Sarah Kellen

Sarah Kellen (born Sarah Lyn Kensington, 1979) was a central figure in Jeffrey Epstein's sex-trafficking operation, serving as his assistant and scheduler from approximately 2002 through at least 2015. Named as an unindicted co-conspirator in Epstein's 2008 federal non-prosecution agreement, Kellen was identified in Palm Beach police investigations and multiple civil lawsuits as recruiting underage girls, coordinating their visits to Epstein's properties, and managing the logistics of his abuse. The archive contains 8,752 emails involving Kellen, documenting her extensive role managing Epstein's calendar, travel arrangements, and contacts. Despite being described as "criminally responsible" by U.S. District Judge Alison Nathan during Ghislaine Maxwell's 2022 sentencing, Kellen has never been criminally charged. She married NASCAR driver Brian Vickers in 2015; they divorced in 2025.

Kellen appears in the archive under multiple aliases, including "Kensington," "Sarah K," and various email addresses. Her correspondence spans from 2000 to 2023, with particularly heavy activity during Epstein's most active years operating his trafficking network. Flight logs show her traveling with Epstein and victims, federal prosecutors documented 156 phone calls between her and one victim, and court filings describe her as essential to the operation's functioning. She was one of four named targets in the federal investigation codenamed "Operation Leap Year" and was explicitly identified by prosecutors as someone who "clearly knew that Epstein was engaging in sexual activity" with minors.

Background#

Sarah Kellen was born in 1979 as Sarah Lyn Kensington. Public records indicate she was previously married and divorced before beginning work for Epstein, and she became estranged from her family and community. She began working for Epstein around 2002, initially serving as his personal assistant. According to testimony in Ghislaine Maxwell's trial, Kellen worked in Epstein's office building on Manhattan's Upper East Side and acted as a personal assistant for both Epstein and Maxwell. Her employment coincided with the period prosecutors would later identify as the height of Epstein's criminal enterprise, which federal court documents in MJ v. Epstein dated to "at least 1998," with MJ's own abuse occurring from "Summer 2002 to Spring 2004."

Kellen first drew public attention during the 2005-2007 Palm Beach police investigation of Epstein. A 2007 probable cause affidavit from Palm Beach police accused Kellen of coordinating the recruitment of minors for sexual services. She was one of four women—alongside Nadia Marcinkova, Lesley Groff, and Adriana Ross—named as unindicted co-conspirators in Epstein's 2008 non-prosecution agreement with the U.S. Attorney's Office for the Southern District of Florida, granting her immunity from federal prosecution at that time.

The immunity provision in the non-prosecution agreement (NPA) was proposed by Epstein's own defense counsel. According to the detailed CVRA motion documenting NPA negotiations, on September 16, 2007, Epstein's counsel proposed language stating: "Epstein's fulfilling the terms and conditions of the Agreement also precludes the initiation of any and all criminal charges which might otherwise in the future be brought against Sarah Kellen, Adriana Ross, Lesley Groff, and Nadia Marcinkova or any employee of N.E.S." The final NPA, signed September 24, 2007, provided: "the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova." Epstein's attorney explicitly requested that prosecutors "do whatever you can to keep this from becoming public," and the agreement was negotiated in secret meetings "off campus" to avoid being seen, with prosecutors discussing filing charges in Miami-Dade County to "hopefully cut the press coverage significantly."

Notably, Kellen's legal representation during this critical period was provided by Nathan Dershowitz (brother of Alan Dershowitz), who simultaneously represented both Kellen and Nadia Marcinkova. An August 28, 2007 letter from Dershowitz to prosecutors stated: "I made an effort to contact my clients Sarah Kellen and Nadia Marcinkova. I was unsuccessful and left messages for them reiterating my request that they contact me upon their return from vacation." AUSA Ann Marie Villafaña warned Dershowitz about this dual representation, noting "it is quite possible that Ms. Groff will have evidence adverse to Ms. Marcinkova and/or Ms. Kellen, and one or both of them may want to explore the possibility of cooperation." The coordination of their defense—both clients vacationing simultaneously with the same attorney during plea negotiations—suggests a strategic arrangement rather than independent representation. From January 18, 2007, federal prosecutors documented that "Epstein hired counsel for all employees," paying for Kellen's legal representation throughout the investigation.

