mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00011551.json

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    "page_number": "32",
    "document_number": "737",
    "date": "07/22/22",
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  "full_text": "Case 1:20-cr-00330-PAE Document 737 Filed 07/22/22 Page 32 of 101\nM6SQmax1\nalready been decided or conceded by the defendant. The court found they were leader or the defendant didn't contest that, so the issue was only about whether the criminal activity was otherwise extensive. So that is not -- that is clear under Second Circuit law, that they have to supervise another criminal participant, and it's clear from the guidelines too, as the government concedes.\nLet's just talk a bit about Sarah Kellen. I don't think it is a fair inference to say from the trial record that Ms. Maxwell was supervising Sarah Kellen. In fact, the inference is exactly the opposite. And you can rely on Carolyn's testimony alone for that; that she herself testified that there was a clear break between when she says that Ms. Maxwell was calling her to schedule for massage appointments versus when Sarah Kellen took over and scheduled for massage appointments. They did not overlap. There was a break. That is corroborated by Juan Alessi no less, who said the same thing. He said Sarah Kellen came at the end of my employment, to his recollection, and as soon as she got there, she took over the responsibility of scheduling the massage appointments. Again, a clear break.\nWhat the record shows is that there was a replacement. Sarah Kellen replaced Ms. Maxwell, at least according to the trial testimony; not that there was some sort of ongoing supervision by Ms. Maxwell over Sarah Kellen. It couldn't be\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00011551",
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      "content": "M6SQmax1\nalready been decided or conceded by the defendant. The court found they were leader or the defendant didn't contest that, so the issue was only about whether the criminal activity was otherwise extensive. So that is not -- that is clear under Second Circuit law, that they have to supervise another criminal participant, and it's clear from the guidelines too, as the government concedes.\nLet's just talk a bit about Sarah Kellen. I don't think it is a fair inference to say from the trial record that Ms. Maxwell was supervising Sarah Kellen. In fact, the inference is exactly the opposite. And you can rely on Carolyn's testimony alone for that; that she herself testified that there was a clear break between when she says that Ms. Maxwell was calling her to schedule for massage appointments versus when Sarah Kellen took over and scheduled for massage appointments. They did not overlap. There was a break. That is corroborated by Juan Alessi no less, who said the same thing. He said Sarah Kellen came at the end of my employment, to his recollection, and as soon as she got there, she took over the responsibility of scheduling the massage appointments. Again, a clear break.\nWhat the record shows is that there was a replacement. Sarah Kellen replaced Ms. Maxwell, at least according to the trial testimony; not that there was some sort of ongoing supervision by Ms. Maxwell over Sarah Kellen. It couldn't be",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00011551",
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  "entities": {
    "people": [
      "Sarah Kellen",
      "Ms. Maxwell",
      "Carolyn",
      "Juan Alessi"
    ],
    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "07/22/22"
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      "1:20-cr-00330-PAE",
      "737",
      "DOJ-OGR-00011551"
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