{
  "document_metadata": {
    "page_number": "29",
    "document_number": "670",
    "date": "06/22/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 29 of 55\nsomeone who had been trained not to ask questions and who worked in a culture of silence carried out those necessary tasks. Both Larry Visoski and David Rodgers played the essential role of transporting minor victims to different locations, providing a discreet means of ensuring that Epstein had access to minor girls for his sexual gratification when he traveled. The defendant organized all of those individuals by telling Virginia to show Carolyn what to do, by scheduling Carolyn's appointments, by giving Alessi innumerable directions, and by providing instructions to both pilots. (PSR ¶¶ 24, 62, 66). Additionally, the defendant supervised all of Epstein's staff for years, thereby running an extensive operation. Those individuals more than satisfy the definition of an extensive operation in which the defendant served as an organizer.\nIn any event, this enhancement applies even under the defense's interpretation of U.S.S.G. § 3B1.1 because Maxwell also supervised at least one other knowing participant in Sarah Kellen. Larry Visoski testified that he understood Sarah Kellen to be one of Maxwell's assistants. (Tr. 140). Even if he was not certain that Kellen had that precise title, his understanding is consistent with Maxwell's role as second in command beneath Epstein over all other employees. (Tr. 139). Consistent with Visoski's recollection, David Rodgers testified his understanding was that \"Sarah was more of Ghislaine's assistant, but actually she was probably both,\" an assistant to the defendant and an assistant to Epstein, again confirming that the defendant supervised Kellen. (Tr. 1890). Rodgers also testified that Maxwell was \"number two\" below Epstein among Epstein's employees. (Tr. 1809-10). Alessi testified that he did not know exactly what Kellen's job responsibilities were, but Kellen took over the \"scheduling of massages\" in approximately 2002. (Tr. 833). Carolyn also recalled that even after Kellen took over calling to schedule massages, Maxwell was still present inside the Palm Beach residence when Carolyn arrived for massage appointments. (Tr. 1527). Moreover, the household manual makes clear that as of 2005, Maxwell 27\nDOJ-OGR-00010564",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 29 of 55",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "someone who had been trained not to ask questions and who worked in a culture of silence carried out those necessary tasks. Both Larry Visoski and David Rodgers played the essential role of transporting minor victims to different locations, providing a discreet means of ensuring that Epstein had access to minor girls for his sexual gratification when he traveled. The defendant organized all of those individuals by telling Virginia to show Carolyn what to do, by scheduling Carolyn's appointments, by giving Alessi innumerable directions, and by providing instructions to both pilots. (PSR ¶¶ 24, 62, 66). Additionally, the defendant supervised all of Epstein's staff for years, thereby running an extensive operation. Those individuals more than satisfy the definition of an extensive operation in which the defendant served as an organizer.",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "In any event, this enhancement applies even under the defense's interpretation of U.S.S.G. § 3B1.1 because Maxwell also supervised at least one other knowing participant in Sarah Kellen. Larry Visoski testified that he understood Sarah Kellen to be one of Maxwell's assistants. (Tr. 140). Even if he was not certain that Kellen had that precise title, his understanding is consistent with Maxwell's role as second in command beneath Epstein over all other employees. (Tr. 139). Consistent with Visoski's recollection, David Rodgers testified his understanding was that \"Sarah was more of Ghislaine's assistant, but actually she was probably both,\" an assistant to the defendant and an assistant to Epstein, again confirming that the defendant supervised Kellen. (Tr. 1890). Rodgers also testified that Maxwell was \"number two\" below Epstein among Epstein's employees. (Tr. 1809-10). Alessi testified that he did not know exactly what Kellen's job responsibilities were, but Kellen took over the \"scheduling of massages\" in approximately 2002. (Tr. 833). Carolyn also recalled that even after Kellen took over calling to schedule massages, Maxwell was still present inside the Palm Beach residence when Carolyn arrived for massage appointments. (Tr. 1527). Moreover, the household manual makes clear that as of 2005, Maxwell",
      "position": "main content"
    },
    {
      "type": "printed",
      "content": "27",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010564",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Larry Visoski",
      "David Rodgers",
      "Epstein",
      "Virginia",
      "Carolyn",
      "Alessi",
      "Maxwell",
      "Sarah Kellen",
      "Ghislaine"
    ],
    "organizations": [],
    "locations": [
      "Palm Beach"
    ],
    "dates": [
      "06/22/22",
      "2002",
      "2005"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "670",
      "29",
      "55",
      "DOJ-OGR-00010564"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ghislaine Maxwell, detailing her involvement in Jeffrey Epstein's criminal activities. The text discusses the roles of various individuals in Epstein's organization and Maxwell's supervisory role."
}