After Epstein's 2019 arrest and death, federal prosecutors in the Southern District of New York stated they were not bound by the Florida agreement and that Kellen and others could face charges. However, no charges were ever filed. Kellen has largely avoided public statements but has denied wrongdoing through attorneys. She married retired NASCAR driver Brian Vickers in 2015; the couple divorced in April 2025. As of 2025, she resides in high-end properties in Miami and New York City and has worked as an interior designer. Notably, no evidence of Kellen's reported SurfAir interior design business appears in the archive, and her 2010 payroll records show she was not on Epstein's formal payroll by that time, despite continued coordination activities documented in emails through 2016-2018. A May 2016 email shows her arranging hair and makeup services for work at Epstein's Manhattan townhouse for "five women," with Lesley Groff identified as "the assistant to Jeffrey Epstein." Kellen was still performing coordination functions during the same period she was reportedly operating as an interior designer.

Operation Leap Year Investigation#

The federal investigation of Epstein and his associates was codenamed "Operation Leap Year" (Lions No. 2006R01181), led by AUSA Ann Marie Villafaña with FBI Special Agents Nesbitt Kuyrkendall and Jason Richards. According to the March 2007 Operation Leap Year Memo, the investigation specifically targeted "Jeffrey Epstein and three of his assistants, Sarah Kellen, Adriana Ross (nee Mucinska), and Nadia Marcinkova." The memo stated that "The targets would arrange 'sexual massages' for Epstein when he would travel to Palm Beach."

By May 2007, prosecutors had drafted a 53-page indictment and 82-page prosecution memorandum. As late as July 1, 2008, the U.S. Attorney's Office was actively planning to present the indictment to a grand jury, with a travel authorization memo planning to bring "New York victims" and "Epstein's two New York-based assistants" to Florida for grand jury testimony—strongly suggesting Kellen was one of those New York-based assistants targeted for indictment.

The investigation revealed specific evidence of Kellen's knowledge of the sexual abuse. According to the Operation Leap Year Memo, witness Johanna Sjoberg (referred to as "Robson" in early documents) told federal investigators that "During her initial interview with the Palm Beach Police Department, Robson noted that Kellen had mentioned something about how Epstein did not like to have sex with the girls, he was just 'turned on' by masturbating in front of them." This admission, documented by prosecutors, demonstrated that Kellen "clearly knew that Epstein was engaging in sexual activity" with the victims. The memo also documented that "Robson and Miller's telephone records have been subpoenaed and analyzed. They show a large number of calls between their cell phones and Sarah Kellen's cell phone and Epstein's house in Palm Beach."

The investigation also uncovered evidence regarding victims' ages. The Operation Leap Year memo noted: "Robson also said that she told the girls that she brought to say that they were 18, but she also said that, while she was giving massages to Epstein, he knew that she was under 18. No one asked Robson whether Kellen or someone else told her to instruct the girls to say that they were 18." The probable cause affidavit documented that one recruiter told a 14-year-old victim to say she was 18 before bringing her to the house—after coordination through Kellen's phone.

Despite the extensive evidence compiled, the investigation was derailed by plea negotiations. Prosecutor Villafaña strongly opposed the plea deal; on July 3, 2007, she documented "disagreement on Menchel's plea negotiations and written request for meeting between USAO management and victims." On May 23, 2007, she wrote that she disagreed with promising meetings to Epstein's counsel because it "disclosed prosecution strategy" and stated: "If meeting is held, Villafaña will ask to have the case reassigned." The NPA negotiations proceeded without victim notification, in direct violation of the Crime Victims' Rights Act, as later court rulings would confirm.

Correspondence with Epstein#

The archive documents extensive coordination between Kellen and Epstein spanning from 2000 to 2019, with Kellen appearing as sender in 5,038 emails and as recipient in 3,714 emails. Her role evolved from direct administrative assistant coordinating every detail of Epstein's activities in the 2000s to more sporadic correspondence after his 2008 conviction.

