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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 Document 767 LCKCmax7 Filed 08/10/22 Page 151 of 257 2985 Summation — Ms. Menninger anywhere. While she went to New York the one time before New Mexico, Ghislaine Maxwell wasn't there, had nothing to do with it. And Kate, as we've already told you, nothing illegal happened with Kate. Counts Five and Six, are the counts that relate to Carolyn. the sex trafficking counts, these Now, the government wants you to believe that because Ghislaine Maxwell traveled to Palm period and helped to manage one orchestrating massages, despit Beach at some points in that Epstein's properties, she was the th no proof of that, no message pads, You've seen Sarah Kellen was there. fact that you've seen no phone records, nothing. The Judge is also going to explain to you that mere presence is not enough alleged crime does not, member of the conspiracy. mere presenc by itself, does And she will at the scene of the not make someone a also, I expect, instruct you that knowledge without participation in the unlawful plan is also not suf ficient to convict. In other words, you cannot conclude Ghislaine was a member of the conspiracy simply because she visit nor can you convict her because yo that she must have known. She mus beyond a reasonable doubt. The law presumes, ed Palm Beach in the 2000s, have known is not proof u have some nagging sense as you sit here today, as I stand here today, that Ghislaine Maxwell is innocent of all the SOUTHERN DISTRICT R G iPORT BRS, Pes (212) 805-0300 DOJ-OGR-00014551