Epstein Secrets

of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-CV-80811-MARRAIJOHNSON C.M. A., Plaintiff, v. JEFFREY EPSTEIN and SARAH KELLEN, Defendants, DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS COMPLAINT FOR FAILURE TO STATE A CAUSE OF ACTION Defendant, JEFFREY EPSTEIN, ("EPSTEIN

Count I of Plaintiffs Complaint for failure to state a cause of action. Rule 12(b)(6), Fed.R.Civ.P. (2008). Count II is directed only to Defendant KELLEN, who has not yet been served. In support of dismissal, Defendant states: Plaintiff, CMA, attempts to assert a cause of action against EPSTEIN in Cou

00.03, 800.04, Fla. Stat. Rather, the ' This action began in Florida state court, Palm Beach County 15°' Judicial Circuit Court, and was removed to Federal Court pursuant to a Notice of Removal filed by Defendants. EFTA00201294 Case 9:08-cv-80811-KAM Document 35 Entered on FLSD Docket 01/07/2009 Page 5 o

ed of supplying young girls for him to abuse face probe as it's revealed Ghislaine Maxwell moved house 36 times in a year before she was caught • Sara Kellen, Adriana Ross, Lesley Groff and Nadia Marcinkova are under investigation for their role in Epstein's sex-trafficking ring, according to reports •

involved in a sexual relationship with the financier. 2/11 EFTA00075159 CaseastcS04014310ttenElDbdthileat7107g412CF 0:Oe' :1413 /20g€Fe58209161 Kellen worked as an assistant for Jefferey Epstein and was named in his 2008 plea agreement as 'potential co-conspirators' Nada Marcinkova who now goes by

e Epstein, who hanged himself last August while awaiting trial on sex trafficking charges. During the two hour and 20 minute hearing at Manhattan's Federal Court, Maxwell appeared via video from the Metropolitan Detention Center in Brooklyn. The small room she was in had white walls, a white bed, a window wi

ot yet obtained Jane Doe #18's telephone records, we were able to identify her telephone number, and there are twenty telephone calls that appear on Sarah Kellen's phone records. All of those calls were outgoing (meaning Kellen called Jane Doe #18.) The telephone calls range in date from August 27, 2003 throu

each day would be made. The girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and Epstein's assistant—usually Kellen—in the kitchen. The assistant normally would escort the girls upstairs to the master bedroom/bathroom area and set up the massage table and massage

n of a material witness. Finally, Sections 3150 and 3151 discuss the applicability of the Bail Reform Act to those State cases which are removed to Federal Court, and the issue of forfeited bail. 554 Proving Federal Crimes EFTA00191623 Federal Narcotics Prosecutions - Chapter 26 Page 1 of 12 USABOok :>

1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (2) In or around 2001, Defendant SARAH ICELLEN led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001

in exchange for posing for nude photographs. (13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that auJant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane 1.J1 Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who w

dockets. In 1979, there were 1194 appeals filed in the Tenth Circuit; in 1984, there were 1922. Administrative Office of the United States Courts, Federal Court Man- agement Statistics 11 (1984). The average time it is currently taking this circuit to handle a criminal appeal from the date of the notice to

n. Sarah Kellen is on a lot of these flight logs with, you know, these girls that -- or women and with Epstein and others, and so I wanted to talk to Sarah Kellen. ROUGH DRAFT ONLY HOUSE_OVERSIGHT_021896 Oo O DN OO FF WwW NY =| NO RO PO PNP NM NO | S| S| HS SF S| S| S| S| S| non BP WO NO -|- ODO OO WDN OO O

lked about. One of the things that really bolstered the adverse inference that I was drawing in this case was that I've mentioned those three girls, Kellen, Mucinska, and Marcinkova, they were all covered by a nonprosecution agreement. And the nonprosecution agreement was highly unusual . I had been a f

you let us know? A. Okay. Will do. Q. What is your understanding of the ethical responsibility of an attorney in signing a pleading to be filed in Federal Court, and let's say in the Southern District of Florida, if that's any different than elsewhere? A. Sure. Q. Just give me your understanding. A. Sure. T

WOW' provided the following additional or clarifying information not previously documented in earlier FD-302s: JEFFREY EPSTEIN and his assistants, SARAH and -(identified as and would contact ma to set up appo intments for EPS EIN's massages. According to was would call and say that EPSTEIN was

h apparently he has, which is that the 21 $50,000 or $150,000 floor under 2255 also would be a cap. That 22 if they were to proceed to file suit in Federal Court to get 23 fair damages under 2255, Mr. Epstein would admit liability, but 24 he, of course, could fight the damages portion, which means 25 that,

y jurisdiction, and to prevent any application of 18 U.S.C. § 3509(k), a mandatory stay provision applicable in federal court .3 Haley 2 Defendant Kellen is a citizen of New York (Am. Compl. ¶ 5), and is therefore a nonresident defendant for purposes of diversity jurisdiction and removal. 3 Section

h apparently he has, which is that the 21 $50,000 or $150,000 floor under 2255 also would be a cap. That 22 if they were to proceed to file suit in Federal Court to get 23 fair damages under 2255, Mr. Epstein would admit liability, but 24 he, of course, could fight the damages portion, which means 25 that,

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

h apparently he has, which is that the 21 $50,000 or $150,000 floor under 2255 also would be a cap. That 22 if they were to proceed to file suit in Federal Court to get 23 fair damages under 2255, Mr. Epstein would admit liability, but 24 he, of course, could fight the damages portion, which means 25 that,

in therefore not filed with this pleading and will be provided to the court for in camera review. Epstein chose to make this payment as a result of a Federal Court ordered mediation process which he himself sought. Epstein entered into the settlements in July 2010 more than seven months after he filed his lawsui

ng the commission of a violation of federal law to a law enforcement officer, namely, Special Agents of the FBI. Epstein also threatened and harassed Sarah Kellen against cooperating against him as well. 21. | Edwards learned that the Palm Beach police department investigation ultimately led to the execution o

” — categories Clinton and acquaintances of Clinton fall into; (f) flight logs showed that Clinton took many flights with Epstein, Ghislaine Maxwell, Sarah Kellen, and Adriana Mucinska, -- all employees and/or co-conspirators of Epstein’s that were closely connected to Epstein’s child exploitation and se

tegories Clinton and acquaintances of Clinton fall into; (f) flight logs showed that Clinton took many flights with Epstein, Ghislaine Maxwell, Sarah Kellen, and Adriana Mucinska, -- all employees and/or co-conspirators of Epstein’s that were closely connected to Epstein’s child exploitation and sexual ab