{
  "document_metadata": {
    "page_number": "33",
    "document_number": "87",
    "date": "07/27/2023",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 22-1426, Document 87, 07/27/2023, 3548202, Page33 of 35\n\n1892. But Kimberly Espinoza did. Id. In fact, according to Espinoza, by the time Kellen began working for Epstein in 2001-2002, Ms. Maxwell and Epstein “went their separate ways” (Tr. 2370) and Kellen sat in the office where Ms. Maxwell used to sit and managed Epstein’s properties. Tr. 2337, 2370-71, 2375-6, 2382. Carolyn corroborates this fact when she testified that there was a clean break in time between when she dealt with Maxwell and when she dealt with Kellen. Tr. 1527. There is, quite simply, not a single witness that testified that Ms. Maxwell supervised Kellen in any capacity, much less in connection with anything of a criminal nature. Nor does the existence of an earlier version of the 2005 household manual, attested to by Juan Alessi (Tr. 808) or flight records support a finding that Ms. Maxwell supervised Sarah Kellen as a criminal participant. This is the thin gruel upon which the court based its finding (see A417) and it is simply not sufficient to support the enhancement even by a preponderance of the evidence.\n\nCONCLUSION\n\nFor the reasons stated here and in Points I and II of Ms. Maxwell’s Principal Brief, the Convictions should be reversed, and the Indictment, or a portion thereof, be dismissed and a new trial ordered on any remaining counts. Alternatively, for the reasons stated in Point I, the matter should be remanded to the District Court for a hearing. For the reasons stated in Points III (Point II herein) and IV of Ms. Maxwell’s Principal Brief, the Convictions should be reversed, and the matter remanded for a new trial.\n\n27\nDOJ-OGR-00021775",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 22-1426, Document 87, 07/27/2023, 3548202, Page33 of 35",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "1892. But Kimberly Espinoza did. Id. In fact, according to Espinoza, by the time Kellen began working for Epstein in 2001-2002, Ms. Maxwell and Epstein “went their separate ways” (Tr. 2370) and Kellen sat in the office where Ms. Maxwell used to sit and managed Epstein’s properties. Tr. 2337, 2370-71, 2375-6, 2382. Carolyn corroborates this fact when she testified that there was a clean break in time between when she dealt with Maxwell and when she dealt with Kellen. Tr. 1527. There is, quite simply, not a single witness that testified that Ms. Maxwell supervised Kellen in any capacity, much less in connection with anything of a criminal nature. Nor does the existence of an earlier version of the 2005 household manual, attested to by Juan Alessi (Tr. 808) or flight records support a finding that Ms. Maxwell supervised Sarah Kellen as a criminal participant. This is the thin gruel upon which the court based its finding (see A417) and it is simply not sufficient to support the enhancement even by a preponderance of the evidence.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "CONCLUSION",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "For the reasons stated here and in Points I and II of Ms. Maxwell’s Principal Brief, the Convictions should be reversed, and the Indictment, or a portion thereof, be dismissed and a new trial ordered on any remaining counts. Alternatively, for the reasons stated in Point I, the matter should be remanded to the District Court for a hearing. For the reasons stated in Points III (Point II herein) and IV of Ms. Maxwell’s Principal Brief, the Convictions should be reversed, and the matter remanded for a new trial.",
      "position": "main body"
    },
    {
      "type": "printed",
      "content": "27",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00021775",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Kimberly Espinoza",
      "Kellen",
      "Ms. Maxwell",
      "Epstein",
      "Carolyn",
      "Juan Alessi",
      "Sarah Kellen"
    ],
    "organizations": [],
    "locations": [
      "District Court"
    ],
    "dates": [
      "07/27/2023",
      "2001",
      "2002",
      "2005"
    ],
    "reference_numbers": [
      "Case 22-1426",
      "Document 87",
      "3548202",
      "Tr. 2370",
      "Tr. 2337",
      "Tr. 2370-71",
      "Tr. 2375-6",
      "Tr. 2382",
      "Tr. 1527",
      "Tr. 808",
      "A417",
      "DOJ-OGR-00021775"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell. The text is well-formatted and printed, with no visible handwriting or stamps. The document includes references to various court transcripts and exhibits."
}