Epstein Secrets

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

le sex acts" with Accuser-4. (Id. ¶ 9d). (4) The dates when Ms. Maxwell allegedly was "present" when [Accuser-4] "was nude in the massage room of the Palm Beach Residence." (Id. ¶ 9d). 23 EFTA00103784 (5) The dates when, and locations where, Ms. Maxwell allegedly paid Accuser-4 "hundreds of dollars in cash." (Id.

e No. 21. Epstein Page 15 Request No. 15. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes,

ts are implicated. Request No. 7. All surveillance videos, slides, film, videotape, digital recording or other audio or video depiction or image of the Palm Beach Residence. Response: Defendant is asserting specific legal objections to the production request as well as his U.S. constitutional privileges. I intend to pr

U.S.C. §2422, along with pre-2006 amended text. See Exhibit B hereto - copy of Plaintiff's Second Amended Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's plan and scheme (which) reflected a particular pattern and method" in the alleged recruiting of girl

ed Complaint. Plaintiff also alleges that "Sarah Kellen, Epstein's assistant" was a part of "Epstein's p

not identified in response to interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence. No. 3. Identify all persons who came to the Palm Beach Residence and who gave a massage or were asked to give a massage to Defendant. No. 4. Identify all persons who came to the New York Residence and who gave a

No. 2 v. Epstein Page 15 Request No. 15. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes,

OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon

communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes,

No. 2 v. Epstein Page 15 Request No. 15. Any and all documents consisting of, referring or relating to communications between Jeffrey Epstein and Sarah Kellen, including, but not limited to, letters, notes, text messages, messages on social networking sites, and e-mails. Response: Defendant is asserting

OBJECTIONS TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES Interrogatory No. 1. Identify all employees who performed work of services inside the Palm Beach Residence. Answer: Defendant is asserting specific legal objections to the interrogatories as well as his U.S. constitutional privileges. I intend to respon