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be NO Ww ws Oo OY ~] oO Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE M6SQmaxl clearer, your Honor, Document 779 Kellen was an assistant of belied by the trial record. both Filed 08/22/22 this notion that she was somehow —-- f you look at Larry Visoski's testimony, believe is what the government is relying on there, oh, I originally testified, both. didn't know what her role was, that she was an assistant for But on cross-examination, think she was an assistant Page 33 of 101 which he for he conceded that he really 33 Sarah Epstein and Maxwell is again and his best recollection was And again, testimony who was the actual assistant says uneguivocally, assistant." So there is no "TIT was her assistant. fair Epstein. just look again at Cimberly for Ms. supervising Sarah Kellen. Th is infer opposite, and it can't provide a basis ne Maxwell, Kellen was inference that Ms. enhancement. Espinosa's and Maxwell xactly the for that leadership she Epstein's was enhancements to the leadership question, I attention, TH mal COURT: All right. for the government MS. MOE: Your Honor, we noted this on page 27 of Anything further on the "s objection? just very briefly with respect our brief just want to direct the Court's , but the led that even af Frer testimony at trial was that Carolyn recal Sarah Kellen was still present inside the took over calling to schedul]l Palm arrived for massage appointments. Beach residenc l©€ massages, Maxwel] when Carol SOUTH E RN STR GI PORTE lyn (212) 805-0300 DOJ-OGR-00014780