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Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 173 of 257 3007
LCKCmax7 Rebuttal - Ms. Comey

1 Maxwell? What do you think stands out in her memory more, who
2 the pregnant person in that picture was or the middle-aged man
3 who was masturbating and touching her breasts inside that room?
4 That is the definition of a peripheral detail.
5 And why is the defense focusing so much on these
6 peripheral details? Because they desperately want you to
7 ignore the fact that Carolyn has consistently remembered
8 Maxwell as one of the people involved in her experiences at
9 that house. They want you to forget that she mentioned Maxwell
10 not once, but twice in her 2009 deposition. Without prompting,
11 Carolyn named Maxwell as one of the two people who would call
12 her to schedule these massages with Jeffrey Epstein. She named
13 her as one of the two people she would talk to when she called
14 herself begging to come over because she needed the money. And
15 Carolyn told Sean that she met a woman named Maxwell, whose
16 first name she couldn't pronounce.
17 Now, back then there was no reason for Carolyn to go
18 into more detail about what was happening with Maxwell,
19 especially not in a lawsuit that was about Sarah and Epstein.
20 But when she was asked more detailed questions, she remembered
21 the core events, and she'd already mentioned Maxwell, without
22 prompting, long before there could be anything to contaminate
23 her memory.
24 Next, the defense suggests that somehow these clear
25 memories of Maxwell got implanted into the brains of Jane and

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300

DOJ-OGR-00017194