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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE M6éSOmaxl conviction. jet, and both pilots testi Visoski testi pilots fly victims of Document 737 Filed fied fly Epstein or schedule fied all counts o convi ction, flights trial demonstrates that Epstein and 07/22/22 Page 44 of 101 44 that Maxwell partially owned the that she would tell them when to for herself. The evidence at the conspiracy. the defendant had the Across the timeframe of Alessi, Visoski and Rodgers provided personalized services that were peculiarly tailored to the defendant's available to Carrozzella case, that there w e) testified at trial, the public. r fFfenses and were not Again, fungibl services generally I'm citing from the In addition to these unknowin find by a prepon 105 F.3d at 804. g participants that derance of the evidence other unknowing persons led by Maxwell. As Epstein's number one, Ms. Maxwell mana ged Epstein's numerous households and interviewed, hired and oversaw the household staff. The det Sarah Kellen and another Fendant had her own personal assistants, like individual. From the record, I can't determine the precis unknowingly assisted criminal activity, that the number is within the meaning of 3Bl1 but number of Suttierent, £6 -l(a) find an these other individuals that Epstein and the defendant in their adequate basis in the record make States v. Archer, 6 Last 2G1.1(b) (4) ( < B). the det 71 F.3d 149 the activity extensive from 1994 to 2004. See United (2d Cir. 2011). Fendant objects to enhancement That provision increases the offense level by SOUTH ERN D STR GI REPORT BRS, P«G.# (212) 805-0300 DOJ-OGR-00011563