DOJ-OGR-00014573.jpg
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Case 1:20-cr-00330-PAE
LCKCmax7
Maxwell? What do you think st
the pregnant person in
who was mast
That is the definition
And why is the
peripheral details?
Document 767
Rebuttal - Ms.
Filed 08/10/22 Page 173 of 257 3007
Comey
tands out in her memory more, who
that picture was or the middle-aged man
oO
de
Becaus
fense
turbating and touching her breasts inside that room?
f a peripheral detail.
focusing so much on these
ignore the
Maxwell as one of the people
that house.
not once, but twice
they desperately want you to
fact that Carolyn has consistently remembered
involved in her experiences at
They want you to
in her 2009 deposit
Carolyn named Maxwell as one of the two
her to schedule these massages with Je
forget that she mentioned Maxwell
ion. Without prompting,
people who would call
her as one of the two people she would
herself begging to com
over because sh
rey Epstein. She named
talk to when she called
needed the money. And
Carolyn told Sean that she met a woman named Maxwell, whose
Now,
first name she couldn't pronounce.
back then there was no reason for Carolyn to go
into more detail about what was happening with Maxwell,
especially not in a lawsuit that was about Sarah and Epstein.
prompting,
the core events,
long befor
th
But when she was asked mor
her memory.
detailed questions, she remembered
and she'd already mentioned Maxwell, without
re could be anything to contaminate
Next, the defense suggests tha
t somehow these clear
memories of Maxwell got implanted into
the brains of Jane and
SOUTHERN
D
STR
CT REPORT
BRS, Pes
(212)
805-0300
DOJ-OGR-00014573