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Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 21 of 29
who was his employee. According to the record, there were several people employed by Epstein
who interacted with “Jane” and Annie Farmer and whom Ms. Maxwell supervised in her role as
manager of Epstein’s properties in the mid-late 1990s — e.g., Juan Alessi in Palm Beach and
various unnamed employees at Zorro Ranch. The record also reflects that Ms. Maxwell had
some role in coordinating payroll and expenses for Epstein pilots, Larry Visoski and David
Rodgers, who transported “Jane” on Epstein’s private planes. But these people had no
knowledge of the criminal conduct and do not qualify as criminally responsible participants for
the purposes of the aggravating role enhancement.
Similarly, there is no evidence in the trial record that Ms. Maxwell supervised another
criminal participant in the offenses against Carolyn. Apart from Epstein, Sarah Kellen was the
only other person identified in the trial record as a criminal participant in the offenses against
Carolyn. Among other things, Carolyn testified that Sarah Kellen scheduled massage
appointments for her and took nude pictures of her at the Palm Beach residence on one occasion.
(Tr. 1527-28; 1538-39). The record is clear, however, that Ms. Maxwell did not supervise Sarah
Kellen. Rather, Kellen was hired by Epstein as his assistant to replace Ms. Maxwell and take
over responsibility for scheduling massage appointments and other property management tasks at
a time when Ms. Maxwell was moving on from Epstein and was no longer actively managing the
day-to-day affairs of his residences.
For example, Cimberly Espinosa testified that Kellen was hired sometime between 2000-
2002 to be Epstein’s assistant and that she, and not Sarah Kellen, was Ms. Maxwell’s assistant
from when she was hired in 1996 up through the end of her employment in 2002. (Tr. 2332-33,
2376-77).° Espinosa further testified that in the last two years of her employment (2000-2002),
8 Larry Visoski initially testified that he thought Sarah Kellen was Ms. Maxwell’s assistant. (Tr. 139-40). But he
later clarified on cross-examination that he “didn’t know what her exact job” was and did not know whether Kellen
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Document Details
| Filename | DOJ-OGR-00010438.jpg |
| File Size | 718.9 KB |
| OCR Confidence | 95.2% |
| Has Readable Text | Yes |
| Text Length | 2,248 characters |
| Indexed | 2026-02-03 17:58:51.212436 |