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to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants
tims of a crime veto power over any prosecutorial decision, strategy or tactic regarding bail, release, plea, sentencing or parole.") (citing In re W.R. Huff, 409 F.3d 555, 564 (2d Cir. 2005) ("Nothing in the CVRA requires the Government to seek approval from crime victims before negotiating or entering i
to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
z. r 1 1-1 2O - z) JEFFREY EPSTEIN and SARAH KELLEN, C N Lc; •74 > -41, 1 n -< 73 i Defendants
tims of a crime veto power over any prosecutorial decision, strategy or tactic regarding bail, release, plea, sentencing or parole.") (citing In re W.R. Huff, 409 F.3d 555, 564 (2d Cir. 2005) ("Nothing in the CVRA requires the Government to seek approval from crime victims before negotiating or entering i
to so participate, through a pattern of criminal activity in violation of Florida Statutes §772.103(3)-(4). 42. Defendants, Jeffrey Epstein's and Sarah Kellen's enterprise included, at a minimum, a group of individuals associated in fact to assist Defendant, Jeffrey Epstein, in recruiting and procuring mino
B AD Plaintiff, VS. JEFFREY EPSTEIN and SARAH KELLEN, Defendants. . 91 c. C AMENDED COMPLAINT 61
tims of a crime veto power over any prosecutorial decision, strategy or tactic regarding bail, release, plea, sentencing or parole.") (citing In re W.R. Huff, 409 F.3d 555, 564 (2d Cir. 2005) ("Nothing in the CVRA requires the Government to seek approval from crime victims before negotiating or entering i
olved the exact same crimes and same evidence being reviewed by the U.S. Attorney's office when he was employed there. Specifically, he represented Sarah Kellen (Epstcin's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry
ployed there. Specifically, he represented Sarah Kellen (Epstcin's number one co-conspirator who was actu
r restitution measures against nonconvicted defendants." hi re W.R. Huff Asset Mgt. Co., LLC, 409 F.3d 555, 564 (2d Cir. 2005) (emphasis added). In W.R. Huff petitioners filed two writs of mandamus seeking to vacate settlement agreements of forfeiture actions between the United States and members of the
not use non-public Government information for any purpose. 14. After opening my private practice on January 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of action to which the United States was not a party. At a later time, I was retained to represent seve
nuary 2, 2008, I was retained to represent Sarah Kellen for purposes of civil depositions in causes of ac
ttlement, factors which Congress has required the court to consider. See 18 U.S.C. § 377l(dX2). W11. Huff 409 F.3d at 564. In this instance, as in W.R. Huff there was an un-convicted defendant, Epstein. Unlike in Wit. Huff here Epstein was the only defendant. Nonetheless, the AUSA who investigated Epste
Entities connected to both Sarah Kellen and W.R. Huff

Jeffrey Epstein
PERSONJane Doe
PERSON
Marc Rich
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSON
Prince Andrew
PERSON
United States
LOCATIONMichael J. Pike
PERSON
George W. Bush
PERSON
Salt Lake City
LOCATIONLeon Black
PERSON
A. Marie Villafana
PERSONMaria Farmer
PERSONthe Southern District
LOCATIONRobert D. Critton
PERSON
Scarlett Johansson
PERSON
Joe Biden
PERSON