DOJ-OGR-00010564.jpg

764 KB

Extraction Summary

8
People
2
Organizations
1
Locations
3
Events
5
Relationships
5
Quotes

Document Information

Type: Legal filing (court document/sentencing memorandum)
File Size: 764 KB
Summary

This document is a page from a legal filing (likely a government sentencing memorandum) arguing for sentencing enhancements for Ghislaine Maxwell. It details her role as an 'organizer' and 'second in command' who supervised Epstein's staff (including pilots Visoski and Rodgers and house manager Alessi) and directed the activities of Sarah Kellen and victims like Virginia and Carolyn. The text cites trial testimony to establish that Maxwell ran an extensive operation facilitating Epstein's abuse of minors.

People (8)

Name Role Context
Ghislaine Maxwell Defendant / Organizer
Described as 'the defendant', 'second in command', 'number two' below Epstein; supervised staff including pilots and ...
Jeffrey Epstein Principal / Employer
Beneficiary of the operation for 'sexual gratification'; employer of the staff mentioned.
Larry Visoski Pilot
Transported minor victims; testified regarding Maxwell's role and Sarah Kellen's role.
David Rodgers Pilot
Transported minor victims; testified that Maxwell was 'number two' and supervised Kellen.
Sarah Kellen Assistant / Scheduler
Described as a 'knowing participant', assistant to Maxwell and Epstein; took over scheduling massages in approx 2002.
Virginia [Giuffre] Victim / Recruiter (in this context)
Instructed by Maxwell to 'show Carolyn what to do'.
Carolyn Victim / Witness
Received instructions from Virginia; had appointments scheduled by Maxwell and later Kellen; visited Palm Beach resid...
Juan Alessi Staff (House Manager)
Referred to as 'Alessi'; received 'innumerable directions' from Maxwell; testified regarding Kellen's duties.

Organizations (2)

Name Type Context
U.S.S.G.
United States Sentencing Guidelines, referenced regarding sentencing enhancements (§ 3B1.1).
DOJ
Department of Justice (implied by Bates stamp DOJ-OGR).

Timeline (3 events)

Approximately 2002
Sarah Kellen took over the scheduling of massages.
Unspecified
Multiple dates (Recurring)
Transporting minor victims to different locations.
Various locations
Multiple dates (Recurring)
Carolyn arriving for massage appointments at Palm Beach residence while Maxwell was present.
Palm Beach residence

Locations (1)

Location Context
Location where Maxwell was present when Carolyn arrived for appointments.

Relationships (5)

Ghislaine Maxwell Subordinate/Partner Jeffrey Epstein
Described as 'second in command' and 'number two' below Epstein.
Ghislaine Maxwell Supervisor Sarah Kellen
Maxwell supervised Kellen; Kellen was Maxwell's assistant.
Ghislaine Maxwell Supervisor Larry Visoski
Maxwell provided instructions to both pilots.
Ghislaine Maxwell Supervisor David Rodgers
Maxwell provided instructions to both pilots.
Ghislaine Maxwell Supervisor Juan Alessi
Maxwell gave Alessi 'innumerable directions'.

Key Quotes (5)

"someone who had been trained not to ask questions and who worked in a culture of silence carried out those necessary tasks."
Source
DOJ-OGR-00010564.jpg
Quote #1
"Both Larry Visoski and David Rodgers played the essential role of transporting minor victims to different locations, providing a discreet means of ensuring that Epstein had access to minor girls for his sexual gratification when he traveled."
Source
DOJ-OGR-00010564.jpg
Quote #2
"Maxwell's role as second in command beneath Epstein over all other employees."
Source
DOJ-OGR-00010564.jpg
Quote #3
"Sarah was more of Ghislaine’s assistant, but actually she was probably both"
Source
DOJ-OGR-00010564.jpg
Quote #4
"Maxwell was 'number two' below Epstein among Epstein's employees."
Source
DOJ-OGR-00010564.jpg
Quote #5

Full Extracted Text

Complete text extracted from the document (2,265 characters)

Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 29 of 55
someone who had been trained not to ask questions and who worked in a culture of silence carried
out those necessary tasks. Both Larry Visoski and David Rodgers played the essential role of
transporting minor victims to different locations, providing a discreet means of ensuring that
Epstein had access to minor girls for his sexual gratification when he traveled. The defendant
organized all of those individuals by telling Virginia to show Carolyn what to do, by scheduling
Carolyn’s appointments, by giving Alessi innumerable directions, and by providing instructions to
both pilots. (PSR ¶¶ 24, 62, 66). Additionally, the defendant supervised all of Epstein’s staff for
years, thereby running an extensive operation. Those individuals more than satisfy the definition
of an extensive operation in which the defendant served as an organizer.
In any event, this enhancement applies even under the defense’s interpretation of U.S.S.G.
§ 3B1.1 because Maxwell also supervised at least one other knowing participant in Sarah Kellen.
Larry Visoski testified that he understood Sarah Kellen to be one of Maxwell’s assistants. (Tr.
140). Even if he was not certain that Kellen had that precise title, his understanding is consistent
with Maxwell’s role as second in command beneath Epstein over all other employees. (Tr. 139).
Consistent with Visoski’ s recollection, David Rodgers testified his understanding was that “Sarah
was more of Ghislaine’s assistant, but actually she was probably both,” an assistant to the
defendant and an assistant to Epstein, again confirming that the defendant supervised Kellen. (Tr.
1890). Rodgers also testified that Maxwell was “number two” below Epstein among Epstein’s
employees. (Tr. 1809-10). Alessi testified that he did not know exactly what Kellen’s job
responsibilities were, but Kellen took over the “scheduling of massages” in approximately 2002.
(Tr. 833). Carolyn also recalled that even after Kellen took over calling to schedule massages,
Maxwell was still present inside the Palm Beach residence when Carolyn arrived for massage
appointments. (Tr. 1527). Moreover, the household manual makes clear that as of 2005, Maxwell
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