mirror-epstein-docs/results/IMAGES008/DOJ-OGR-00021031.json

{
  "document_metadata": {
    "page_number": "205",
    "document_number": "58",
    "date": "02/28/2023",
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  "full_text": "Case 22-1426, Document 58, 02/28/2023, 3475901, Page205 of 221\nA-405\n\nM6SQmax1\n30\n1\nMS. MOE: Yes, your Honor. Looking at the text of the\n2\napplication note -- again, it's unclear from some case law on\n3\nthis, but under the text of the application note, if we're\n4\nlooking to one criminal participant, we would direct the\n5\nCourt's attention to Sarah Kellen.\n6\nTHE COURT: And the leadership over her as opposed to\n7\nEpstein being the leader over her or them being -- Kellen sort\n8\nof replacing the defendant's role, could you focus my mind on\n9\nwhat specifically you point to to show supervision and\n10\nleadership by Ms. Maxwell over Ms. Kellen.\n11\nMS. MOE: Yes, your Honor.\n12\nThe trial evidence was that Sarah Kellen became an\n13\nassistant, and that she worked for both Maxwell and Epstein.\n14\nEssentially, when you look at defendant's role in earlier\n15\nyears, she was doing things like calling victims and arranging\n16\nfor massage appointments. As the scheme shifted, they brought\n17\nin another member of the scheme beneath them in the structure\n18\nand hierarchy of the scheme. The defendant remained a close\n19\nassociate. She was often traveling with them, often traveling\n20\nwith Kellen together. So as Kellen took on some of the tasks\n21\nthat were then delegated to a lower member of the conspiracy,\n22\nthe defendant was higher up in the leadership structure.\n23\nThere wasn't direct evidence about, you know, the\n24\ndefendant directly instructing Kellen to make a certain phone\n25\ncall, and we acknowledge that, but we think the inference is\nSOUTHERN DISTRICT REPORTERS, P.C.\n(212) 805-0300\nDOJ-OGR-00021031",
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      "content": "Case 22-1426, Document 58, 02/28/2023, 3475901, Page205 of 221",
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      "content": "A-405",
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      "content": "M6SQmax1\n30",
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      "content": "MS. MOE: Yes, your Honor. Looking at the text of the application note -- again, it's unclear from some case law on this, but under the text of the application note, if we're looking to one criminal participant, we would direct the Court's attention to Sarah Kellen.",
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    {
      "type": "printed",
      "content": "THE COURT: And the leadership over her as opposed to Epstein being the leader over her or them being -- Kellen sort of replacing the defendant's role, could you focus my mind on what specifically you point to to show supervision and leadership by Ms. Maxwell over Ms. Kellen.",
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      "type": "printed",
      "content": "MS. MOE: Yes, your Honor.",
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    {
      "type": "printed",
      "content": "The trial evidence was that Sarah Kellen became an assistant, and that she worked for both Maxwell and Epstein. Essentially, when you look at defendant's role in earlier years, she was doing things like calling victims and arranging for massage appointments. As the scheme shifted, they brought in another member of the scheme beneath them in the structure and hierarchy of the scheme. The defendant remained a close associate. She was often traveling with them, often traveling with Kellen together. So as Kellen took on some of the tasks that were then delegated to a lower member of the conspiracy, the defendant was higher up in the leadership structure.",
      "position": "body"
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    {
      "type": "printed",
      "content": "There wasn't direct evidence about, you know, the defendant directly instructing Kellen to make a certain phone call, and we acknowledge that, but we think the inference is",
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      "content": "SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300",
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      "content": "DOJ-OGR-00021031",
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  "entities": {
    "people": [
      "MS. MOE",
      "Sarah Kellen",
      "Epstein",
      "Ms. Maxwell"
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    "organizations": [
      "SOUTHERN DISTRICT REPORTERS, P.C."
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    "locations": [],
    "dates": [
      "02/28/2023"
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      "Case 22-1426",
      "Document 58",
      "3475901",
      "Page205 of 221",
      "DOJ-OGR-00021031"
    ]
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