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6. Defendant Sarah Kellen is a citizen and resident of the Stale of New York. 7. This t an action for damages in excess of Fifleen Thoesand Dollars ($15,000), excinsive of mmberest and costs. 8. Vez 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 testes mi Palin Beach County, Florida Factual Altegations 9. Atall relevant times, Defendant Jeffrey Epwein was an adult male. Epstein is a financier ao ae teh Orr Pest bee j money matzager With 2 secret Clientele limited exclusively to billionaites. He is 2 man of emendous wealth, power and infieence. He maintains his principal home in New York and also owns tesidences in New Mexico, St. Thomas and Palm Beach, Florida The allegations herein concem Epstets's conduct while at his lavish estate in Palm Beach. 10. Upor informztion and belief, Epstein has a sexual preference and obsession fox minor giris. , He engaged mm a plan, scheme, and/or enterprise in which he gained access to primarily economically | disadvantaged minor girls in his home, sexually assaulted these gisls of coerced or attempied to ' coetce them bo €A@2ge in prostitution, and then gave them money. in or about 2005, Jane Doe, thea " seams cla tate patina tag ead Necensene Gt ie dicta 11. Upon information and belief, Jefirey Epstein carried out this scheme/enterprise and assaulted "girls in Florida, New York and on his private island, known as Little St. James, in St. Thomas, 12. As integral player in Epstein’s Florida scheme/esierptise was Sarah Keilen, mM asnstant of | Epstein’s, from New York, New York and Haley Robson, 2 Palm Beach Community College student " from Loxahatchee, Florida. They recsuited girls ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's pian/emterprise, Ms. Robson | was contacted shoutly before or soon after Epstein was at bis Palm Beach residence. Epstein, Kellen, Page 2 of 9 07/26/17 Page 75 of 131 Public Records Request No.: 17-295 DOJ-OGR- 00030542