2002-2008: Active Management Period

During the height of Epstein's trafficking operation, Kellen managed virtually every aspect of his schedule and logistics. Federal prosecutors preparing a draft indictment in February 2008 noted that one victim had 156 calls with Sarah Kellen, providing documentary evidence of Kellen's coordination role. Prosecutors described maintaining "telephone charts for all of the girls and Kellen, Nadia, and Adriana" and searching Kellen's phone records electronically for phone numbers of "new girls."

Multiple civil complaints describe Kellen's operational role in detail. In Jane Doe No. 1 v. Epstein, the plaintiff alleged that after being brought to Epstein's Palm Beach mansion, she "was introduced to Kellen, who led her up the stairs to the room with the massage table. Kellen set up the massage table, laid out the massage oils, told Plaintiff that Epstein would be in shortly, and then left the room." The pattern repeated across multiple victims: Kellen would gather personal information, escort girls to the massage room, prepare the space, and later be present when Epstein paid them.

This standardized procedure was confirmed across numerous independent victim statements in the Palm Beach Probable Cause Affidavit. Multiple victims independently described the same pattern: Upon arrival at Epstein's residence, victims "would be introduced to [Kellen], Epstein's assistant, who in turn would record their telephone numbers and name." Kellen would then "set up the massage table and covered the table with a sheet. She brought out the massage oils and [placed] them next to the massage bed. [Kellen] then left the room and informed [victim] Jeff would be in, in a minute." After the abuse, Kellen would be present when victims were paid. This identical pattern appears in at least five separate victim statements in the affidavit and demonstrates the systematic nature of Kellen's role.

The MJ v. Epstein RICO case statement provided additional detail about Kellen's coordination with recruiters: "Kellen helped arrange for recruiters of the minor girls. She also spoke personally to the recruiters as well as to the minor girls who were victims of Epstein's sexual abuse. At Epstein's specific direction, Kellen spoke to the recruiters about subjects such as finding more minor girls to satisfy Epstein's criminal sexual appetite." The RICO complaint also confirmed that "the term 'work' was a code or slang word used by the various criminal enterprise members to avoid detection by law enforcement"—indicating that when Kellen scheduled "work" appointments, she was scheduling victims for sexual abuse.

Flight logs show Kellen traveling with Epstein and victims on numerous occasions. Composite flight records document trips including June 21, 2002 (West Palm Beach to Bahamas with "Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, Sarah Kellen, Cindy Lopez, Jean Luc Brunel") and August 17, 2002 (Santa Fe to Teterboro with the same group plus additional passengers).

Kellen's coordination extended to travel logistics and customs arrangements. In March 2007, pilot Larry Visoski copied Kellen on an email about Bedford customs, asking if "drop in is not possible" and whether "Bangor Maine ok for fuel stop if needed?" Epstein replied "yes" with Kellen copied. Similarly, in June 2007, Visoski copied Kellen on an email regarding aircraft registration numbers, seeking approval for modifications.

Post-2008: Continued but Reduced Contact

After Epstein's 2008 plea agreement and incarceration, Kellen's direct involvement diminished but did not cease entirely. An April 2011 email from Lesley Groff to Epstein copied "Sarah Kellen Sarab" on coordination regarding household staff. In January 2006, Epstein's email to Ghislaine Maxwell about island staff departures for "Miles fiftieth" copied both Kellen and Daphne Wallace, instructing them to "tell Karen and Brice but not miles until feb20".

This continued association despite absence from formal employment is significant. The 2010 payroll and benefits document for Epstein's entities (listing 116 employees with total payroll of $9.5 million) does not include Sarah Kellen. She was apparently no longer formally employed by 2010, or was compensated through other arrangements outside the standard payroll structure. Top paid employees in 2010 were led by attorney Darren Indyke ($1.53M), with pilot Larry Visoski at $303K. Yet despite this absence from formal payroll, Kellen continued to be copied on operational emails and coordinate activities.

