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s in Florida state court, in exchange for a federal Non-Prosecution Agreement ("NPA") providing him and his co-conspirators (including Lesley Groff, Sarah 48 EFTA00162005 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from
ding him and his co-conspirators (including Lesley Groff, Sarah 48 EFTA00162005 Case 1:22-cv-10018-JSR Document 42 Filed 01/13/23 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal prosecution for extensive federal sex-trafficking charges in Florida. The deal incl
ed the allegations underlying the NPA and to varying degrees detailed the involvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. 195. The names of these women and other alleged co-conspirators were 49 EFTA00162006 Case 1:22-cv-10018-JSR Document 42
York, Florida, New Mexico, New Jersey, Massachusetts, the U.S. Virgin Islands, and elsewhere, and in foreign commerce to places abroad, especially Eastern Europe. 121. At all times relevant to this complaint, the Epstein sex-trafficking venture was a group of two or more individuals associated in fact, even
alty 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, Adriana Ross, Lesley Groff, and Marcinkova—figured in the FBI investigation. The Non Prosecution Agreement stipulated that they would not be charged
Page: HOUSE_OVERSIGHT_022252 →s staff in the predatory activity, and four—Sarah Kellen, Adriana Ross, Lesley Groff, and Marcinkova—figur
Page: HOUSE_OVERSIGHT_022252 →an Luc Brunel when he was starting the modeling agency MC2 ¢ According to a former bookkeeper, young girls were brought to the U.S. by MC2—often from Eastern Europe—then traveled on Epstein’s private jets Jeffrey Epstein’s loyal friends say that his prosecution was unduly harsh, rather than outrageously lenient.
Page: HOUSE_OVERSIGHT_022252 →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, Adriana Ross, Lesley Groff, and Marcinkova—figured in the FBI investigation. The Non Prosecution Agreement stipulated that they would not be charged
s staff in the predatory activity, and four—Sarah Kellen, Adriana Ross, Lesley Groff, and Marcinkova—figur
gave $1 million around the same time that Brunel was starting his MC2 modeling agency. Some of the young girls MC2 recruited from overseas—often from Eastern Europe and South America—are known to have been passengers on Epstein’s private jets. The U.S. Attorney General’s Office in Florida says that it is against
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, Adriana Ross, Lesley Groff, and Marcinkova—figured in the FBI investigation. The Non Prosecution Agreement stipulated that they would not be charged
s staff in the predatory activity, and four—Sarah Kellen, Adriana Ross, Lesley Groff, and Marcinkova—figur
has never been charged.) An American fashion designer who booked her girls through MC2 says they were very young and very beautiful; many were from Eastern Europe and spoke little English. A former bookkeeper in the agency’s Miami office, who also arranged visas for girls traveling to the U.S., confirmed that M
onship grew closer as the years went on. In fact, during the criminal investigation into Epstein in 2005, Staley flew on Epstein's plane along with Sarah Kellen and Nadia Marcinkova, individuals who had bank accounts through Epstein at JP Morgan and who were publicly identified as Epstein's co-conspirators
ailed the involvement of Epstein's alleged co-conspirators, including Lesley Groff, Sarah Kellen, and Nadia Marcinkova. Some articles reported that Kellen and Marcinkova had invoked their Fifth Amendment right against self-incrimination. 212. Additionally, press reports during this time noted allegati
reign commerce between the United 23 EFTA00162143 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 24 of 130 States and Europe, especially Eastern Europe. 88. At all times relevant to this complaint, the Epstein sex-trafficking venture was a group of two or more individuals associated in fact, even
benefitted 107 EFTA00162227 Case 1:22-cv-10019-JSR Document 36 Filed 01/13/23 Page 108 of 130 financially include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Acting through its officers and employees (including Staley), JP Morgan itself directly committed and pe
ally include Ghislaine Maxwell, Lesley Grog Sarah Kellen, Adriana Ross, and Nadia Marcinkova. 412. Actin
sexual conduct, sex trafficking, and forced labor. 29. Many of these women, particularly after Epstein's conviction in 2008, were trafficked from Eastern Europe. As the Government explained in its Second Amended Complaint, these women were recruited and, in several instances, required to marry other Epstein
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
as never been charged.) An American fashion designer who booked her girls through MC2 says they were very young and very beautiful; many were from Eastern Europe and spoke little English. A former bookkeeper In the agency's Miami office, who also arranged visas for girls traveling to the U.S., confirmed that
l Scott E. Kalb Anatole Kaletsky Paul-Bernhard Kellen Ajay Kalsi Baba N. Kalyani Abdullah Saleh Kem
gdom Ronald N. Mannix Chairman Coril Holdings Ltd Canada Harish Manwani President, Asia, Africa, Central and Unilever Asia Pte Ltd Singapore Eastern Europe Hans Peter Manz Ambassador of Austria to Switzerland John Manzoni President and Chief Executive Officer Talisman Energy Inc. Canada Galia Maor
alty 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, Adriana Ross, Lesley Groff, and Marcinkova- figured in the FBI investigation. The Non Prosecution Agreement stipulated that they would not be charge
Page: HOUSE_OVERSIGHT_029768 →s staff in the predatory activity, and four-Sarah Kellen, Adriana Ross, Lesley Groff, and Marcinkova- figu
Page: HOUSE_OVERSIGHT_029768 →l has never been charged.) An American fashion designer who booked her girls through MC2 says they were very young and very beautiful; many were from Eastern Europe and spoke little English. A former bookkeeper in the agency's Miami office, who also arranged visas for girls traveling to the U.S., confirmed that M
Page: HOUSE_OVERSIGHT_029769 →Entities connected to both Sarah Kellen and Eastern Europe

Jeffrey Epstein
PERSON
Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
Marc Rich
PERSONJane Doe
PERSONJack Goldberger
PERSONLarry Visoski
PERSON
Bradley Edwards
PERSONNadia Marcinkova
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
United States
LOCATION
Kenneth Marra
PERSONJack Scarola
PERSON
George W. Bush
PERSONLeon Black
PERSON
Lake Worth
LOCATIONRichard Horace Willits
PERSONScott Rothstein
PERSON