DOJ-OGR-00021002.jpg
Extracted Text (OCR)
Case 22-1426, Document 58_02/28/2023, 3475901, Page1/6 of 221
A-376
Case 1:20-cr-00330-AJN Document 657 Filed 04/29/22 Page 19 of 45
commercial sex act; and (4) the Defendant’s acts were in or affecting interstate commerce; or
that the Defendant aided and abetted the same. Jury Charge at 32, 37. Count Six applied solely
to Carolyn during the period 2001 to 2004. Jd. at 32.
Carolyn testified that when she was under the age of eighteen, the Defendant would call
her to set up appointments for Carolyn to perform sexualized massages on Epstein. Trial Tr.
1527, 1530. Carolyn explained the sexual activities that occurred during the massages. /d. at
1544-47. Carolyn testified that the Defendant saw her naked in the massage room and continued
to call Carolyn to schedule appointments with Epstein. /d. at 1538. She recalled a specific
incident when she was fourteen in which she was naked in the massage room and the Defendant
touched her breasts and commented that Carolyn “had a great body for Mr. Epstein and his
friends.” /d. at 1536-38. Carolyn testified that the Defendant knew that she was under the age
of eighteen and continued to call her to schedule appointments with Epstein after learning that
fact. /d. at 1535. Carolyn further testified that she received money in exchange for performing
sexualized massages on Epstein. E.g., id. 1523. She recalled that while money was often left on
the sink outside of the massage room, the Defendant paid her directly after massages on one or
two occasions. Jd. at 1540-41. Carolyn’s testimony was corroborated by Shawn, Carolyn’s
boyfriend at the time, and physical evidence including phone message pads. This evidence was
plainly sufficient for the jury to find beyond a reasonable doubt that the Defendant committed
sex trafficking of an individual under eighteen, or aided and abetted Epstein in doing so.?
3 Tf the Court were to conclude that Count Five is not multiplicitous, it would deny the Defendant’s Rule 29 motion
as to Count Five. Count Five charged the Defendant with participating in a conspiracy to commit sex trafficking of
individuals under the age of eighteen from about 2001 to 2004. The evidence that supports the Defendant’s
conviction of Count Six, the substantive count, also supports the Count Five conspiracy conviction. Additionally,
Juan Alessi testified that the Defendant approached Virginia Roberts in a parking lot and that he then saw her at
Epstein’s Palm Beach residence later that day. Trial Tr. at 841-43. Documentary evidence, including flight records,
established that Virginia was under the age of eighteen when she met the Defendant and Epstein. See, e.g., id. at
1855 (December 2000 flight record including Epstein, the Defendant, and Virginia); see also GX-14 (birth
certificate). Carolyn testified that Virginia recruited her and that Virginia performed sexualized massages on
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Extracted Information
Dates
Document Details
| Filename | DOJ-OGR-00021002.jpg |
| File Size | 775.6 KB |
| OCR Confidence | 94.7% |
| Has Readable Text | Yes |
| Text Length | 2,900 characters |
| Indexed | 2026-02-03 20:06:05.017330 |