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- "page_number": "30",
- "document_number": "779",
- "date": "08/22/22",
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- "full_text": "Case 1:20-cr-00330-PAE Document 779 Filed 08/22/22 Page 30 of 101\n\n1 MS. MOE: Yes, your Honor. Looking at the text of the\n2 application note -- again, it's unclear from some case law on\n3 this, but under the text of the application note, if we're\n4 looking to one criminal participant, we would direct the\n5 Court's attention to Sarah Kellen.\n6 THE COURT: And the leadership over her as opposed to\n7 Epstein being the leader over her or them being -- Kellen sort\n8 of replacing the defendant's role, could you focus my mind on\n9 what specifically you point to to show supervision and\n10 leadership by Ms. Maxwell over Ms. Kellen.\n11 MS. MOE: Yes, your Honor.\n12 The trial evidence was that Sarah Kellen became an\n13 assistant, and that she worked for both Maxwell and Epstein.\n14 Essentially, when you look at defendant's role in earlier\n15 years, she was doing things like calling victims and arranging\n16 for massage appointments. As the scheme shifted, they brought\n17 in another member of the scheme beneath them in the structure\n18 and hierarchy of the scheme. The defendant remained a close\n19 associate. She was often traveling with them, often traveling\n20 with Kellen together. So as Kellen took on some of the tasks\n21 that were then delegated to a lower member of the conspiracy,\n22 the defendant was higher up in the leadership structure.\n23 There wasn't direct evidence about, you know, the\n24 defendant directly instructing Kellen to make a certain phone\n25 call, and we acknowledge that, but we think the inference is\n\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00014777",
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- "content": "1 MS. MOE: Yes, your Honor. Looking at the text of the\n2 application note -- again, it's unclear from some case law on\n3 this, but under the text of the application note, if we're\n4 looking to one criminal participant, we would direct the\n5 Court's attention to Sarah Kellen.\n6 THE COURT: And the leadership over her as opposed to\n7 Epstein being the leader over her or them being -- Kellen sort\n8 of replacing the defendant's role, could you focus my mind on\n9 what specifically you point to to show supervision and\n10 leadership by Ms. Maxwell over Ms. Kellen.\n11 MS. MOE: Yes, your Honor.\n12 The trial evidence was that Sarah Kellen became an\n13 assistant, and that she worked for both Maxwell and Epstein.\n14 Essentially, when you look at defendant's role in earlier\n15 years, she was doing things like calling victims and arranging\n16 for massage appointments. As the scheme shifted, they brought\n17 in another member of the scheme beneath them in the structure\n18 and hierarchy of the scheme. The defendant remained a close\n19 associate. She was often traveling with them, often traveling\n20 with Kellen together. So as Kellen took on some of the tasks\n21 that were then delegated to a lower member of the conspiracy,\n22 the defendant was higher up in the leadership structure.\n23 There wasn't direct evidence about, you know, the\n24 defendant directly instructing Kellen to make a certain phone\n25 call, and we acknowledge that, but we think the inference is",
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- "content": "SOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00014777",
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- ],
- "entities": {
- "people": [
- "Sarah Kellen",
- "Epstein",
- "Maxwell",
- "Ms. MOE"
- ],
- "organizations": [
- "SOUTHERN DISTRICT REPORTERS, P.C."
- ],
- "locations": [],
- "dates": [
- "08/22/22"
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- "reference_numbers": [
- "1:20-cr-00330-PAE",
- "779",
- "DOJ-OGR-00014777"
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- },
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