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Case 22-1426, Document oO N-399 3536039, Page145 of 217 30 M6SOmaxl 1 MS. MOE: Yes, your Honor. Looking at the text of the 2 application note -- again, it's unclear from some case law on 3 this, but under the text of the application note, if we're 4 looking to one criminal participant, we would direct the 5 Court's attention to Sarah Kellen. 6 THE COURT: And the leadership over her as opposed to 7 Epstein being the leader over her or them being Kellen sort 8 of replacing the defendant's role, could you focus my mind on g what specifically you point to to show supervision and 10 leadership by Ms. Maxwell over Ms. Kellen. 11 MS. MOE: Yes, your Honor. 12 The trial evidence was that Sarah Kellen became an 13 assistant, and that she worked for both Maxwell and Epstein. 14 Essentially, when you look at defendant's role in earlier 15 years, she was doing things like calling victims and arranging 16 for massage appointments. As the scheme shifted, they brought 17 in another member of the scheme beneath them in the structure 18 and hierarchy of the scheme. The defendant remained a close 19 associate. She was often traveling with them, often traveling 20 with Kellen together. So as Kellen took on some of the tasks 21 that were then delegated to a lower member of the conspiracy, 22 the defendant was higher up in the leadership structure. 23 There wasn't direct evidence about, you know, the 24 defendant directly instructing Kellen to make a certain phone 25 call, and we acknowledge that, but we think the inference is SOUTHERN DISTRICT REPORTERS, P.C.eee (212) 805-0300 DOJ-OGR-00021575