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be NO Case 1:20-cr-00330-AJN Document 741 Filed 08/10/22 Page 30 of 106 34 LBTCMAX2 second in command. Epstein's life. 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 committed these the house. She firing employees. Opening - Ms. Pomerantz crimes together, the defendant was the lady of She was involved in every detail of During the ten years the defendant and Epstein ran Epstein's various properties, hiring and She imposed rules, instructing employees to not speak directly with visiting Epstein's homes. the rules for staff nothing, hear nothing, silence. That was by design, say nothing. There was a culture of Epstein or talking with other people When she took charge of those homes, were strict. Employees were to see the defendant's design, because mu behind closed doors, the defendant and Epstein were committing heinous crimes. The det They were sexually abusing teenage girls. Fendant and Epstein were partners in crime. They had a playbook. First, then they gained their trust. hopes and dreams. They learned about each girl's they got access to young girls, They learned about each girl's families, often targeting the daughters of single mothers. The defendant and Epstein promised these girls the world. Some of the girls had difficult home lives and came from families that were struggling to make ends meet. wealthy, powerful, The defendant and Epstein were and well connected, and they flaunted it. mu They made sure everybody knew. The defendant and Epstein made young girls believe that their dreams could come true. They up and they promised to help, SOUTHERN DISTR figured out what the girls dreamed of becoming when they grew promised to help pay for school, CT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00016140