By 2015-2016, Kellen appeared to have transitioned away from direct work for Epstein. A May 2016 email shows her arranging hair and makeup services for work at Epstein's Manhattan townhouse, but clarifying "there's a typo in Alexandra's email. That was my fault when I sent it" — suggesting she was coordinating services rather than directly employed.

From 2017-2019, sporadic correspondence shows continued coordination on behalf of Epstein. In March 2018, she forwarded to Epstein a message from Larry Summers' assistant: "larry was wondering if Jeffrey might be able to come to his house in Brookline on Sunday around 4/4:30". In May 2017, another assistant emailed Kellen seeking help scheduling an appointment with a doctor for Epstein; Kellen replied "I do not know who Dr. Chen is and have never heard of him."

Morocco Property Activities as "Kensington"

Between 2015-2016, extensive correspondence shows Kellen using the alias "Kensington" to coordinate with Epstein regarding property in Marrakech, Morocco. In September 2015, Epstein wrote that he would "be in mararksh next week" and asked about property for sale; Kensington replied with property details. In December 2015, Epstein told Kensington he was "likely to be in mararksh next week", and Kensington replied "Enjoy Christmas and call when you are in Morocco". These emails suggest Kellen continued advising Epstein on real estate matters using her maiden name as an alias.

Connections#

Kellen's primary connection was to Jeffrey Epstein, with whom she shared 4,401 emails documenting their working relationship. Her second-most frequent correspondent was Lesley Groff (621 emails), Epstein's other primary assistant, with whom she coordinated scheduling and logistics.

Kellen communicated regularly with Epstein's household and operations staff, including Gary Kerney (221 emails), Larry Visoski (192 emails, Epstein's pilot), Jojo Fontanilla (149 emails), and Richard Barnett (165 emails). She also corresponded with Ghislaine Maxwell, appearing in email threads regarding island operations and staffing.

Relationship with Nadia Marcinkova and Other Co-Conspirators

Kellen's relationship with fellow co-conspirator Nadia Marcinkova was particularly close and coordinated. Both women shared the same attorney, Nathan Dershowitz, and were vacationing simultaneously during the critical August 2007 period when plea negotiations were being finalized, as documented in Dershowitz's August 28, 2007 letter. The MJ v. Epstein RICO complaint described a division of labor between them: "Marcinkova, who is known to be Epstein's bisexual sex slave, also directly participated in the sexual abuse of the minor girls by participating in unlawful sexual activities and prostitution with the girls. Both Kellen and Marcinkova assisted Epstein in attempting to keep Epstein's criminal sexual abuse unknown to law enforcement." According to the RICO filing and a CVRA motion, Jane Doe 1 provided "details about her abuse—and the abuse of Jane Doe 2—to the FBI on August 7, 2007" including "the direct sexual abuse by one of his co-conspirators, Nadia Marcinkova—who participated in the abuse of other victims as well."

While Kellen and Marcinkova shared an attorney, the third named co-conspirator, Adriana Ross (Mucinska), had separate counsel. Records show Ross asserting her Fifth Amendment rights through attorney Bruce Lyons, who was distinct from Nathan Dershowitz and the Epstein defense team, though prosecutors noted Lyons "admitted to speaking with Bruce Lyons and Roy Black about the case."

Connection to Ghislaine Maxwell: Division of Labor

The MJ v. Epstein RICO complaint describes the organizational hierarchy between Maxwell and Kellen: "Maxwell was also a participant in sexually abusing minor females. Maxwell served many additional purposes for the criminal organization and was highly ranked within the organization, thus she was able to act on her own accord, without needing orders from Epstein." By contrast, Kellen's role is consistently described as being carried out "at Epstein's specific direction." The RICO complaint states that Maxwell's roles included "maintaining computer records and images of underage minor females with their names and phone numbers," while Kellen's role was more operational—handling day-to-day scheduling, preparing rooms, gathering victim information, and directly coordinating with recruiters about "finding more minor girls to satisfy Epstein's criminal sexual appetite."

