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Case 1:20-cr-00330-PAE Document670 - Filed 06/22/22 Page 39 of55
operate the scheme, Maxwell and Epstein used many employees: pilots, household staff, personal
assistants, and drivers. Maxwell was central to operating the scheme and managing employees at
these properties. Most importantly, the offense conduct was extensive because so many young
girls were sexually exploited as a direct result of the defendant’s conduct. At trial, the evidence
established that Jane, Annie, Kate, Carolyn, Virginia, and Melissa were all exploited as a direct
result of the defendant’s actions.
The trial record also makes clear that there were many other victims who were harmed by
this conspiracy. First, Carolyn testified that she brought multiple additional minors, including
Melissa, to provide paid sexualized massages to Epstein. Although these minors did not
necessarily interact directly with Maxwell, they were subjected to sexual abuse as a result of the
pyramid scheme that Maxwell and Epstein set in motion. Carolyn specifically recalled bringing
girls named Tatum and Amanda when they were under the age of 18 to provide paid sexualized
massages for Epstein. (Tr. 1543-44). Second, the defendant’s black book contained dozens of
entries under the heading “Massage — Florida,” and included entries referencing individuals’
parents. (GX 52). Third, records recovered from Epstein’s Palm Beach residence during a 2005
search by the Palm Beach Police Department reveal that additional minors provided Epstein with
sexualized massages between 2001 and 2004. In particular, message pads seized from the
residence contain multiple messages from underage girls who called to schedule massage
appointments. (GX 1, 2, 3, and 4). Lest there be any doubt that the individuals named in the
message pads were in fact minors providing sexualized massages to Epstein, many of the girls
identified in the messages were listed as identified minor victims of Epstein in connection with his
resolution of the investigation conducted by the U.S. Attorney’s Office for the Southern District
of Florida (“USAO-SDFL”). Specifically, in a letter dated July 10, 2008, the USAO-SDFL
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Document Details
| Filename | DOJ-OGR-00010574.jpg |
| File Size | 748.4 KB |
| OCR Confidence | 94.5% |
| Has Readable Text | Yes |
| Text Length | 2,179 characters |
| Indexed | 2026-02-03 18:00:16.268477 |