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Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 24 of55 affirmative steps to withdraw.” Meneilly, 28 F. App’x at 32 (citations omitted). The defendant has not claimed, as a legal matter, that there is any evidence that she withdrew from the conspiracy, nor could she. Instead, she argues, as a policy matter, that the 2004 Manual should not be applied because the defendant had “moved on,” an expression that has no legal meaning. More importantly, documentary evidence establishes that the defendant remained a close associate of Jeffrey Epstein for multiple years after 2002. In particular: e Flight records reflect that the defendant flew on Epstein’s private jet 49 times in 2003, 19 times in 2004, and 16 times in 2005. Regarding 2004 in particular, the flight records for that year reflect that the defendant flew on Epstein’s private jet twice in November 2004 and once in December 2004, which makes clear that the defendant was still traveling with Epstein after the Guidelines were amended and while the conspiracy was ongoing. (GX 662). e In October 2005, the Palm Beach Police Department executed a search warrant at the Palm Beach residence, and discovered the defendant’s desk, upon which a notepad with her named stationary was sitting. (GX 285). The setup of the defendant’s desk—and instructions that make clear the defendant was a forceful presence in the house—are set forth in the household manual, which is dated February 14, 2005. (GX 606). e Travel agency records from Shopper’s Travel—offered by the defendant at trial—reflect that Epstein paid for the defendant’s flights through at least 2006. (DX RS-1 (listing a May 1, 2006 flight on Epstein’s account)). e Bank records reflect that, as of 2007, Epstein transferred $7,759,793.40 to the defendant’s personal bank account. 22 DOJ-OGR-00010559