Epstein Secrets

s in Florida state court, in exchange for a federal Non-Prosecution Agreement ("NPA") providing him and his co-conspirators (including Lesley Groff, Sarah 48 EFTA00162005 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from

ding him and his co-conspirators (including Lesley Groff, Sarah 48 EFTA00162005 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecution for extensive federal sex-trafficking charges in Florida. The deal incl

ed the allegations underlying the NPA and to varying degrees detailed the involvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. 195. The names of these women and other alleged co-conspirators were 49 EFTA00162006 Case 1:22-cv-10018-JSR Document 42

ther Class Members. 313. This action has been brought and may properly be maintained as a class action against Deutsche Bank pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is readily and easily ascertainable from D

onship grew closer as the years went on. In fact, during the criminal investigation into Epstein in 2005, Staley flew on Epstein's plane along with Sarah Kellen and Nadia Marcinkova, individuals who had bank accounts through Epstein at JP Morgan and who were publicly identified as Epstein's co-conspirators

ailed the involvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. Some articles reported that Kellen and Marcinkova had invoked their Fifth Amendment right against self-incrimination. 212. Additionally, press reports during this time noted allegati

e other Class members. 284. This action has been brought and may properly be maintained as a class action against JP Morgan pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is easily ascertainable from JP Morgan's r

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

76 2015 U.S. Dist. LEXIS 87203, * already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation

861 Thm P-007785 File folder entitled "EPSTEIN/KELLEN CELL PHONE RECORDS" containing documents receiv

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic