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Case 1:20-cr-00330-PAE Document621 Filed 02/25/22 Page19of51 flown to New York on Epstein’s private jet (see Def. Mot. at 14 (citing GX-662-R at 44)), but would have accepted her much briefer and less detailed testimony about abuse in New Mexico solely because it was corroborated by a flight record.° The defendant also speculates that the jury then decided to acquit the defendant on Count Two but not on Count Four because the jury convicted based on the evidence related to the New Mexico trip. Specifically, the defendant argues that the jury acquitted the defendant of enticement because the flight logs showed that “she was present on the trip [to New Mexico] but said nothing about whether she ‘persuaded, induced, enticed, or coerced’ Jane to take the trip. Indeed, Jane did not testify about having any interaction with Ms. Maxwell prior to the flight to New Mexico in which they discussed the trip.” (Def. Mot. at 15). In contrast, the defendant suggests that the jury must have “found that Ms. Maxwell had some role in arranging Jane’s return flight from New Mexico,” which they took to be sufficient. But there is no specific evidence—not a flight record, and not in Jane’s testimony—of how and to where Jane returned from that particular New Mexico trip, much less that the defendant participated in or made Jane’s travel arrangements. (See Tr. 3129-30 (defense referring to the return flight as “going somewhere away from... New Mexico” and as “some other flight besides the flight to New Mexico”)). In the defendant’s view, the jury rejected nearly all of the evidence relating to Jane for lack of corroboration, and then convicted the 3 The defendant says that the “critical difference” between those trips is that the defendant was not listed as a passenger on the trip to New York but is listed on the second trip to New Mexico. (Def. Mot. at 14). That difference, however, says nothing about whether the jury required a corroborative flight record before crediting Jane’s account of travel to and abuse in New York or New Mexico. 18 DOJ-OGR-00009581