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OW C.M.A., I I I I Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. $eated FILED UNDER SEAL' DEFENDANTS JEFFREY EPSTEIN AND SARAH KELLEN'S MOTION FOR STAY • This motion is filed under seal because the deferred-prosecution agreement between the United States Attorney's Office (by Assist
I I Plaintiff, vs. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. $eated FILED UNDER SEAL' DEFENDA
In October 2007, shortly after the agreement was signed, four victims were contacted and these provisions were discussed. One of those victims was C.W. who at the time was not represented, and she was given notice of the agreement. Notice was also provided of an expected change of plea in October 2
ss Specialist. Attached hereto are copies of the letters provided to Bradley Edwards' three clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex. 11. Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she was interviewed (Ex. 2).2
ael Tein Right now I am digesting something filed in a new federal civil lawsuit against Epstein. Bruce Reinhart is listed as counsel of record for Sarah Kellen, and a deposition transcript attached to the removal petition includes questions from Mike Tein to G. implying that Jeff and I both went to her ho
each of the agreement and we intend to proceed. We may want to use that opportunity to put them on notice that Bruce Reinhart cannot represent Ms. Kellen in connection with the criminal litigation. A. Marie Villafana Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 33401
their position makes it impossible for Mr. Epstein to fully perform his contractual obligations and that, coupled with Mr. Rubinstein's denial that C.W. was a victim, places them in breach of the agreement and we intend to proceed. We may want to use that opportunity to put them on notice that Bruce
ael Tein Right now I am digesting something filed in a new federal civil lawsuit against Epstein. Bruce Reinhart is listed as counsel of record for Sarah Kellen, and a deposition transcript attached to the removal petition includes questions from Mike rein to G. implying that Jeff and I both went to her hou
reach of the agreement and we intend to proceed. We may want to use that opportunity to put them on notice that Bruce Reinhart cannot represent Ms. Kellen in connection with the criminal litigation. A. Marie Villafafta Assistant U.S. Attorney 500 S. Australian Ave, Suite 400 West Palm Beach, FL 334
their position makes it impossible for Mr. Epstein to fully perform his contractual obligations and that, coupled with Mr. Rubinstein's denial that C.W. was a victim, places them in breach of the agreement and we intend to proceed. We may want to use that opportunity to put them on notice that Bruce
l Stuart said the depanty In the odorant sentences was arse/ The USW Saws Moneys Oda dee *dyed not lo charge any ol Eolith's possible co-compmica • Sarah Kellen, Actlans Rom Lesley Groff end Nada Misrartove The agreement was negotiated In pert by New York howywegm ezignInal deem. Quemoy Geoid Larogn on Its
ment that lets Epstein and co-conspirators Sarah Kellen, Adrian& Ross, Lesley Groff and Nadia Marcinkova
eference to the ages of the minor victims and, upon conviction, did not require sex offender registration. 3. Jane Doe #1 is a woman with initials C.W., and Jane Doe #2 is a woman with initials T.M. Both were victims of Epstein's while they were minors beginning when they were fifteen years old. Bo
Entities connected to both Sarah Kellen and C.W.

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Marc Rich
PERSON
George W. Bush
PERSON
Kenneth Marra
PERSON
A. Marie Villafana
PERSON
Paul Cassell
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSONBruce E. Reinhart
PERSON
United States
LOCATION
Alexander Acosta
PERSONScott Rothstein
PERSONMichael J. Pike
PERSONLeon Black
PERSON
Salt Lake City
LOCATION