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be N 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 Case 1:20-cr-00330-AJN Document 765 Filed 08/10/22 Page 70 of 95 TAMAX2ps LC de the defendant is going to say that of government the trips. she didn't was traveling repeatedly with these minors. would argue that at fendant traveling with some of To the extent the minor victims. the purpose was sexual abuse, a minimum this she did know, if she consciously avoided knowing, THE don't know if distancing of clearly a knowledge So my strong inclina here. to look back issue, issue. of regarding age. opening, Mr. but age aside, theme of COURT: Ms. throughout Maxwell it will be a theme of fro The other point is, m Mr. the closing, the opening, t the counts. think ven th That's my conclusion. through relevant por Tha Knowledge ot sort of age. questions about Epstein is alleged avoidance instruction. So my conclusion is to include it. knowledge of a Sp ag And in any event, Ms. to have a standard instance of g ecific arguments as eis tions of t's my conclusion. issue -- well, Maxwell's knowledge of what there are, been doing that the applicability of from the openings, 2808 assume she didn't know the purposes the why Jeffrey Epstein but the Epstein and what he did was and so that implicates tion is that it's appropriate I'm going F testimony on the age not the age to knowledge intertwined with arguments as a result of the I think it's a conscious let me make sur Next. MR. EVERDELL: Next, your Honor SOUTHERN DISTRICT REPORTERS, (212) 805-0300 PG ew DOJ-OGR-00016996