Epstein Secrets

ssage. DICENSO received $200.00 each time she provided EPSTEIN with a massage. She believed GARCIA received the same amount. According to DICENSO, KELLEN may have paid their taxi fare. DICENSO stated that would call her once in a while on her cellphone to see if she vailable to provide a massage.

Palm Beach via a taxi cab. DICENSO believed this occurred during her 10th grade year, while attending Wellington High School. DICENSO stated that SARAH LNU(identified as ans he door and showed the girls around ouse. ven ua ly, took DICENSO and GARCIA upstairs. The girls IIIIII were sitting on

Doe #10 JEFFREY EPSTEIN 27 3/31/2005 R Jane Jane Doe #14 Jane Doe #15 Doe #16 JEFFREY EPSTEIN ng 9 18/2005 Jane Doe #16 JEFFREY EPSTEIN SARAH KELLEN ADRIANA 29 9/29/05 Jane Doe #16 .A JEFFREY EPSTEIN Sta All in violation of Title 18, United States Code, Sections 2423(b) and 2. FORFEITURE

enumerated offenses set forth in Title 18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty plea in Palm Beach County Circuit Court to solicitation of prostitution (Fl. Stat. Section 796.07) and procurement of minors to engage in prostitution (Fl. Stat. Section 796.03) (an offens

of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION Defendant, JEFFREY EPSTEIN, ("EPSTEIN

Count I of Plaintiffs Complaint for failure to state a cause of action. Rule 12(b)(6), Fed.R.Civ.P. (2008). Count II is directed only to Defendant KELLEN, who has not yet been served. In support of dismissal, Defendant states: Plaintiff, CMA, attempts to assert a cause of action against EPSTEIN in Cou

joyment of life. (Plaintiff alleges in her Complaint, ¶2, that she is presently 21 years old. The suit was originally filed in Florida state court, Palm Beach County Circuit Court, on February 21, 2008.) Count I is lacking in sufficient factual allegations to allege the necessary elements to state a cause of action either un

lafatia Gerald Lefcourt Letter that he cannot accept service for Eric Gany 8O8O007 A. Marie Villafatia Nathan Z. Dershowitz Left messages with Sarah Kellen and Nadia Marcinkova to request if he can accept service on their behalf 8/30/2007 Jeff Sloman, Andrew Lourie, Drew Oosterbaan, John McMillan,

Nathan Z. Dershowitz Left messages with Sarah Kellen and Nadia Marcinkova to request if he can accept

etter - 5 pages (CEOS) B-28 3/28/2008 Villafana Danchuk Letter advising of representation of Individual #3 and that a lawsuit has been filed in Palm Beach County Circuit Court B-41 4/1/2008 Jay Lefkowitz Jeffrey Sloman Draft letter regarding termination of agreement Privileged Confidential Page 32 of 51 Contains 6(e)

THERN DISTRICT OF FLORIDA 08-80804-Civ-MARRA/JOHNSON CASE NO.: JANE DOE, a/k/a JANE DOE #1, Plaintiff, vs. JEFFREY EPSTEIN, HALEY ROBSON, and SARAH KELLEN, Defendants. NOTICE OF REMOVAL July 18, 2008 STEVEN M. LARIMORF CLERK D.S. DIST. CT. S.O. OF FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441

stroy diversity jurisdiction, and to prevent any application of 18 § 3509(k), a mandatory stay provision applicable in federal court 2 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

S.O. OF FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein, hereby remove this action' from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this pla

orney ee! R, Alexander Acosta, U.S. Attomey AUSA A. Marie Villafaia HOUSE_OVERSIGHT_012207 Id) 063 TAB 3 HOUSE_OVERSIGHT_012208 TOLL RECORDS OF SARAH KELLEN’S CALLS e MR. EPSTEIN DID NOT KNOW WHO WOULD BE COMING TO GIVE HIM A MASSAGE. Wednesday, April 27, 2005 Wednesday, April 27, 2005 Wednesday, April

3 HOUSE_OVERSIGHT_012208 TOLL RECORDS OF SARAH KELLEN’S CALLS e MR. EPSTEIN DID NOT KNOW WHO WOULD BE

e enumerated offenses set forth in Title 18, United States Code, Section 2255. Specifically, the Agreement mandates, inter alia, (1) a guilty plea in Palm Beach County Circuit Court to solicitation of prostitution (F1. Stat. Section 796.07) and procurement of minors to engage in prostitution (FI. Stat. Section 796.03) (an offense

Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on thei

faiia Gerald Lefcourt Letter that he cannot accept service for Eric Gany 8/28/2007 A. Marie Villafaiia Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on their behalf 8/30/2007 Jeff Sloman, Andrew Laurie, Drew Oosterbaan, John McMillan, Karen Atkinson

tter - 5 pages (CEOS) B-28 3/28/2008 Villafalia Danchuk Letter advising of representation of Individual #3 and that a lawsuit has been filed in Palm Beach County Circuit Court B-41 4/1/2008 Jay Lefkowitz Jeffrey Sloman Draft letter regarding termination of agreement Privileged Confidential Page 32 of 51 Contains 6(c)

prosecutors to approve warrants to arrest Epstein on four counts of unlawful sexu.al actiyity witl_l a minor .a11d to ch~rge his person41 a~sistant, Sarah Kellen, n·ow 27, for her alleged role in arranging the visits. Police officials also wanted to charge Robson, the self.:describe·d.Heidi Pleiss, with lewd

irls told similar stories. In most accounts, Epstein’s personal assistant at the time, Sarah Kellen, now 27, escorted the girls to Epstein’s bedroom. Kellen, whose most recent known’ address is in North Carolina, has not been charged in the case. Palm Beach police often conducted surveillance ofEpstein’s

th Epstein, Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein’s agreement to settle lawsuits filed a

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

FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein, and , hereby remove this action' from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this pla

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

FLA. • MIAMI In accordance with 28 U.S.C. §§ 1441, 1446, and 1332(a)(1), the defendants, Jeffrey Epstein, , and hereby remove this action) from Palm Beach County Circuit Court to the United States District Court for the Southern District of Florida, and respectfully state as follows: Introduction Six months ago, this pla