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Case 1:20-cr-00330-PAE Document 741 Filed 08/10/22 Page 30 of 106 34
LBTCMAX2 Opening - Ms. Pomerantz

1 second in command. She was involved in every detail of
2 Epstein's life. During the ten years the defendant and Epstein
3 committed these crimes together, the defendant was the lady of
4 the house. She ran Epstein's various properties, hiring and
5 firing employees. She imposed rules, instructing employees to
6 not speak directly with Epstein or talking with other people
7 visiting Epstein's homes. When she took charge of those homes,
8 the rules for staff were strict. Employees were to see
9 nothing, hear nothing, say nothing. There was a culture of
10 silence. That was by design, the defendant's design, because
11 behind closed doors, the defendant and Epstein were committing
12 heinous crimes. They were sexually abusing teenage girls.
13 The defendant and Epstein were partners in crime.
14 They had a playbook. First, they got access to young girls,
15 then they gained their trust. They learned about each girl's
16 hopes and dreams. They learned about each girl's families,
17 often targeting the daughters of single mothers. The defendant
18 and Epstein promised these girls the world. Some of the girls
19 had difficult home lives and came from families that were
20 struggling to make ends meet. The defendant and Epstein were
21 wealthy, powerful, and well connected, and they flaunted it.
22 They made sure everybody knew. The defendant and Epstein made
23 young girls believe that their dreams could come true. They
24 figured out what the girls dreamed of becoming when they grew
25 up and they promised to help, promised to help pay for school,

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
DOJ-OGR-00011695