[GRADE B — Public record inference]
| Field | Value |
|---|---|
| Confidence | HIGH |
| Graph ID | ioe-entity-sarah_kellen |
| Combined Score | 19.0 |
| Legal Status | Named co-conspirator in NPA. Never charged. |
The consent order states CC-2 was specifically flagged by DB compliance as a Butterfly Trust beneficiary. RC-1 (Tazia Smith) confirmed CC-2 "was accused as a co-conspirator in a case but was never brought to trial nor ever convicted." Kellen was named in the NPA, invoked the Fifth Amendment in depositions, and has been publicly identified as a Butterfly Trust beneficiary in multiple reports. CC-1 and CC-2 both invoked the Fifth per the consent order.
WHAT THIS SHOWS AND DOES NOT SHOW: The consent order's description of CC-2 — NPA co-conspirator who invoked the Fifth, Butterfly Trust beneficiary, never convicted — matches Kellen's publicly documented status precisely. This is the strongest of the three co-conspirator identifications. Kellen has not been convicted of any crime and received immunity under the NPA.