DOJ-OGR-00010427.jpg

724 KB

Extraction Summary

4
People
2
Organizations
3
Locations
4
Events
1
Relationships
3
Quotes

Document Information

Type: Legal document
File Size: 724 KB
Summary

This legal document, part of a court filing, analyzes the testimony of a witness named Carolyn regarding her interactions with Epstein. The document argues that Carolyn's memory is unreliable and contradictory, pointing to inconsistencies in her timeline of events, particularly concerning her visits to Epstein's Palm Beach residence in 2004 after giving birth to her son. Evidence from message pads is cited to corroborate a timeline that conflicts with parts of her testimony, thereby attempting to discredit her as a witness.

People (4)

Name Role Context
Carolyn Witness/Victim
A person whose testimony regarding her interactions with Epstein is being analyzed for credibility. Her memory is des...
Epstein
The individual whom Carolyn visited at his Palm Beach residence. The interactions between him and Carolyn are the sub...
Carolyn Andriano
Name associated with messages from 2004, likely the full name of 'Carolyn'.
Caroline Ambriano
Name associated with a message from July 6, 2004, likely a misspelling of 'Carolyn Andriano'.

Organizations (2)

Name Type Context
The government government agency
Asserts that Carolyn's recollection can be credited.
The Court government agency
The document argues that the Court should not credit Carolyn's recollection.

Timeline (4 events)

2003
Carolyn left Florida and traveled to Georgia, where she became pregnant.
Florida, Georgia
2004
Carolyn returned from Georgia after giving birth.
Georgia
2004
Carolyn's last interactions with Epstein occurred from approximately late spring through summer 2004, when she was 17 years old. She visited him 'four or five times' for money.
Palm Beach
2004-03-14
Carolyn gave birth to her son.
Georgia

Locations (3)

Location Context
Location of Epstein's residence where Carolyn's visits occurred.
The state Carolyn returned from after giving birth to her son. Also where she traveled to and became pregnant.
Mentioned in a footnote as the state Carolyn left in 2003.

Relationships (1)

Carolyn exploitative Epstein
Carolyn visited Epstein after giving birth because she 'needed money to buy things for her son,' but stopped when it 'became clear that she was too old for Epstein.' The document also references her leaving Florida 'to escape the traumatic events' that happened in Palm Beach.

Key Quotes (3)

"[doesn’t] remember the times and dates"
Source
— Carolyn (Carolyn's testimony affirming she had trouble remembering details of her visits to Epstein's Palm Beach residence.)
DOJ-OGR-00010427.jpg
Quote #1
"four or five times"
Source
— Carolyn (Carolyn's statement on how many times she went back to see Epstein after her son was born because she needed money.)
DOJ-OGR-00010427.jpg
Quote #2
"to escape the traumatic events"
Source
— Carolyn (Carolyn's testimony explaining why she left Florida for Georgia in 2003.)
DOJ-OGR-00010427.jpg
Quote #3

Full Extracted Text

Complete text extracted from the document (2,356 characters)

Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 10 of 29
17. (GX-3-B). Carolyn further testified that she had trouble remembering details of the events in question and affirmed that she “[doesn’t] remember the times and dates” of her visits to Epstein’s Palm Beach residence. (Tr. 1525, 1559).
The government asserts that Carolyn’s recollection can be credited because even if she cannot recall the year that an event took place, she has been consistent about how old she was when the event took place. (PSR at 53). As set forth above, this claim is flatly contradicted by the record. If Carolyn could not accurately remember how old she was when she first met Epstein, the Court should not credit her recollection of how old she was when she last saw him.
Carolyn’s memory of when she stopped seeing Epstein was not only unreliable, but also contradicted by the other evidence in the record. Carolyn herself testified that her last interactions with Epstein were when she returned from Georgia after giving birth to her son on March 14, 2004. (Tr. 1548-49). Carolyn stated that she went back to Epstein “four or five times” because she needed money to buy things for her son, but eventually gave up when it became clear that she was too old for Epstein. (Tr. 1549).⁴ The message pads that were admitted in evidence corroborate that these interactions occurred from approximately late spring through summer 2004, when Carolyn was 17 years old. (See GX-3-E (undated message from “Carolyn Andriano”; surrounded by messages dated April 29 and May 2 and included in a book of messages from 2004); GX-3-I (July 6 message from “Caroline Ambriano”; included in a book of messages from 2004); GX-1-B (July 30 message from “Carolyn Andriano”; next to a message dated August 12, 2004 and included in a book of messages from 2004). Accordingly, the trial
⁴ Carolyn’s memory of her interactions with Epstein around the time of the Georgia interlude was also inconsistent and contradictory. On the one hand, Carolyn testified that she left Florida in 2003 “to escape the traumatic events” that had happened in Palm Beach and traveled to Georgia where she became pregnant with her child. (Tr. 1548-49, 1617, 1668). On the other hand, Carolyn testified that she continued to visit Epstein in Palm Beach while she was pregnant. (Tr. 1549).
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DOJ-OGR-00010427

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