DOJ-OGR-00010557.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 22 of 55
Q: And about how old were you the last time you went over to his house?
A: Eighteen
(Trial Tr. 1525). Carolyn further testified:
Q: Why did you stop going to Jeffrey Epstein’s house?
A: Because I became too old.
Q: How old were you?
A: 18.
(Tr. 1549). That testimony alone confirms that the offense conduct spanned the entirety of 2004,
and thus that the 2004 Manual applies.
The thrust of the defendant’s argument is that the Court should, at sentencing, discredit the
testimony of a crime victim, when a jury has credited that victim and found the defendant guilty.
Indeed, the jury convicted the defendant of Count Six, which solely relates to Carolyn. In service
of her lawless argument, the defendant asks the Court both to reject Carolyn’s testimony and to do
so in the face of documentary evidence that establishes that Carolyn told the truth at trial about
when the offense conduct ended. As the defendant acknowledges, a message book seized from
the Palm Beach residence contains two messages from Carolyn, using her first and last name: one
in November 2004 (GX 4B), and one dated March 1, 2005 (GX 4F). The defendant asks the Court
to ignore this evidence that Carolyn told the truth at trial, speculating that perhaps the message
book is not authentic, because the Government did not offer these excerpts at trial. That
speculation is baseless. As the defendant knows, the Government streamlined its proof at trial and
elected not to call several witnesses, including employees who worked for Epstein in 2005 when
this book was used. Given the volume of messages relating to Carolyn that were admitted at trial,
and her own testimony about the duration of the conspiracy, the testimony from the additional
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DOJ-OGR-00010557
Extracted Information
Document Details
| Filename | DOJ-OGR-00010557.jpg |
| File Size | 633.2 KB |
| OCR Confidence | 94.8% |
| Has Readable Text | Yes |
| Text Length | 1,813 characters |
| Indexed | 2026-02-03 18:00:04.218515 |