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Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page9of29 2004, as the government asserts. The government’s claim is based solely on (1) Carolyn’s vague recollection that she stopped performing sexualized massages for Epstein in 2005 when she was 18 years old (Tr. 1525, 1549), and (2) two message pad slips that were never admitted in evidence. (GX 4-B, GX 4-F). Such meager and unreliable evidence is insufficient to support a finding that the offense conduct continued into the last two months of 2004, especially when that determination has such a significant effect on the recommended sentencing range. Instead, the credible evidence in the trial record established, at most, that Epstein was receiving sexualized massages in his Palm Beach residence through the summer of 2004, before the 2004 Guidelines took effect. Carolyn’s recollection that she was 18 when she stopped seeing Epstein cannot be credited. (Tr. 1525, 1549). Carolyn’s memory of the timeline of events—in particular, her age at the time of the relevant events—was demonstrably inconsistent and unreliable. For example, Carolyn initially testified that she was 14 years old when Virginia Roberts first took her to Epstein’s Palm Beach residence, which would have been in 2001. (Tr. 1518-19, 1525; GX-11). However, when Carolyn was confronted on cross-examination with her prior deposition testimony in 2009, she agreed that Virginia first took her to Epstein’s house in May or June 2002 when she was 15 years old, as she stated in her deposition. (Tr. 1570-73). Then on redirect Carolyn changed her testimony yet again and testified that she first went to Epstein’s house when she was 13 years old, which would have been in 2000. (Tr. 1693). Carolyn also testified that she was “15, going to be 16” when she recruited her friend Tatum to give Epstein massages, which would have been towards the end of 2002 or early 2003. (Tr. 1544). However, according to the message pad slips that were admitted in evidence, the earliest of which dates to January 2003, Tatum did not begin calling the Palm Beach residence until April 2004 when Carolyn was DOJ-OGR-00010426