mirror-epstein-docs/results/IMAGES004/DOJ-OGR-00010430.json

{
  "document_metadata": {
    "page_number": "13",
    "document_number": "662",
    "date": "06/15/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 13 of 29\nvariance would provide just punishment for the offense and promote respect for the law because it would punish Ms. Maxwell only for the conduct for which she was directly responsible, rather than artificially inflating her sentence based on two months' worth of Epstein's criminal conduct in which she was not involved.\nThere is no evidence in the record that Ms. Maxwell did anything in furtherance of the conspiracy in November or December 2004. In fact, the evidence clearly showed that by that time, Ms. Maxwell was in a committed relationship with another man and Sarah Kellen had taken over responsibility for scheduling the massage appointments at the Palm Beach residence.\nMs. Maxwell's assistant, Kimberly Espinosa, testified that by 2002 Ms. Maxwell had \"moved on\" from Epstein, had stopped coming to the office, and had begun a long-term relationship with Ted Waitt. (Tr. 2370-71, 2374, 2378-80). Juan Alessi testified that Sarah Kellen, whom he recalled seeing for the first time towards the end of his employment in 2002, \"immediately took over\" responsibility for answering the phones and scheduling the massage appointments at the Palm Beach residence as soon as she was hired. (Tr. 832-33). Carolyn testified that Ms. Maxwell called her to schedule massage appointments only in \"the first year or two\" and that Sarah Kellen called her thereafter. (Tr. 1527). In sum, the record is clear that by 2002 or 2003 at the latest Ms. Maxwell had stopped actively participating in the offense conduct and had been replaced by Kellen.\nApplying the 2004 Guidelines would significantly increase Ms. Maxwell's sentencing range based on a finding by a mere preponderance that her co-conspirator Epstein engaged in offense conduct in the final two months of 2004 that Ms. Maxwell had nothing to do with and was not personally responsible for. That result would be fundamentally unjust and contrary to the purposes of sentencing. See United States v. Reuter, 463 F.3d 792, 793 (7th Cir. 2006)\n9\nDOJ-OGR-00010430",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 13 of 29",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "variance would provide just punishment for the offense and promote respect for the law because it would punish Ms. Maxwell only for the conduct for which she was directly responsible, rather than artificially inflating her sentence based on two months' worth of Epstein's criminal conduct in which she was not involved.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "There is no evidence in the record that Ms. Maxwell did anything in furtherance of the conspiracy in November or December 2004. In fact, the evidence clearly showed that by that time, Ms. Maxwell was in a committed relationship with another man and Sarah Kellen had taken over responsibility for scheduling the massage appointments at the Palm Beach residence.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Ms. Maxwell's assistant, Kimberly Espinosa, testified that by 2002 Ms. Maxwell had \"moved on\" from Epstein, had stopped coming to the office, and had begun a long-term relationship with Ted Waitt. (Tr. 2370-71, 2374, 2378-80). Juan Alessi testified that Sarah Kellen, whom he recalled seeing for the first time towards the end of his employment in 2002, \"immediately took over\" responsibility for answering the phones and scheduling the massage appointments at the Palm Beach residence as soon as she was hired. (Tr. 832-33). Carolyn testified that Ms. Maxwell called her to schedule massage appointments only in \"the first year or two\" and that Sarah Kellen called her thereafter. (Tr. 1527). In sum, the record is clear that by 2002 or 2003 at the latest Ms. Maxwell had stopped actively participating in the offense conduct and had been replaced by Kellen.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Applying the 2004 Guidelines would significantly increase Ms. Maxwell's sentencing range based on a finding by a mere preponderance that her co-conspirator Epstein engaged in offense conduct in the final two months of 2004 that Ms. Maxwell had nothing to do with and was not personally responsible for. That result would be fundamentally unjust and contrary to the purposes of sentencing. See United States v. Reuter, 463 F.3d 792, 793 (7th Cir. 2006)",
      "position": "bottom"
    },
    {
      "type": "printed",
      "content": "9",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010430",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Ms. Maxwell",
      "Epstein",
      "Sarah Kellen",
      "Kimberly Espinosa",
      "Ted Waitt",
      "Juan Alessi",
      "Carolyn"
    ],
    "organizations": [],
    "locations": [
      "Palm Beach"
    ],
    "dates": [
      "November 2004",
      "December 2004",
      "2002",
      "2003",
      "2004",
      "2006"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "Document 662",
      "Tr. 2370-71",
      "Tr. 2374",
      "Tr. 2378-80",
      "Tr. 832-33",
      "Tr. 1527",
      "463 F.3d 792",
      "793",
      "DOJ-OGR-00010430"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case of Ms. Maxwell, discussing her involvement in a conspiracy with Epstein and the appropriate sentencing guidelines. The text is printed and there are no visible stamps or handwritten notes."
}