In October 2007, Karen at Zorro Ranch emailed Maxwell (copying Epstein's attorney) reporting that "a female saying she worked for the Associated Press" called asking for comments and "would it be possible to speak to Ghislaine Maxwell or Sarah Kellen for a comment" regarding Epstein's plea bargain. This indicates both women were recognized publicly as key figures in Epstein's inner circle, though at different organizational levels.

Connection to Jean-Luc Brunel and MC2 Modeling

The June 2008 travel authorization memo documented critical evidence linking Epstein's operation to international modeling agency MC2: "a witness here in the Palm Beach area came forward recently to inform the FBI about a link between Epstein and the MC Modeling Agency. The witness stated that Epstein and the head of MC2, Jean Luc Brunel, worked together to obtain fraudulent visas to bring potential models to the United States. The witness stated that Epstein selected some of the underage girls to come to the United States even though Brunel never intended to use them as models so that Epstein could engage in sexual activity with them." The memo specifically noted: "Brunel's name appears on several of the message pads recovered during the search of Epstein's home. Some of the messages describe young girls that he would like Epstein to meet (including a 16-year-old who would 'teach Russian' to Epstein)."

These message pads—bearing notations about "young girls" from Brunel—were the same pads that victims testified were managed and signed by Sarah Kellen. On August 16, 2007, federal prosecutors issued a grand jury subpoena to Jean-Luc Brunel. The MJ v. Epstein RICO complaint named both Kellen and Brunel as co-conspirators in the same criminal enterprise, stating: "Maxwell and Brunel participated by helping to create the impression that the girls would be going to meet with Epstein for legitimate 'modeling' purposes... Brunel used his modeling agency to locate underage girls for Epstein and others to sexually abuse."

Kellen coordinated with Epstein's broader network of associates. The archive confirms coordination with Epstein's full range of staff, pilots, property managers, and business associates across his various properties and operations.

Document References#

Sarah Kellen appears extensively in federal court records related to civil lawsuits filed by Epstein's victims and in documents from the criminal investigations. In Jane Doe No. 1 v. Epstein, Robson, and Kellen, filed in Florida federal court in 2008, a 14-year-old plaintiff sued Kellen directly, alleging she recruited the minor "ostensibly to give a wealthy man a massage for monetary compensation," gathered her personal information, and brought her to the room where Epstein sexually assaulted her. The court's October 2008 opinion found that the complaint stated viable causes of action for civil conspiracy, describing Kellen as part of a plan to "commit the tort of sexual assault of a minor." The case was remanded to state court.

Multiple similar civil suits named Kellen as a defendant. In Jane Doe II v. Epstein and Kellen, Case No. 09-80469, Kellen moved to adopt Epstein's motion to dismiss, which the court granted. In M.J. v. Epstein and Kellen, Case No. 10-81111, the plaintiff sought a protective order barring Epstein from contact, noting that "Sarah Kellen" was listed among those Epstein had allegedly intimidated. The motion referenced federal prosecutors' draft charges against Epstein for witness tampering, noting: "During the FBI investigation of his sexual abuse of young girls, Epstein intimidated and harassed other possible witnesses against him -- namely Sarah Kellen, Leslie Groff and Nadia Marcinkova. Indeed, this intimidation was so serious that federal prosecutors prepared draft federal charges against him for witness tampering charges."

The CVRA motion documenting the secret NPA negotiations reveals that on September 15, 2007, prosecutors discussed "having Epstein plead to obstruction of justice for pressuring one of his co-conspirators to prevent her from turning over evidence or complying with a previously-served grand jury subpoena." The following day, September 16, 2007, prosecutors discussed "having Epstein plea to a second charge of assaulting a different co-conspirator"—referencing physical assault against co-conspirators. These proposed charges were never filed, but they strongly suggest Kellen (or other co-conspirators) were subjected to pressure and intimidation by Epstein to prevent cooperation with federal investigators.

