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Case 1:20-cr-00330-PAE Document670 Filed 06/22/22 Page8of55 side with Epstein, Maxwell also received a townhouse that Epstein bought for her in New York City, and Epstein transferred a total of approximately $23 million to Maxwell during the timeframe of the conspiracy. (/d.). In addition to her role as Epstein’s girlfriend, the defendant also supervised Epstein’s households and enjoyed a lifestyle of extraordinary wealth. (/d.). The defendant relished her role as “the lady of the house.” (PSR 4 24). When the defendant took charge of Epstein’s homes, she imposed strict rules for staff. For example, the defendant helped author and implement a household manual, which contained rules for operating the Palm Beach house to “anticipate the needs of Mr Epstein, Ms Maxwell and their guests.” (/d.). Staff were directed to have two sizes of notepads marked “Ghislaine Maxwell” and “Lady Ghislaine,” in addition to Epstein’s notepads. (/d.). Staff were also instructed on Epstein and the defendant’s breakfast preferences, and the items to keep in Epstein and the defendant’s respective bathrooms. (/d.). The defendant’s instructions extended to massages: she specified the massage oils and lotions for the Palm Beach house. (/d.). In short, the defendant was waited on hand and foot. To protect her criminal activities from exposure, the defendant also fostered a culture of silence at Epstein’s homes. (PSR 49 25, 79). The Palm Beach household manual made clear that staff were to “see nothing, hear nothing, say nothing, except to answer a question directed at” that staff member. (PSR ¥ 25; see also PSR at 49 (manual instructed employees to “NEVER disclose Mr Epstein or Ms Maxwell’s activities or whereabouts to anyone’”’)). And the defendant reinforced the messages of the household manual. She directed Juan Alessi, the former manager of Epstein’s Palm Beach villa, to speak to Epstein only when spoken to and not to look Epstein in the eyes. (PSR ¢ 25). Alessi explained during his trial testimony that he understood he was to be “blind, deaf and dumb” and “to say nothing of their lives.” (/d.). DOJ-OGR-00010543