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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
8 Wall.) 163 (1873) 18 North Carolina v. Pearce, 395 U.S. 711 (1969) 18 United States v. Annabi, 771 F.2d 670 (2d Cir. 1985) United States v. Bortnovsky, passim 820 F.2d 572 (2d Cir. 1987) 22, 23 United States v. Brown, No. 99-1230(L), 2002 WL 34244994 (2d Cir. Apr. 26, 2002) 16 United States v
d 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, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. I at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
tes v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197,199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Borti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United S
d 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, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
es v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United S
d 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, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
es v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 180, 190, 197, 199 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 271 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 266, 267, 274 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 218 United S
d 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, Adriana Ross, Lesley Groff, or Nadia Marcinkova. NPA at 5; Def. Mot. 1 at 20-21. Aside from the reference to "United States" which, as noted abov
s of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova
es v. Bonacorsa, 528 F.2d 1218 (2d Cir. 1976) 120, 127, 133, 135 United States v. Bonventre, 646 F App'x 73 (2d Cir. 2016) 179 United States v. Bortnovsky, 820 F.2d 572 (2d Cir. 1987) 174, 175, 182 United States v. Botti, No. 08 Cr. 230 (CSH), 2009 WL 3157582 (D. Conn. Sept. 25, 2009) 145 United S
Entities connected to both Sarah Kellen and Bortnovsky

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Prince Andrew
PERSON
United States
LOCATION
George W. Bush
PERSONLeon Black
PERSON
Virginia Giuffre
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSONDarren Indyke
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
John F. Kennedy
PERSON
Department of Justice
ORGANIZATION