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719 KB

Extraction Summary

10
People
0
Organizations
2
Locations
5
Events
7
Relationships
1
Quotes

Document Information

Type: Legal document
File Size: 719 KB
Summary

This legal document, page 21 of a court filing, argues that Ms. Maxwell should not receive an aggravating role enhancement because she did not supervise other criminal participants. It specifically refutes the idea that she supervised Sarah Kellen, presenting testimony from Cimberly Espinosa that Kellen was hired by Epstein to replace Maxwell's duties, not to work under her. The document also states that other employees, like pilots Larry Visoski and David Rodgers, had no knowledge of any criminal conduct.

People (10)

Name Role Context
Epstein Employer
Mentioned as the employer of several individuals, including Ms. Maxwell, Sarah Kellen, pilots, and property staff.
Jane
A person who interacted with Epstein's employees and was transported on his private planes.
Annie Farmer
A person who interacted with Epstein's employees.
Ms. Maxwell Manager of Epstein's properties
The subject of the document, described as supervising some employees but not others, specifically not Sarah Kellen. H...
Juan Alessi Employee
Mentioned as an example of an employee supervised by Ms. Maxwell in Palm Beach.
Larry Visoski Epstein pilot
One of the pilots who transported "Jane". His testimony regarding Sarah Kellen's role is cited in a footnote.
David Rodgers Epstein pilot
One of the pilots who transported "Jane".
Carolyn Victim
Testified that Sarah Kellen scheduled massage appointments for her and took nude pictures of her.
Sarah Kellen Criminal participant / Epstein's assistant
Identified as a criminal participant in offenses against Carolyn. The document argues she was hired by Epstein to rep...
Cimberly Espinosa Ms. Maxwell's assistant
Testified that she was Ms. Maxwell's assistant from 1996-2002 and that Sarah Kellen was hired as Epstein's assistant,...

Timeline (5 events)

1996-2002
Cimberly Espinosa was employed as Ms. Maxwell's assistant.
2000-2002
Sarah Kellen was hired by Epstein as his assistant.
Larry Visoski and David Rodgers transported "Jane" on Epstein's private planes.
Sarah Kellen scheduled massage appointments for Carolyn and took nude pictures of her on one occasion.
Palm Beach residence
mid-late 1990s
Ms. Maxwell worked as manager of Epstein's properties.

Locations (2)

Location Context
Location where Juan Alessi worked and where Epstein had a residence where an incident with Carolyn occurred.
Location where various unnamed employees worked.

Relationships (7)

Ms. Maxwell professional Epstein
Ms. Maxwell was the manager of Epstein's properties and coordinated payroll for his pilots. The document notes she was 'moving on from Epstein' later.
Sarah Kellen professional Epstein
Kellen was hired by Epstein as his assistant to replace Ms. Maxwell.
Ms. Maxwell professional Sarah Kellen
The document argues there was no supervisory relationship. Kellen was hired to 'replace Ms. Maxwell' in certain duties.
Cimberly Espinosa professional Ms. Maxwell
Espinosa testified that she was Ms. Maxwell's assistant from 1996 to 2002.
Larry Visoski professional Epstein
Visoski was one of Epstein's pilots.
David Rodgers professional Epstein
Rodgers was one of Epstein's pilots.
Sarah Kellen perpetrator/victim Carolyn
Carolyn testified that Kellen scheduled massage appointments for her and took nude pictures of her. Kellen is identified as a 'criminal participant in the offenses against Carolyn'.

Key Quotes (1)

"didn’t know what her exact job"
Source
— Larry Visoski (From his cross-examination testimony regarding Sarah Kellen's role, clarifying his initial thought that she was Ms. Maxwell's assistant.)
DOJ-OGR-00010438.jpg
Quote #1

Full Extracted Text

Complete text extracted from the document (2,252 characters)

Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 21 of 29
who was his employee. According to the record, there were several people employed by Epstein who interacted with “Jane” and Annie Farmer and whom Ms. Maxwell supervised in her role as manager of Epstein’s properties in the mid-late 1990s – e.g., Juan Alessi in Palm Beach and various unnamed employees at Zorro Ranch. The record also reflects that Ms. Maxwell had some role in coordinating payroll and expenses for Epstein pilots, Larry Visoski and David Rodgers, who transported “Jane” on Epstein’s private planes. But these people had no knowledge of the criminal conduct and do not qualify as criminally responsible participants for the purposes of the aggravating role enhancement.
Similarly, there is no evidence in the trial record that Ms. Maxwell supervised another criminal participant in the offenses against Carolyn. Apart from Epstein, Sarah Kellen was the only other person identified in the trial record as a criminal participant in the offenses against Carolyn. Among other things, Carolyn testified that Sarah Kellen scheduled massage appointments for her and took nude pictures of her at the Palm Beach residence on one occasion. (Tr. 1527-28; 1538-39). The record is clear, however, that Ms. Maxwell did not supervise Sarah Kellen. Rather, Kellen was hired by Epstein as his assistant to replace Ms. Maxwell and take over responsibility for scheduling massage appointments and other property management tasks at a time when Ms. Maxwell was moving on from Epstein and was no longer actively managing the day-to-day affairs of his residences.
For example, Cimberly Espinosa testified that Kellen was hired sometime between 2000-2002 to be Epstein’s assistant and that she, and not Sarah Kellen, was Ms. Maxwell’s assistant from when she was hired in 1996 up through the end of her employment in 2002. (Tr. 2332-33, 2376-77).⁸ Espinosa further testified that in the last two years of her employment (2000-2002),
⁸ Larry Visoski initially testified that he thought Sarah Kellen was Ms. Maxwell’s assistant. (Tr. 139-40). But he later clarified on cross-examination that he “didn’t know what her exact job” was and did not know whether Kellen
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