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fe N Ww ws Oo OY ~] oO WO a oO a fe N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE M6SQmaxl MS. MOE: Yes, your Honor. application note -- again, i Document 737 t's unclear PAIS, but looking to one criminal under the text of participant, the appl Court's attention to Sarah Kel THE COURT: And the Filed 07/22/22 Looking at the text of Llen. lication note, we would direct Page 30 of 101 the from some case law on if we're the leadership over her as opposed to Kellen sort Epstein being the ] of replacing the defendant's role, ader over her or them being could you focus my mind on what specifically you point to to show supervision and leadership by Ms. Maxwell over Ms. Kellen. MS. MOE: Yes, your Honor. The trial evidence was that Sarah Kellen became an assistant, and that she worked for both Maxwell and Epstein. Essentially, years, in another member of and hierarchy of associate. with Kellen together. that wer for massage appointments. when you look at det she was doing things like callin As the schem Fendant's role in earlier g victims and arranging th scheme beneath the scheme. e shifted, they brought them in the structure The defendant remained a close She was often travel There wasn't direct defendant directly instructing Kellen So as Kel videnc then delegated to a lower member of ing with them, often traveling llen took on some of the tasks the conspiracy, the defendant was higher up in the leadership structure. call, and we acknowledge that, about, you know, the to make a certain phone but we think the inference is SOUTHERN DISTRICT REPORTERS, P.C..» (212) 805-0300 30 DOJ-OGR-00011549