DOJ-OGR-00021576.jpg

Case 22-1426, Document Oo N_A00 3536039, Page146 of 217 31 Me6eSQmaxl very clear that when you have two knowing conspirators, Maxwell and Epstein, and they bring in a much younger woman as an assistant and have her take on some of those roles while the defendant remains a lady of the house in the hierarchy of the structure to whom a person like Sarah Kellen would report, that she has leadership of that person; that she is directing that person; that she has control. Even the simple task of directing her to take on some of those responsibilities, which, of course, to transition parts of that role she would have to do would qualify for leadership. THE COURT: And there's clear time overlap in the role? MS. MOE: Yes, your Honor. As we noted in our brief, the flight records reflect that the defendant continued flying on Epstein's private jet at the same time that Sarah Kellen was also traveling, and that there was an overlap in the years of the time period where they were all close associates of Jeffrey Epstein and the scheme was ongoing. THE COURT: Go ahead. MR. EVERDELL: Yes. Your Honor, before I address the Sarah Kellen point, I would just make the point that the government seems to argue that there is some case law that is not clear that you don't have to necessarily show that they're supervising another criminal participant. That's just wrong. All those cases that the government cites, the issue has SOUTHERN DISTRICT REPORTERS, P.C.eee (212) 805-0300 DOJ-OGR-00021576