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Case 1:20-cr-00330-PAE LCKVMAX4 Document 767 Summation - Ms. Filed 08/10/22 Moe Page 68 of 257 2901 1 So next, the defense has repeatedly attacked Jane, 2 Annie, Carolyn, and Kate, claiming that they are liars or that 3 their memories are faulty or maybe it's both. They argued both 4 to you during this trial. They are doing that because the 5 testimony of the witnesses in this case is devastating evidence 6 of Maxwell's guilt; because if you believe them, Maxwell is 7 guilty. 8 You are the finders of the fact. You're the judges of 9 the truth. And your common sense tells you that only one of 10 three things can be true about Kate, Jane, Annie, and Carolyn: 11 BRither they are all misremembering the same thing, or they're 12 outright lying, or they're telling the truth. 13 So I want to talk through those one-by-on 14 First, the defense has suggested to you that perhaps 15 Jane and Kate and Annie and Carolyn are all talking about fake 16 memories. But that's what they testified about, that they are 17 getting it wrong; that their memories are faulty. Four women 18 have testified at this trial about Maxwell. They all describe 19 the same woman, the same playbook. They didn't imagine what 20 happened to them. Your common sense tells you that just cannot 2l be true. They are not all somehow suffering from the same mass 22 delusion. 23 And while time has passed, they told you very clearly 24 that they remember being exploited by Maxwell and Epstein. 25 Your common sense tells you that being molested is not SOUTHERN D STR CT REPORT (212) 805-0300 ERS, Ps DOJ-OGR-00017089