DOJ-OGR-00014624.jpg

fe NO Ww ws Oo OY ~] oO Ke) a oO a fe No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE LCKCmax9 which she did. Document 767 Charge Filed 08/10/22 Page 224 of 257 3058 Three, between in or about 2001 and in or about 2004, an address in the Southern residence in Florida about October of 200 Epstein's employees sent Carolyn gifts, including lingerie from District of For example, 2, fF New York to Carolyn's on one occasion, in or Epstein caused a package to be sent by Federal Express from an address in Manhattan to Carolyn in Florida. Four, on multiple occasions between in or about 2001 and in or about 2004 , Epstein, Maxwell, or one of Epstein's other employees called Carolyn to schedule an appointment for Carolyn to massage Epstein. 2004 or May of 2004, Carolyn to schedule such appoin For example, in or about April of another employee of Epstein's called tments. In order for government to satis Fy this element, it's not necessary for the government to prove that Ms. Maxwell committed the overt to show that any of act. the members of It i s suf Ficient for the government committed some overt act in Further, the overt in the indictment. substantially simila Rather, was still in existence and that it was done in furtherance of furtherance of the conspiracy knowingly the conspiracy. act need not be one that is alleged it can be any overt act that is r to those acts alleged in the indictment, if you are convinced that the act occurred while the conspiracy the conspiracy as described in the indictment. SOUTH ERN D STR CT RE PORTERS, (212) 805-0300 PG ew DOJ-OGR-00014624