On multiple occasions between 2001 and 2004, Epstein, Maxwell, or other employees called Carolyn to schedule an appointment for her to massage Epstein.
This legal document outlines specific actions taken between 2001 and 2004 as part of a conspiracy charge. It details how Jeffrey Epstein, Ghislaine Maxwell, and other employees sent gifts (including lingerie) to a woman named Carolyn and repeatedly called her to schedule massages for Epstein. The document concludes with a legal clarification that for a conspiracy conviction, it is sufficient to prove that any member of the conspiracy committed an overt act, not necessarily the defendant (Ms. Maxwell) herself.
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