Epstein Secrets

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

2005) (recognizing that the CVRA does not require notice of public court proceedings based on violations of state criminal law), and, in any event, AUSA Villafaila provided Petitioners with pre-hearing notice of those state proceeding — in which Epstein pled guilty to state criminal charges — upon the governme

l Stuart said the depanty In the odorant sentences was arse/ The USW Saws Moneys Oda dee *dyed not lo charge any ol Eolith's possible co-compmica • Sarah Kellen, Actlans Rom Lesley Groff end Nada Misrartove The agreement was negotiated In pert by New York howywegm ezignInal deem. Quemoy Geoid Larogn on Its

ment that lets Epstein and co-conspirators Sarah Kellen, Adrian& Ross, Lesley Groff and Nadia Marcinkova

ie Villafana secured pro bono counsel to represent Jane Doe #1. Pro bono counsel was able to assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaila secured pro bono counsel by contacting Meg Garvin, Esq. of the the National Crime Victims' Law Center in Portland, Oregon, which is based in the Le

not use non-public Government information for any purpose. 14. After opening my private practice on January 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of action to which the United States was not a party. At a later time, I was retained to represent seve

nuary 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of ac

tters in approximately June 2007 [Jane Doe #1] and August 2006 [Jane Doe #2) wherein they were advised of this right and given the phone numbers of AUSA Villafaila, FBI Special Agent Kuyrkendall, and the Justice Department's Office for Victims of Crime. The letters specifically advised that if the Petitioners