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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
and from the FBI's Victim-Witness 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
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
ttorney's Office. She provided additional details of Epstein's sexual abuse of her." (DE48 at 17.) And, one of Petitioners' counsel's other clients, S.R., was originally interviewed in October 2007 and refined to provide information regarding Epstein. (DE 14 at ¶ 7.) During the time that Epstein was
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 Sarah Kellen (Epstein's number one co-conspirator whoyvas actually named as such in the NPA), his housekeeper (Louella Ruboyo), his pilots Larry Morrison, Larry
ployed there. Specifically, he represented Sarah Kellen (Epstein's number one co-conspirator whoyvas actu
ent that might have shed light on improper influences. Along with other capable attorneys, I was involved in representing one of Epstein's victims (S.R.) who filed a federal civil case against Epstein. Suspecting that Epstein may have improperly influenced your office, we immediately served discovery
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
ttorney's Office. She provided additional details of Epstein's sexual abuse of her." (DE48 at 17.) And, one of Petitioners' counsel's other clients, S.R., was originally interviewed in October 2007 and refused to provide information regarding Epstein. (DE14 at It 7.) During the time that Epstein was
Entities connected to both Sarah Kellen and S.R.

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSONJane Doe
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSON
Marc Rich
PERSONLarry Visoski
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
Paul Cassell
PERSON
Prince Andrew
PERSON
United States
LOCATION
Alan Dershowitz
PERSONJack Scarola
PERSONBruce E. Reinhart
PERSON
A. Marie Villafana
PERSON
Lake Worth
LOCATIONRichard Horace Willits
PERSON
Alexander Acosta
PERSON