DOJ-OGR-00021031.jpg
575 KB
Extraction Summary
5
People
2
Organizations
0
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal document
File Size:
575 KB
Summary
This document is a court transcript from February 28, 2023, in which an attorney, Ms. Moe, responds to a judge's question about the hierarchy of a criminal conspiracy. Ms. Moe argues that trial evidence shows the unnamed defendant held a leadership position superior to that of Sarah Kellen, who was an assistant to Ms. Maxwell and Epstein. The argument is based on the defendant's role shifting over time and Kellen taking on tasks like calling victims, placing the defendant higher in the scheme's structure.
People (5)
| Name | Role | Context |
|---|---|---|
| MS. MOE | Attorney/Speaker |
Speaking to the Court, explaining the defendant's role in relation to Sarah Kellen.
|
| Sarah Kellen | Criminal participant/Assistant |
Identified as a criminal participant and assistant who worked for Maxwell and Epstein. Her role and tasks are being d...
|
| Epstein | Leader |
Mentioned as a leader in the scheme for whom Sarah Kellen worked.
|
| Ms. Maxwell | Leader |
Mentioned as having a supervisory and leadership role over Ms. Kellen.
|
| The defendant | Defendant |
An unnamed defendant whose leadership role and relationship with Sarah Kellen is the subject of the discussion. Alleg...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| THE COURT | government agency |
The judicial body being addressed by MS. MOE.
|
| SOUTHERN DISTRICT REPORTERS, P.C. | company |
The court reporting agency that transcribed the proceedings, listed at the bottom of the page.
|
Timeline (2 events)
The defendant was often traveling with 'them' (presumably Maxwell and Epstein) and with Kellen.
Sarah Kellen was involved in arranging massage appointments.
Sarah Kellen
victims
Relationships (3)
The document discusses the 'supervision and leadership by Ms. Maxwell over Ms. Kellen.' It also states Kellen worked for Maxwell as an assistant.
The document states that Sarah Kellen 'worked for both Maxwell and Epstein' as an assistant.
Described as 'close associate[s]' who traveled together. The defendant is argued to be 'higher up in the leadership structure' than Kellen, with Kellen taking on tasks previously performed by the defendant.
Key Quotes (3)
"And the leadership over her as opposed to Epstein being the leader over her or them being -- Kellen sort of replacing the defendant's role, could you focus my mind on what specifically you point to to show supervision and leadership by Ms. Maxwell over Ms. Kellen."Source
— THE COURT
(The judge asking MS. MOE to clarify the evidence showing Ms. Maxwell's leadership over Sarah Kellen, as distinct from Epstein's or the defendant's role.)
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Quote #1
"The trial evidence was that Sarah Kellen became an assistant, and that she worked for both Maxwell and Epstein."Source
— MS. MOE
(Explaining Sarah Kellen's initial role in the scheme.)
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Quote #2
"So as Kellen took on some of the tasks that were then delegated to a lower member of the conspiracy, the defendant was higher up in the leadership structure."Source
— MS. MOE
(Arguing for the defendant's superior position in the hierarchy relative to Sarah Kellen.)
DOJ-OGR-00021031.jpg
Quote #3
Full Extracted Text
Complete text extracted from the document (1,554 characters)
Case 22-1426, Document 58, 02/28/2023, 3475901, Page205 of 221
A-405
A-405
30
M6SQmax1
M6SQmax1
MS. MOE: Yes, your Honor. Looking at the text of the
application note -- again, it's unclear from some case law on
this, but under the text of the application note, if we're
looking to one criminal participant, we would direct the
Court's attention to Sarah Kellen.
THE COURT: And the leadership over her as opposed to
Epstein being the leader over her or them being -- Kellen sort
of replacing the defendant's role, could you focus my mind on
what specifically you point to to show supervision and
leadership by Ms. Maxwell over Ms. Kellen.
MS. MOE: Yes, your Honor.
The trial evidence was that Sarah Kellen became an
assistant, and that she worked for both Maxwell and Epstein.
Essentially, when you look at defendant's role in earlier
years, she was doing things like calling victims and arranging
for massage appointments. As the scheme shifted, they brought
in another member of the scheme beneath them in the structure
and hierarchy of the scheme. The defendant remained a close
associate. She was often traveling with them, often traveling
with Kellen together. So as Kellen took on some of the tasks
that were then delegated to a lower member of the conspiracy,
the defendant was higher up in the leadership structure.
There wasn't direct evidence about, you know, the
defendant directly instructing Kellen to make a certain phone
call, and we acknowledge that, but we think the inference is
application note -- again, it's unclear from some case law on
this, but under the text of the application note, if we're
looking to one criminal participant, we would direct the
Court's attention to Sarah Kellen.
THE COURT: And the leadership over her as opposed to
Epstein being the leader over her or them being -- Kellen sort
of replacing the defendant's role, could you focus my mind on
what specifically you point to to show supervision and
leadership by Ms. Maxwell over Ms. Kellen.
MS. MOE: Yes, your Honor.
The trial evidence was that Sarah Kellen became an
assistant, and that she worked for both Maxwell and Epstein.
Essentially, when you look at defendant's role in earlier
years, she was doing things like calling victims and arranging
for massage appointments. As the scheme shifted, they brought
in another member of the scheme beneath them in the structure
and hierarchy of the scheme. The defendant remained a close
associate. She was often traveling with them, often traveling
with Kellen together. So as Kellen took on some of the tasks
that were then delegated to a lower member of the conspiracy,
the defendant was higher up in the leadership structure.
There wasn't direct evidence about, you know, the
defendant directly instructing Kellen to make a certain phone
call, and we acknowledge that, but we think the inference is
SOUTHERN DISTRICT REPORTERS, P.C. ***
(212) 805-0300
(212) 805-0300
DOJ-OGR-00021031
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