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Case 22-1426, Document 58_02/28/2023, 3475901, Page206 of 221 A-406 MeSQmaxl very clear that Sal when you have two knowing conspirators, Maxwell and Epstein, and they bring in a much younger woman as an assistant and ha defendant remain structure to who she has leadersh ve her take on some of those roles while the s a lady of the house in the hierarchy of the m a person like Sarah Kellen would report, that ip of that person; that she is directing that person; that she directing her to of course, to tr has control. Even the simple task of take on some of those responsibilities, which, ansition parts of that role she would have to do would qualify THE COU role? MS. MOE: the flight recor for leadership. RT: And there's clear time overlap in the Yes, your Honor. As we noted in our brief, ds reflect that the defendant continued flying on Epstein's private jet at the same time that Sarah Kellen was also traveling, Epstein and the 20 21 22 23 24 25 THE COU and that there was an overlap in the years of the time period where they were all close associates of Jeffrey scheme was ongoing. RT: Go ahead. MR. EV. Sarah Kellen poi ERDELL: Yes. Your Honor, before I address the nt, I would just make the point that the government seems not clear that y to argue that there is some case law that is ou don't have to necessarily show that they're supervising another criminal participant. That's just wrong. All those cases SOU that the government cites, the issue has THERN DISTRICT REPORTERS, P.C.¢¢. (212) 805-0300 DOJ-OGR-00021032