On
.• (17) On or about April 23, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. (18) On or about May 2, 2004, Defendant SARAH placed a telephone call to a telephone used by Jane pcie #2. Jane Doe -43 (19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
e Agreement, the SDFL unilaterally proposed to divest its right to select the attorney representative for the victims. Contrary to Messrs. Starr and Whitley's recent assertion that this was "engineered in a way that appears intended to profit particular lawyers in private practice in South Florida with
Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (204) On or about November 18, 2004, Defendants JEFFREY EPSTEIN, SARAH ICEL4N, MI a/k/a ME Elln," and= traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyper
to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (215) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, SARAH KEL and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (216) On or a
e Agreement, the SDFL unilaterally proposed to divest its right to select the attorney representative for the victims. Contrary to Messrs. Starr and Whitley's recent assertion that this was "engineered in a way that appears intended to profit particular lawyers in private practice in South Florida with
r of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova.
victims, the NPA granted federal immunity not only to Epstein, but also to "any potential co-conspirator of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova." It is only because the victims filed this lawsuit, and the District Court ordered the NPA be pro
39, 117 S. Ct. 417, 421, 136 L.Ed.2d 347 (1996) ("We have long held that the 'touchstone of the Fourth Amendment is reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S. 83, 83 S. Ct
Entities connected to both Sarah Kellen and Whitley

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
Kenneth Marra
PERSONJack Scarola
PERSON
United States
LOCATIONBruce E. Reinhart
PERSON
George W. Bush
PERSONRobert C. Josefsberg
PERSONLeon Black
PERSONScott Rothstein
PERSON
Salt Lake City
LOCATIONSpencer Kuvin
PERSON