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Case 1:20-cr-00330-PAE Document600_ Filed 02/11/22 Page 33 of 37
which would have dated her trip to New Mexico, or when Epstein bought tickets to the
Broadway production of The Lion King for Jane, which she had originally told the FBI she saw
on her first trip to New York. Tr. 503-11.
C. Phone Records
Contemporaneous phone records for Epstein, Ms. Maxwell, the accusers, and others that
could have been used to rebut the government’s proof were also not available to the defense. For
example, Carolyn testified that Ms. Maxwell would call her to set up massage appointments. Tr.
1527. This was important evidence linking Ms. Maxwell to the sex trafficking charges in Counts
Five and Six. Carolyn’s claim could have been disproven with contemporaneous phone records.
However, because a complete set of Ms. Maxwell’s phone records—as well as phone records for
Carolyn, her mother, and her boyfriend—were not available, the defense could not challenge this
claim.
D. Property Records
The defense also did not have access to property records for Epstein’s various residences,
which would have rebutted the accusers’ testimony concerning the timing of the alleged sexual
abuse. For example, Jane testified that she began being sexually molested by Epstein in his
home in New York when she was 14 years old. Tr. 316-320. Jane described the house as
follows:
[I]t looked more like a building than a house. It was eight stories, his massive
eight-story house building where you walk through these giant doors and then
there was, like, another security door to go in. And it had an elevator and it was
eight stories.
Tr. 317. It is clear that Jane was describing Epstein’s townhouse on East 71* Street. Moreover,
her description of the massage room where she was molested matched photographs of the
massage room at the 71“ Street house. Tr. 320. Jane turned 14 years old in August 1994. But
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Dates
Document Details
| Filename | DOJ-OGR-00008957.jpg |
| File Size | 666.4 KB |
| OCR Confidence | 95.0% |
| Has Readable Text | Yes |
| Text Length | 1,916 characters |
| Indexed | 2026-02-03 17:39:57.905385 |