DOJ-OGR-00010377.jpg

Case 1:20-cr-00330-PAE Document657_ Filed 04/29/22 Page11of 45 minors for sexual abuse. Trial Tr. at 714-19. Applying that expert testimony to the witnesses’ testimony, the Government argued that the Defendant’s conduct as to each victim followed a uniform “playbook.” E.g., id. at 2184 (“She ran the same playbook again and again and again. She manipulated her victims and she groomed them for sexual abuse.”’), 2853 (“The patterns you saw throughout this trial, the playbook that Maxwell ran for years, is just one of the many ways that you know that Maxwell is guilty.”). And the Government emphasized the many similarities in the Defendant’s conduct as recounted by all four witnesses. /d. at 2848 (“The similarities between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful evidence of the defendant’s guilt. So I want to talk to you about the playbook that Maxwell ran again and again and again.”), 2901 (‘““Four women have testified at this trial about Maxwell. They all describe the same woman, the same playbook.”). Carolyn was the only witness who testified regarding Count Five. The Government argued that her testimony “was corroborated by what Annie and Kate and Jane told [the jury] about Maxwell and how she operated for years.” Id. at 2880; see also id. at 2895—96 (“Maxwell groomed both Annie and Carolyn as part of a broader agreement with Epstein to provide him with underage girls for abuse.”). The Government, in short, argued that the Defendant engaged in substantially the same operations for a decade as to all victims under both Counts Three and Five. The Government responds that while the Defendant and Epstein continuously conspired to sexually abuse minor victims, their conduct beginning in 2001 evolved from developing one- on-one relationships with their victims to include a “pyramid scheme of abuse,” by which they acquired underage girls by paying them for so-called “massage” appointments. Gov. Br. at 32 (quoting Trial Tr. at 40). To be sure, the Government in both its opening statement and its closing arguments explained that the Defendant and Epstein’s abuse “evolved over the course of 11 DOJ-OGR-00010377