The pattern of Epstein paying for witnesses' and co-conspirators' attorneys was flagged by prosecutors as problematic. Regarding witness Tatum Miller, the Operation Leap Year Memo noted: "Miller is an openly hostile witness who claims to be 'in love' with Epstein... Miller is represented by Jim Eisenberg, who is being paid by Epstein. Eisenberg has admitted to speaking regularly with Roy Black, who is Epstein's 'behind the scenes' attorney." In June 2008, Villafaña documented that one witness's "attorney gave a copy of the grand jury subpoena to Epstein's lawyers"—showing defense attorneys compromising witness interests by sharing confidential grand jury materials with Epstein's defense team.

Federal prosecutor emails from February 2008, obtained through DOJ document releases, show prosecutors actively investigating Kellen's role. Assistant U.S. Attorney Ann Marie Villafaña wrote to investigators requesting "telephone charts for all of the girls and Kellen, Nadia, and Adriana" and asking "do you have all of Sarah Kellen's records electronically? Maybe we can search for phone numbers for some of the new girls." Another prosecutor email noted that one victim had "156 calls with Sarah Kellen, and 2 calls with Adriana Mucinska", calling this "good documentary evidence."

An April 2011 DOJ email regarding a motion to unseal documents listed specific portions that should remain sealed, including references to "Sarah Kellen," "403," "113," and "371 conspiracy" charges. Prosecutors had considered conspiracy and witness tampering charges but never filed them.

The 2008 non-prosecution agreement between Epstein and the U.S. Attorney for the Southern District of Florida explicitly states: "the United States also agrees that it will not institute any criminal charges against any potential co-conspirators of Epstein, including but not limited to Sarah Kellen, Adriana Ross, Lesley Groff, or Nadia Marcinkova." However, the Second Circuit's 2024 opinion in United States v. Maxwell clarified that this agreement bound only the Florida district, not other U.S. Attorney's offices.

A significant breach of the NPA was documented but went unpunished. A June 12, 2009 letter from the U.S. Attorney's Office found that Epstein had "willfully violated one of the conditions of the Non-Prosecution Agreement" by filing a motion to dismiss in a civil case brought by "Jane Doe No. 101," who was on the victim list. Despite this documented breach, no consequences followed.

During Ghislaine Maxwell's 2021 trial, witnesses testified about Kellen's role. The trial record shows that "Kellen scheduled flights on Epstein's private jets and arranged for his victims to be on them" and "arranged 'massages' — up to three a day — where Epstein would rape and sexually abuse his victims." At Maxwell's June 2022 sentencing, U.S. District Judge Alison Nathan described Kellen as "a criminally responsible participant" in Epstein's crimes, though she was not charged in that case.

Visits to Epstein Properties#

The archive documents Kellen's extensive access to and coordination of activities at Epstein's various properties:

Manhattan Townhouse (9 East 71st Street)

Kellen coordinated services and activities at the Manhattan residence throughout the period documented. In May 2016, she helped arrange hair and makeup services for five women at the townhouse. Multiple civil complaints describe Kellen working at this location, gathering victim information and escorting girls upstairs to Epstein's massage room.

Palm Beach Mansion (358 El Brillo Way)

Court documents describe Kellen's regular presence at the Palm Beach property during the 2002-2008 period. The October 2008 court opinion describes how "Upon arrival at Epstein's mansion, Robson would introduce each victim to Kellen, who gathered the girl's personal information. Defendant Kellen would then bring the girl up a flight of stairs to a bedroom that contained a massage table." The Palm Beach Probable Cause Affidavit confirms that 358 El Brillo Way was the primary location of abuse, where Kellen's standardized procedure—recording victims' telephone numbers and names, setting up the massage table, providing oils, and informing victims that "Jeff would be in, in a minute"—was witnessed by multiple victims. Palm Beach police found phone logs "signed by Kellen" with names of teenagers called for "work" confirmation, according to reporting on the investigation. These message pads, recovered during the August 2005 search of Epstein's Palm Beach residence, contained victim names and phone numbers and also included messages from Jean-Luc Brunel describing "young girls" he wanted Epstein to meet.

