DOJ-OGR-00030542.pdf

--- Page 1 --- **Document Image Extraction** **Page 2 of 9** **Date:** 07/26/17 **Page Number:** Page 75 of 131 **Public Records Request Number:** 17-295 **Text:** Defendant Sarah Kellen is a citizen and resident of the State of New York. This is an action for damages in excess of Fifteen Thousand Dollars ($15,000), exclusive of interest and costs. Venue is proper in this Court under section 47.011, Florida Statutes, because the causes of action brought herein accrued in Palm Beach County, Florida and one or more Defendants reside in Palm Beach County, Florida. Facial Allegations At all relevant times, Defendant Jeffrey Epstein was an adult male. Epstein is a financier and money manager with a secret clientele limited exclusively to billionaires. He is a man of tremendous wealth, power and influence. He maintains his principal home in New York and also owns residences in New Mexico, St. Thomas and Palm Beach, Florida. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach. Upon information and belief, Epstein has a sexual preference and obsession for minor girls. He engaged in a gifts, scheme, and/or enterprise in which he gained access to primarily economically disadvantaged minor girls in his home, sexually assaulted these girls or coerced or attempted to coerce them to engage in prostitution, and then gave them money. In or about 2005, Jane Doe, then 14 years old, fell into Epstein's trap and became one of his victims. Upon information and belief, Jeffrey Epstein carried out this scheme/enterprise and recruited girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas. An integral player in Epstein's Florida scheme/enterprise was Sarah Kellen, an assistant of Epstein's, from New York and Haley Robson, a Palm Beach Community College student from Loxahatchee, Florida. They recruited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's plan/enterprise, Ms. Robson was contacted shortly before or soon after Epstein was at his Palm Beach residence. Epstein. Kellin.