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Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 29 of55
someone who had been trained not to ask questions and who worked in a culture of silence carried
out those necessary tasks. Both Larry Visoski and David Rodgers played the essential role of
transporting minor victims to different locations, providing a discreet means of ensuring that
Epstein had access to minor girls for his sexual gratification when he traveled. The defendant
organized all of those individuals by telling Virginia to show Carolyn what to do, by scheduling
Carolyn’s appointments, by giving Alessi innumerable directions, and by providing instructions to
both pilots. (PSR [fj 24, 62, 66). Additionally, the defendant supervised all of Epstein’s staff for
years, thereby running an extensive operation. Those individuals more than satisfy the definition
of an extensive operation in which the defendant served as an organizer.
In any event, this enhancement applies even under the defense’s interpretation of U.S.S.G.
§ 3B1.1 because Maxwell also supervised at least one other knowing participant in Sarah Kellen.
Larry Visoski testified that he understood Sarah Kellen to be one of Maxwell’s assistants. (Tr.
140). Even if he was not certain that Kellen had that precise title, his understanding is consistent
with Maxwell’s role as second in command beneath Epstein over all other employees. (Tr. 139).
Consistent with Visoski’ s recollection, David Rodgers testified his understanding was that “Sarah
was more of Ghislaine’s assistant, but actually she was probably both,” an assistant to the
defendant and an assistant to Epstein, again confirming that the defendant supervised Kellen. (Tr.
1890). Rodgers also testified that Maxwell was “number two” below Epstein among Epstein’s
employees. (Tr. 1809-10). Alessi testified that he did not know exactly what Kellen’s job
responsibilities were, but Kellen took over the “scheduling of massages” in approximately 2002.
(Tr. 833). Carolyn also recalled that even after Kellen took over calling to schedule massages,
Maxwell was still present inside the Palm Beach residence when Carolyn arrived for massage
appointments. (Tr. 1527). Moreover, the household manual makes clear that as of 2005, Maxwell
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Document Details
| Filename | DOJ-OGR-00010564.jpg |
| File Size | 764.4 KB |
| OCR Confidence | 94.2% |
| Has Readable Text | Yes |
| Text Length | 2,261 characters |
| Indexed | 2026-02-03 18:00:09.878235 |