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Extracted Text (OCR)
Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 28 of 55
defendants’ direction. Rubenstein, 403 F.3d at 99. The same analysis applies with equal force
here. Even if the defendant and Epstein were the only two knowing participants—which, as
discussed below, they were not—their joint supervision and organization of a large array of
unknowing participants created an otherwise extensive organization that qualifies for the
enhancement under U.S.S.G. §3B1.1.
Here, the defendant acted as an organizer and leader of a massive operation that spanned
many years. In operating as the lady of the house and as Epstein’s right hand, the defendant was
responsible for overseeing and organizing extensive logistics involved in facilitating the sexual
abuse of multiple minors and ensuring a culture of silence that prevented that scheme from being
uncovered. Epstein and the defendant were two knowing participants who took the lead in
identifying, enticing, and grooming minor girls to be abused. Additionally, Sarah Kellen, who
handled the responsibilities of scheduling sexualized massages and took nude photographs of
Carolyn (PSR § 66; Tr. 1554-55), constituted a third knowing participant, which number the
Circuit has found sufficient, together with additionally necessary unknowing participants, to be
sufficient for the enhancement. See Archer, 671 F.3d at 166.
Beyond those three knowing participants, Virginia and Carolyn both recruited other minor
girls to provide paid sexualized massages to Epstein, thereby furthering the scheme and filling a
crucial role in the scheme’s later pyramid phase. Juan Alessi provided an essential role
transporting Jane and Virginia to see Epstein, as well as scheduling appointments for massages,
cleaning up the massage room after Epstein received sexualized massages, and putting away sex
toys in the defendant’s bathroom after Epstein received sexualized massages. (PSR 9 24, 57; Tr.
836-38). Those duties were essential both to the continued functioning of the scheme, by ensuring
that minor girls were available to be abused, and to the avoidance of detection by ensuring that
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DOJ-OGR-00010563
Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00010563.jpg |
| File Size | 741.3 KB |
| OCR Confidence | 94.7% |
| Has Readable Text | Yes |
| Text Length | 2,152 characters |
| Indexed | 2026-02-03 18:00:09.513166 |