mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010563.json

{
  "document_metadata": {
    "page_number": "28",
    "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 28 of 55 defendants' direction. Rubenstein, 403 F.3d at 99. The same analysis applies with equal force here. Even if the defendant and Epstein were the only two knowing participants—which, as discussed below, they were not—their joint supervision and organization of a large array of unknowing participants created an otherwise extensive organization that qualifies for the enhancement under U.S.S.G. §3B1.1. Here, the defendant acted as an organizer and leader of a massive operation that spanned many years. In operating as the lady of the house and as Epstein's right hand, the defendant was responsible for overseeing and organizing extensive logistics involved in facilitating the sexual abuse of multiple minors and ensuring a culture of silence that prevented that scheme from being uncovered. Epstein and the defendant were two knowing participants who took the lead in identifying, enticing, and grooming minor girls to be abused. Additionally, Sarah Kellen, who handled the responsibilities of scheduling sexualized massages and took nude photographs of Carolyn (PSR ¶ 66; Tr. 1554-55), constituted a third knowing participant, which number the Circuit has found sufficient, together with additionally necessary unknowing participants, to be sufficient for the enhancement. See Archer, 671 F.3d at 166. Beyond those three knowing participants, Virginia and Carolyn both recruited other minor girls to provide paid sexualized massages to Epstein, thereby furthering the scheme and filling a crucial role in the scheme's later pyramid phase. Juan Alessi provided an essential role transporting Jane and Virginia to see Epstein, as well as scheduling appointments for massages, cleaning up the massage room after Epstein received sexualized massages, and putting away sex toys in the defendant's bathroom after Epstein received sexualized massages. (PSR ¶¶ 24, 57; Tr. 836-38). Those duties were essential both to the continued functioning of the scheme, by ensuring that minor girls were available to be abused, and to the avoidance of detection by ensuring that 26 DOJ-OGR-00010563",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 28 of 55",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "defendants' direction. Rubenstein, 403 F.3d at 99. The same analysis applies with equal force here. Even if the defendant and Epstein were the only two knowing participants—which, as discussed below, they were not—their joint supervision and organization of a large array of unknowing participants created an otherwise extensive organization that qualifies for the enhancement under U.S.S.G. §3B1.1.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "Here, the defendant acted as an organizer and leader of a massive operation that spanned many years. In operating as the lady of the house and as Epstein's right hand, the defendant was responsible for overseeing and organizing extensive logistics involved in facilitating the sexual abuse of multiple minors and ensuring a culture of silence that prevented that scheme from being uncovered. Epstein and the defendant were two knowing participants who took the lead in identifying, enticing, and grooming minor girls to be abused. Additionally, Sarah Kellen, who handled the responsibilities of scheduling sexualized massages and took nude photographs of Carolyn (PSR ¶ 66; Tr. 1554-55), constituted a third knowing participant, which number the Circuit has found sufficient, together with additionally necessary unknowing participants, to be sufficient for the enhancement. See Archer, 671 F.3d at 166.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Beyond those three knowing participants, Virginia and Carolyn both recruited other minor girls to provide paid sexualized massages to Epstein, thereby furthering the scheme and filling a crucial role in the scheme's later pyramid phase. Juan Alessi provided an essential role transporting Jane and Virginia to see Epstein, as well as scheduling appointments for massages, cleaning up the massage room after Epstein received sexualized massages, and putting away sex toys in the defendant's bathroom after Epstein received sexualized massages. (PSR ¶¶ 24, 57; Tr. 836-38). Those duties were essential both to the continued functioning of the scheme, by ensuring that minor girls were available to be abused, and to the avoidance of detection by ensuring that",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "26",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010563",
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  ],
  "entities": {
    "people": [
      "Rubenstein",
      "Epstein",
      "Sarah Kellen",
      "Carolyn",
      "Virginia",
      "Jane",
      "Juan Alessi"
    ],
    "organizations": [],
    "locations": [],
    "dates": [
      "06/22/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 670",
      "PSR ¶ 66",
      "Tr. 1554-55",
      "Archer, 671 F.3d at 166",
      "PSR ¶¶ 24, 57",
      "Tr. 836-38",
      "DOJ-OGR-00010563"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to a criminal case involving Jeffrey Epstein and associates. The text discusses the roles of various individuals in facilitating the sexual abuse of minors and the application of sentencing enhancements under U.S.S.G. §3B1.1."
}