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ot yet obtained Jane Doe #18's telephone records, we were able to identify her telephone number, and there are twenty telephone calls that appear on Sarah Kellen's phone records. All of those calls were outgoing (meaning Kellen called Jane Doe #18.) The telephone calls range in date from August 27, 2003 throu
each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's assistant—usually Kellen—in the kitchen. The assistant normally would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage
ast) because her father, and ste mother have filed a civil suit against Epstein seeking "in excess of 50 million dollars." father is represented by Jeff Herman. father also has been in frequent contact with the journalist at "Vanity Fair" magazine, and, as mentioned in the original pros memo, he has a pri
y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section
recollection that he's 14 15 A. No. 1 6 O. That he's boss? 17 A. No. 18 Q. Does it refresh your memory that he's the 19 ex-partner of Jeff Herman, the first lawyer who sued 20 you -- sued Mr. Epstein on your behalf for fifty million 21 dollars? 22 A. No, sir. I don't know who he is. 23
ve a girl's names and a round dollar amount — usually $200. Banasiak explained that on several occasions when Epstein was "in residence," Epstein or Kellen24 would ask Banasiak ti one of the girls after a g.,e was completed. On other occasions when Epstein and were not in Florida, EMI would call Banasi
Page: EFTA02857524_p28 →erboro, New Jersey to Palm Beach County, Florida, aboard the Gulf by Defendant HYPERION AIR, INC. 131. On or about May 6, 2005, Defendants EPSTEIN, KELLE and traveled from Teterboro, New Jersey to Palm Beach County, Emma, aooara me Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 132. On o
Page: EFTA02857524_p79 →w, at least) because her father, and stepmother have fil a civil suit against Epstein seeking "in excess of 50 million dollars." s represented by Jeff Herman. IMIllfather also has been in frequent contact with the journalist at "Vanity Fair" magazine, and, as mentioned in the original pros memo, he has a
Page: EFTA02857524_p145 →Entities connected to both Sarah Kellen and Jeff Herman

Jeffrey Epstein
PERSON
Lesley Groff
PERSONJane Doe
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
PERSON
A. Marie Villafana
PERSON
Virginia Giuffre
PERSON
Alexander Acosta
PERSONthe Southern District
LOCATION
Palm Beach Police Department
ORGANIZATION
New York
LOCATIONGerald Lefcourt
PERSONRoy Black
PERSON
West Palm Beach
LOCATION