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

d Order a Bill of Particulars as to Counts Five and Six. 22 VII. The Court Should Order the Government to Produce Accuser-4's Prior Statements as Brady Material 24 VIII. Ms. Maxwell Incorporates All of the Arguments Raised in Her Initial Pretrial Motions and Reasserts Them as to the S2 Indictment

r of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova.

victims, the NPA granted federal immunity not only to Epstein, but also to "any potential co-conspirator of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova." It is only because the victims filed this lawsuit, and the District Court ordered the NPA be pro

reasonableness."); / Kyles v. Whitley, 514 U.S. 419, 432-33, 115 S. Ct. 1555, 1565, 131 L.Ed.2d 490 (1995) (under the Due Process Clause and 11 Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L.Ed.2d 215 (1963), prosecutors must disclose all evidence, upon request, that is favorable to the def

lty shops, were stowed near the massage tables set up In several rooms upstairs. Epstein also enlisted his staff in the predatory activity, and four—Sarah Kellen, Adrian Ross, Lesley Groff, and —figured in the FBI Investigation. The Non Prosecution Agreement stipulated that they would not be charged. Accordi

s staff in the predatory activity, and four—Sarah Kellen, Adrian Ross, Lesley Groff, and —figured in the

s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t

Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on thei

faiia Gerald Lefcourt Letter that he cannot accept service for Eric Gany 8/28/2007 A. Marie Villafaiia Nathan Z. Dershowitz Left messages with Sarah Kellen and to request if he can accept service on their behalf 8/30/2007 Jeff Sloman, Andrew Laurie, Drew Oosterbaan, John McMillan, Karen Atkinson

npersuaded by the letter and the presentation, but I agreed that I should carefully review transcripts of the recorded statements given to PBPD for Brady issues." Since witness credibility was clearly at the fore, I undertook efforts " The requested documents and items were never provided. 15 As the

ed States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova. Further, upon execution of this agreement and a plea agreement with the State Attorney's Office, t

rs of Epstein, including but not limited to Sarah Kellen, Adrian Ross, Lesley Groff, or Nadia Marcinkova.

r statements, their credibility and the foundations, if any, for claiming personal injury. Also, Mr. Epstein would have received, pursuant to either Brady or Jencks, material in the form of prior inconsistent statements made by these women before they learned of any financial benefit that may be avail

prosecutors to approve warrants to arrest Epstein on four counts of unlawful sexu.al actiyity witl_l a minor .a11d to ch~rge his person41 a~sistant, Sarah Kellen, n·ow 27, for her alleged role in arranging the visits. Police officials also wanted to charge Robson, the self.:describe·d.Heidi Pleiss, with lewd

irls told similar stories. In most accounts, Epstein’s personal assistant at the time, Sarah Kellen, now 27, escorted the girls to Epstein’s bedroom. Kellen, whose most recent known’ address is in North Carolina, has not been charged in the case. Palm Beach police often conducted surveillance ofEpstein’s

CLERK. 3/28/2023 2:27:00 PM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 • • J8RsEPSl I he was deeply troubled by the alleged Brady violations. I represented the prosecutors in that case, so I'm very, very I familiar with it. It is analogous. It is a situation where there was trem

the exact same crimes and exact same evidence being reviewed by the U.S. Attorney's office when he was employed there. Specifically, he represented Kellen (Epstein's number one co-conspirator who was actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry

s representing criminals, your Office would promptly turn over to us all information in its possession that was helpful to these criminals under the Brady and Giglio decisions. We asked your Office to extend to the victims the same assistance that it would provide to criminals — i.e., we asked and t

rrell Williams (Gn his Vivienne Westwood “Mountain” hat) and Anjelica Huston chatted HOUSE_OVERSIGHT_010718 --- PAGE BREAK --- Portia de Rossi and Ellen DeGeneres Michael Fassbender up Chinatown producer Robert Evans. Dom Perignon sent the champagne, proving that even behind private dinners, one can

arty is now a headline on Page Six. Madonna made her best effort to cream off the stars from Graydon’s party. In attendance were Paul McCartney, Tom Brady and Gisele Biindchen, newly engaged Ashton Kutcher and Mila Kunis, Serena Williams, Prince, and Pink. Madonna closed out her own party by breakdancin