DOJ-OGR-00014781.jpg
Extracted Text (OCR)
Case 1:20-cr-00330-PAE
Document 779
Filed 08/22/22
Page 34 of 101
34
M6SQmaxl
1 With respect to the testimony of the pilots who
2 testified, whether they whether an emoloyee was paid by
3 Maxwell or Epstein or technically reported to one, according to
4 their job descriptions, is not the question here. The fact
a that pilots based on their observation thought at one point
6 that Kellen reported to Maxwell proves the point that she had
7 supervisory authority over Kellen and exercised it, whether in
8 the chain of command or on their formal employment paperwork,
9 she was just an emoloyee for one or the other, it makes no
10 difference. There was an overlap here. They had different
11 roles in the conspiracy, and the defendant had a supervisory
12 roll over Kellen.
13 MR. EVERDELL: Your Honor, just to that point. Being
14 present does not mean that you're a supervisor. That's way too
15 far a stretch. So the fact that there was testimony she was
16 present still in the house while Kellen was making the calls
17 and scheduling the massage appointments means nothing in terms
18 of supervisory authority.
19 THE COURT: Thank you. Other enhancements before the
20 government's objection is to be addressed.
21 MS. MOE: No, your Honor. Thank you.
22 MR. EVERDELL: Your Honor, I assume you don't want to
23 hear or have any questions about the five-point enhancement for
24 repeated and dangerous sex offenders.
25 THE COURT: believe I have what need, but as
SOUTHERN D
STR
GI
REPORTERS, P.C.»
(212)
805-0300
DOJ-OGR-00014781