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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
ons who came to the New York Residence and who gave a massage or were asked to give a massage to Defendant. No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. No. 6. Identify all persons who came to the St. Thomas Residence and who gave
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,
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
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
admissible evidence. Plaintiffs Complaint alleges a time period of "in or about 2004-2005." Interrogatory No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage or were asked to give a massage to Defendant. Answer: Defendant is asserting specific legal objections to the interrogatori
Entities connected to both Sarah Kellen and the New Mexico Residence

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSONJack Goldberger
PERSONNadia Marcinkova
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
United States
LOCATIONMichael J. Pike
PERSON
Adam D. Horowitz
PERSONthe Southern District
LOCATIONRobert D. Critton
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Jean-Luc Brunel
PERSON
Woody Allen
PERSONHaley Robson
PERSONStuart S. Mermelstein
PERSON
Jay Lefkowitz
PERSON
Michael Jackson
PERSON
Jeffrey Marc Herman
PERSON