DOJ-OGR-00011553.pdf

--- Page 1 --- **Document Header:** * Case 1:20-cr-00330-PAE * Document 737 * Filed 07/22/22 * Page 34 of 101 **Case Text:** With respect to the testimony of the pilots who testified, whether they -- whether an employee was paid by Maxwell or Epstein or technically reported to one, according to their job descriptions, is not the question here. The fact that pilots based on their observation thought at one point that Kellen reported to Maxwell proves the point that she had supervisory authority over Kellen and exercised it, whether in the chain of command or on their formal employment paperwork, she was just an employee for one or the other, it makes no difference. There was an overlap here. They had different roles in the conspiracy, and the defendant had a supervisory roll over Kellen. MR. EVERDELL: Your Honor, just to that point. Being present does not mean that you're a supervisor. That's way too far a stretch. So the fact that there was testimony she was present still in the house while Kellen was making the calls and scheduling the massage appointments means nothing in terms of supervisory authority. THE COURT: Thank you. Other enhancements before the government's objection is to be addressed. MS. MOE: No, your Honor. Thank you. MR. EVERDELL: Your Honor, I assume you don't want to hear or have any questions about the five-point enhancement for repeated and dangerous sex offenders. THE COURT: I believe I have what I need, but as I **Footer:** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011553