DOJ-OGR-00021596.pdf

Case 22-1426, Document 78, 06/29/2023, 3536039, Page166 of 217 M6SQmax1 51 1 addressing the factual objections speak directly to this issue. 2 The record at trial amply established that Melissa and Virginia 3 were victims of this conspiracy, and that the defendant had 4 been involved with recruiting Virginia, who in turn recruited 5 Carolyn, who in turn recruited Melissa. 6 With respect to Melissa in particular, we would not 7 that, like Virginia, her name appears in the defendant's little 8 black book, noting that she's a friend of Carolyn's. For all 9 those reasons, and the reasons in our brief, we think the trial 10 record amply establishes that they were both victims of the 11 conspiracy. 12 THE COURT: I agree with that, and for the reasons 13 indicated, do -- I agree with the government's objection to the 14 probation calculation for that reason. 15 I think that means we don't need to resolve the 16 factual objections that pertain to Carolyn's age. As I said, I 17 credit Carolyn's testimony. The objections I would overrule 18 because I think she accurately testified regarding her age both 19 in 2004 and 2005, but it doesn't answer the question, as I see 20 it, the legal question as to establishment of acts 21 conspiratorial conduct in the relevant two-month period. 22 With respect to fines, Mr. Everdell, what is now 23 paragraph 172 of the revised report, the defendant objects to 24 the inclusion a $10 million bequest from Epstein being included 25 in her assets for purposes of determining her ability to pay a SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00021596