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Case 1:20-cr-00330-PAE Document 737 Filed 07/22/22 Page 38 of 101 38 M6SQmaxl 1 me is specific and highly technical. Does the preponderance of 2 th vidence demonstrate that the offense to sex traffic 3 Carolyn continued after November 1, 2004 before she turned 18 4 in early 2005? In other words, does a preponderance of the 5 evidence establish that acts in furtherance of the conspiracy 6 to traffic Carolyn occurred in either November or 7 December 2004? Although Carolyn testified regarding contact 8 earlier in 2004 and after she turned 18 in 2005, there is no 9 vidence, either in the form of testimony or documentary 10 evidence, including the message pads, that demonstrates by a 11 preponderance of the evidence conspiratorial conduct during 12 those last two months of 2004 before Carolyn turned 18 in 2005. 13 In those portions of Carolyn's testimony cited by the 14 government, Carolyn stated that she was 18 years old the last 15 time she went to Epstein's house, which would have been in 16 2005. As Carolyn further explained, she returned more than 17 four or five times to Epstein after she gave birth to her son 18 in March of 2004, and that testimony is supported by message 19 pads entered at trial that show Carolyn called Epstein several 20 times in the summer of 2004: Once in late April or early May 21 again on July 6, and again on July 30. When she did return to 22 Epstein, Carolyn testified Epstein asked if she had younger 23 friends, and she explained during her testimony that at 18 24 years old, she was too old for him. Carolyn wasn't asked, and 25 her testimony doesn't specifically address, whether she went to SOUTHERN DISTRICT REPORTERS, P.C.-» (212) 805-0300 DOJ-OGR-00011557