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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
its criminal prosecution against EPSTEIN. EPSTEIN entered into a Non-Prosecution Agreement ("NPA") with United States Attorney General's Office for the Federal Southern District of Florida. The terms and conditions of the NPA also entailed EPSTEIN entering into a Plea Agreement with the State Attorney's Office, Palm Beach C
or around 2004-2005, when the girls in question were approximately 16 years of age. As part of this scheme, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor girls to his homes in Palm beach, New York and St. Thomas, with the promise of money in EFTA00222
e, Epstein, with the help of his assistant Sarah Kellen, allegedly lured economically disadvantaged minor
tion of 18 U.S.C. §2422 (Count III). In 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution agains
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,
I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Prosecution Agreement with the United States Attorney's Office (USAO) for the Federal Southern District of Florida. The terms and conditions of the Non- Prosecution Agreement also entailed the entering of a Plea Agreement with the State Attorney's Offi
! !24 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRA/JOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, Defendant. Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On Parallel Civil And Criminal Proceedinas
. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, Defendant. Jeffrey Epstein's Motio
I represented Mr. EPSTEIN in the negotiation of and entering into a Non-Prosecution Agreement with the United States Attorney's Office (USAO) for the Federal Southern District of Florida. The terms and conditions of the Non- Prosecution Agreement also entailed the entering of a Plea Agreement with the State Attorney's Offi
Page 5 2009 U.S. Dist. LEXIS 139535, * For Sarah Kellen, Defendant (9:09-cv-80469-KAM): Bruce Reinhart, LEAD ATTORNEY, Bruce E. Reinhart, P.A., West Palm Beach, FL; Denise Kalland, Denise Kalland, P.A.,
age 5 2009 U.S. Dist. LEXIS 139535, * For Sarah Kellen, Defendant (9:09-cv-80469-KAM): Bruce Reinhart, L
tion of 18 U.S.C. §2422 (Count III). In 2008, Epstein entered into a Non-Prosecution Agreement with the United States Attorney General's Office for the Federal Southern District of Florida and the State Attorney's Office for Palm Beach County. Under the terms of the Non-Prosecution Agreement, any criminal prosecution agains
Entities connected to both Sarah Kellen and the Federal Southern District

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSON
Alan Dershowitz
PERSONBruce E. Reinhart
PERSON
United States
LOCATIONMichael J. Pike
PERSON
George W. Bush
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSON
Adam D. Horowitz
PERSONIsidro Manuel Garcia
PERSONSpencer Kuvin
PERSONMermelstein & Horowitz
ORGANIZATIONthe Southern District
LOCATION