Little St. James Island

Flight logs document Kellen traveling to and from St. Thomas, with coordination emails referencing island operations. A January 2006 email about island staff scheduling copied Kellen on decisions about when to inform staff about changes. Flight logs show multiple trips to TIST (St. Thomas airport) with Kellen as a passenger.

Santa Fe Ranch

Composite flight records document Kellen traveling from Santa Fe (SAF) to Teterboro in August 2002 with Epstein, Maxwell, and multiple young women.

International Travel

Beyond U.S. properties, flight logs show Kellen accompanied Epstein on international trips, including to the Bahamas (MYEF) in June 2002. Her correspondence under the "Kensington" alias regarding Morocco property suggests potential visits there, though the archive does not definitively document trips to Morocco.

Criminal Activity#

The archive documents conduct falling within the scope of multiple federal criminal statutes. While Sarah Kellen has never been charged with crimes, the evidence shows her participation in conduct prosecutors investigated for potential prosecution.

Federal prosecutors in 2008 prepared evidence showing Kellen's role in recruiting, coordinating, and facilitating the sexual abuse of minors by Epstein. Court documents describe Kellen gathering personal information from underage girls, escorting them to rooms where Epstein would abuse them, and being present when Epstein paid them. Prosecutors documented 156 phone calls between Kellen and one minor victim. The MJ v. Epstein RICO complaint states that "At Epstein's specific direction, Kellen spoke to the recruiters about subjects such as finding more minor girls to satisfy Epstein's criminal sexual appetite" and that "the term 'work' was a code or slang word used by the various criminal enterprise members to avoid detection by law enforcement." This conduct falls within the scope of 18 U.S.C. § 1591 (sex trafficking of minors).

Flight logs document Kellen traveling interstate and internationally with Epstein and minor victims, including a June 21, 2002 flight from West Palm Beach to the Bahamas with Virginia Roberts (then 17), Ghislaine Maxwell, and others. This interstate transportation of minors for sexual purposes falls within the scope of 18 U.S.C. §§ 2421-2423 (Mann Act violations).

Court records indicate Kellen conspired with Epstein and others to recruit and transport minors for sexual abuse over multiple years. The civil complaint in Jane Doe No. 1 alleged a "conspiracy between the three Defendants" including Kellen "to do an unlawful act, that is, to commit the tort of sexual assault of a minor," with Kellen committing overt acts in furtherance. This conduct falls within the scope of 18 U.S.C. § 371 (conspiracy to commit federal offenses).

Federal documents indicate prosecutors considered witness tampering charges against Epstein for intimidating "Sarah Kellen, Leslie Groff and Nadia Marcinkova" during the FBI investigation. This suggests Kellen may herself have been subjected to obstruction. The CVRA motion reveals that on September 15, 2007, prosecutors discussed charging Epstein with obstruction of justice for "pressuring one of his co-conspirators to prevent her from turning over evidence or complying with a previously-served grand jury subpoena," and the next day discussed a second charge for "assaulting a different co-conspirator." The April 2011 DOJ email regarding documents to keep sealed referenced potential charges against Kellen under "1512" (witness tampering) and "113" (assault within maritime/territorial jurisdiction), though these charges were never filed.

The archive also documents evidence linking Epstein's operation to international visa fraud schemes. The June 2008 travel authorization memo detailed witness information that "Epstein and the head of MC2, Jean Luc Brunel, worked together to obtain fraudulent visas to bring potential models to the United States" and that "Epstein selected some of the underage girls to come to the United States even though Brunel never intended to use them as models so that Epstein could engage in sexual activity with them." This international trafficking scheme, documented on the same message pads Kellen maintained, falls within the scope of federal immigration and trafficking violations.

The conduct documented in the archive thus falls within the scope of federal sex trafficking, Mann Act, conspiracy, obstruction, and immigration fraud statutes detailed in Criminal Statutes. Despite the 2008 non-prosecution agreement providing immunity in the Southern District of Florida, prosecutors in the Southern District of New York maintained they were not bound by that agreement and could bring charges. To date, no charges have been filed against Sarah Kellen in any jurisdiction.