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11.
For each and every occurrence of sexual abuse of the Plaintiff while she was a minor
for which JEFFREY EPSTEIN was responsible, he was aided, assisted, and/or
abetted by SARAH KELLEN, who lived at the Palm Beach mansion of JEFFREY
EPSTEIN. Said acts included, but were not limited to, the following:
a.
She often called the Plaintiff, when the Plaintiff was a minor, to arrange for
the Plaintiff to come to the Palm Beach mansion of JEFFREY EPSTEIN, for
the ostensible purpose of providing "massages" to JEFFREY EPSTEIN,
when she knew or should have known that Plaintiff had no credentials to
provide massage therapy.
b.
She observed the Plaintiff being brought to the Palm Beach mansion of
JEFFREY EPSTEIN, when the Plaintiff was a minor, and sometimes escorted
the Plaintiff to a room in that mansion where JEFFREY EPSTEIN was
waiting, for the ostensible purpose of providing "massages" to JEFFREY
EPSTEIN, when she knew or should have known that Plaintiff had no
credentials to provide massage therapy.
c.
She sometimes paid the Plaintiff for the "sessions" with JEFFREY EPSTEIN.
d.
She made telephone calls to the Plaintiff, when the Plaintiff was a minor, to
arrange for gifts to be sent to the Plaintiff.
e.
She took photographs of the Plaintiff, when the Plaintiff was a minor, which
depicted the Plaintiff in the nude. She told the Plaintiff that the pictures were
at the request of JEFFREY EPSTEIN, and paid the Plaintiff for posing for the
photographs.
12.
As a result, the Plaintiff suffered mental anguish, mental pain and suffering, psychic
trauma, and a loss of the capacity for the enjoyment of life.
WHEREFORE, THE PLAINTIFF DEMANDS JUDGMENT FOR DAMAGES AGAINST
SARAH KELLEN, IN AN AMOUNT IN EXCESS OF FIFTEEN THOUSAND DOLLARS,
EXCLUSIVE OF COSTS AND INTEREST AND FURTHER DEMANDS TRIAL BY JURY.
RICHARD H. WILLITS, P.A.
2290 10th Avenue North, Suite 404
Lake Worth, FL 33461
Telephone: (561) 582-7600
FAX: (561) 588-8819
By:
RICHARD H. WILLITS
Florida Bar No.: 139888
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DOJ-OGR-00015189