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719 KB
Extraction Summary
4
People
1
Organizations
1
Locations
3
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal document
File Size:
719 KB
Summary
This legal document, part of a court filing, argues for a sentencing enhancement against the defendant, identified as Maxwell. It presents evidence of her leadership role in a criminal conspiracy, citing her authority over an associate named Kellen, which is supported by flight records on Epstein's planes and her delegation of illicit tasks. The document then justifies a specific two-point "Undue Influence" enhancement by referencing U.S. Sentencing Guidelines concerning crimes where an adult participant influences a minor.
People (4)
| Name | Role | Context |
|---|---|---|
| Kellen |
Mentioned as flying with the defendant on Epstein's planes, joining the conspiracy, and being instructed by Maxwell.
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| Epstein |
Mentioned as the owner of the private planes on which the defendant and Kellen flew.
|
|
| Maxwell | Second in command under Epstein |
Identified as being second in command to Epstein, exercising authority over Kellen, and instructing Kellen on schedul...
|
| the defendant | Defendant |
Referred to throughout the document as the subject of the legal arguments. The context implies the defendant is Maxwe...
|
Organizations (1)
| Name | Type | Context |
|---|---|---|
| U.S.S.G. | government agency |
Referenced for sentencing guidelines, specifically § 3B1.1 and § 2G1.3(b)(2)(B), regarding leadership enhancement and...
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Timeline (3 events)
2003
The defendant and Kellen flew together on Epstein’s private planes approximately thirty-nine times.
Epstein's private planes
2004
The defendant and Kellen flew together on Epstein’s private planes approximately ten times.
Epstein's private planes
Locations (1)
| Location | Context |
|---|---|
|
Mentioned to describe the breadth of the defendant's criminal scheme.
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Relationships (3)
The document states that "Maxwell was still second in command under Epstein."
The document states that Maxwell "exercised authority over Kellen," "instructed Kellen," and that Kellen followed "Maxwell's directions."
They flew together on private planes approximately 49 times over two years (2003-2004), indicating a close working relationship within the conspiracy.
Key Quotes (4)
"a participant . . . unduly influenced a minor to engage in prohibited sexual conduct."Source
— U.S.S.G. § 2G1.3(b)(2)(B)
(Quoted from the U.S. Sentencing Guidelines to define the condition for a two-level sentencing enhancement.)
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Quote #1
"a participant’s influence over the minor compromised the voluntariness of the minor’s behavior."Source
— U.S.S.G. § 2G1.3(b)(2)(B) app. n.3(B)
(Quoted from the U.S. Sentencing Guidelines to explain when the undue influence enhancement applies.)
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Quote #2
"a participant is at least 10 years older than the minor,"Source
— U.S.S.G. Guidelines
(A condition cited from the Guidelines that leads to a rebuttable presumption of undue influence.)
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Quote #3
"a rebuttable presumption . . . that such participant unduly influenced the minor to engage in prohibited sexual conduct."Source
— U.S.S.G. Guidelines
(The legal presumption that arises when a participant is at least 10 years older than a minor victim.)
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,083 characters)
Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 30 of 55
was still the lady of the house, supervising other staff, (GX 606), and flight records make clear that the defendant and Kellen flew together on Epstein’s private planes approximately thirty-nine times in 2003 and approximately ten times in 2004, confirming their continued overlap, (GX 662).
The combination of this evidence demonstrates that Kellen joined the conspiracy when Maxwell was still second in command under Epstein. Given Maxwell’s role in the household and in the conspiracy, she certainly exercised authority over Kellen. The clear inference from this record is that Maxwell instructed Kellen regarding how to schedule massages and run the part of the scheme that Maxwell had previously handled, at which point Kellen switched to making calls to schedule appointments following Maxwell’s directions. Thus, even if the defense were correct that the defendant needed to supervise a knowing participant in the scheme for the leadership enhancement to apply, the record amply supports the conclusion that Maxwell did so with respect to Kellen.
Given the breadth of the defendant’s criminal scheme, spanning multiple continents, abusing multiple victims, and employing numerous underlings to accomplish the conspiracy’s goal over the course of multiple years, the defendant clearly warrants the enhancement under U.S.S.G. § 3B1.1 contemplated by the PSR.
C. The Two-Point “Undue Influence” Enhancement Applies
Pursuant to U.S.S.G. § 2G1.3(b)(2)(B), two levels are added if “a participant . . . unduly influenced a minor to engage in prohibited sexual conduct.” This enhancement applies where “a participant’s influence over the minor compromised the voluntariness of the minor’s behavior.” Id. app. n.3(B). Where, as here, “a participant is at least 10 years older than the minor,” the Guidelines provide for “a rebuttable presumption . . . that such participant unduly influenced the minor to engage in prohibited sexual conduct. In such a case, some degree of undue influence can
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DOJ-OGR-00010565
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