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709 KB
Extraction Summary
6
People
2
Organizations
2
Locations
2
Events
4
Relationships
4
Quotes
Document Information
Type:
Legal filing (court document/sentencing memorandum)
File Size:
709 KB
Summary
This document is a legal filing (page 18 of a brief filed 06/15/22) arguing against an 'aggravating role enhancement' for Ghislaine Maxwell's sentencing. The text contends that Maxwell did not supervise Sarah Kellen, citing testimony from Juan Alessi and 'Carolyn' that Kellen independently took over scheduling duties at the Palm Beach residence. It further notes Maxwell's separation from Epstein and her subsequent relationship with Ted Waitt.
People (6)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the legal argument regarding 'aggravating role enhancement'; defense argues she did not supervise Kellen.
|
| Jeffrey Epstein | Associate/Employer |
Former romantic partner of Maxwell; employer of Kellen.
|
| Ted Waitt | Romantic Partner |
Described as being in a long-term, committed relationship with Maxwell after she split from Epstein.
|
| Juan Alessi | Witness |
Testified regarding Kellen taking over phone duties and scheduling.
|
| Sarah Kellen | Employee/Scheduler |
Took over scheduling massage appointments; described as an employee working with Epstein.
|
| Carolyn | Witness/Victim |
Testified about who called her for appointments (Maxwell initially, then Kellen).
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Probation |
Refers to the Department of Probation regarding the Pre-Sentence Report (PSR).
|
|
| The government |
Refers to the prosecution/DOJ.
|
Timeline (2 events)
2001-2002
Carolyn's visits to the Palm Beach residence where Maxwell initially scheduled appointments.
Palm Beach residence
Unspecified (Historical)
Locations (2)
| Location | Context |
|---|---|
|
Epstein's home where massage appointments took place.
|
|
|
Specific room in the Palm Beach residence where Maxwell was seen.
|
Relationships (4)
Text states they ended their romantic relationship and went separate ways.
Maxwell entered a long-term, committed relationship with Ted Waitt.
Defense argues Maxwell did not supervise or direct Kellen.
Described as an employee who worked with Epstein.
Key Quotes (4)
"Epstein and Ms. Maxwell ended their romantic relationship and 'went their separate ways'"Source
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Quote #1
"Kellen 'immediately took over' responsibility for answering the phones and scheduling the massage appointments"Source
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Quote #2
"no aggravating role enhancement applies unless Ms. Maxwell supervised another criminal participant in the offense"Source
DOJ-OGR-00010439.jpg
Quote #3
"Kellen was 'an employee who worked with Epstein.'"Source
DOJ-OGR-00010439.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,190 characters)
Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 22 of 29
Epstein and Ms. Maxwell ended their romantic relationship and “went their separate ways”: Ms.
Maxwell “moved on” from Epstein, stopped coming into the office, started dating other men, and
eventually entered a long-term, committed relationship with Ted Waitt. (Tr. 2370-71, 2374,
2378-80). Juan Alessi testified that Kellen “immediately took over” responsibility for answering
the phones and scheduling the massage appointments at the Palm Beach residence as soon as she
was hired. (Tr. 833). Carolyn herself testified that there was a clear break in time between when
Ms. Maxwell called her to schedule massage appointments and when Sarah Kellen called her.
(Tr. 1527) (Ms. Maxwell called her in roughly “the first year or two” of her visits to the Palm
Beach residence—2001-2002, according to Carolyn—and Kellen called her thereafter). Carolyn
recalled seeing Ms. Maxwell in the kitchen office of the Palm Beach residence during the period
when Kellen scheduled her massage appointments. (Tr. 1527). But nothing in her testimony
indicates that Ms. Maxwell supervised or directed Kellen or that Ms. Maxwell had anything to
do with the massage appointments at that time. (Id.). Accordingly, there is no basis in the trial
record to conclude that Ms. Maxwell supervised Sarah Kellen in connection with the offense
conduct and therefore no basis to apply the aggravating role enhancement.
Maxwell “moved on” from Epstein, stopped coming into the office, started dating other men, and
eventually entered a long-term, committed relationship with Ted Waitt. (Tr. 2370-71, 2374,
2378-80). Juan Alessi testified that Kellen “immediately took over” responsibility for answering
the phones and scheduling the massage appointments at the Palm Beach residence as soon as she
was hired. (Tr. 833). Carolyn herself testified that there was a clear break in time between when
Ms. Maxwell called her to schedule massage appointments and when Sarah Kellen called her.
(Tr. 1527) (Ms. Maxwell called her in roughly “the first year or two” of her visits to the Palm
Beach residence—2001-2002, according to Carolyn—and Kellen called her thereafter). Carolyn
recalled seeing Ms. Maxwell in the kitchen office of the Palm Beach residence during the period
when Kellen scheduled her massage appointments. (Tr. 1527). But nothing in her testimony
indicates that Ms. Maxwell supervised or directed Kellen or that Ms. Maxwell had anything to
do with the massage appointments at that time. (Id.). Accordingly, there is no basis in the trial
record to conclude that Ms. Maxwell supervised Sarah Kellen in connection with the offense
conduct and therefore no basis to apply the aggravating role enhancement.
Both Probation and the government contend that the aggravating role enhancement
applies because Ms. Maxwell was the organizer or leader of criminal activity relevant to each
victim that was “otherwise extensive.” (PSR at 58-59). But this position ignores the first step in
the analysis. Regardless of whether the criminal activity was “otherwise extensive,” no
aggravating role enhancement applies unless Ms. Maxwell supervised another criminal
participant in the offense. USSG § 3B1.1, cmt. n.2. The record does not contain any evidence
applies because Ms. Maxwell was the organizer or leader of criminal activity relevant to each
victim that was “otherwise extensive.” (PSR at 58-59). But this position ignores the first step in
the analysis. Regardless of whether the criminal activity was “otherwise extensive,” no
aggravating role enhancement applies unless Ms. Maxwell supervised another criminal
participant in the offense. USSG § 3B1.1, cmt. n.2. The record does not contain any evidence
was Epstein’s assistant or Ms. Maxwell’s assistant. (Tr. 204). He further conceded that his best recollection was
that Kellen was “an employee who worked with Epstein.” (Id.).
that Kellen was “an employee who worked with Epstein.” (Id.).
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DOJ-OGR-00010439
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