DOJ-OGR-00021035.pdf

Case 22-1426, Document 58, 02/28/2023, 3475901, Page209 of 221 A-409 34 1 With respect to the testimony of the pilots who 2 testified, whether they -- whether an employee was paid by 3 Maxwell or Epstein or technically reported to one, according to 4 their job descriptions, is not the question here. The fact 5 that pilots based on their observation thought at one point 6 that Kellen reported to Maxwell proves the point that she had 7 supervisory authority over Kellen and exercised it, whether in 8 the chain of command or on their formal employment paperwork, 9 she was just an employee for one or the other, it makes no 10 difference. There was an overlap here. They had different 11 roles in the conspiracy, and the defendant had a supervisory 12 roll over Kellen. 13 MR. EVERDELL: Your Honor, just to that point. Being 14 present does not mean that you're a supervisor. That's way too 15 far a stretch. So the fact that there was testimony she was 16 present still in the house while Kellen was making the calls 17 and scheduling the massage appointments means nothing in terms 18 of supervisory authority. 19 THE COURT: Thank you. Other enhancements before the 20 government's objection is to be addressed. 21 MS. MOE: No, your Honor. Thank you. 22 MR. EVERDELL: Your Honor, I assume you don't want to 23 hear or have any questions about the five-point enhancement for 24 repeated and dangerous sex offenders. 25 THE COURT: I believe I have what I need, but as I SOUTHERN DISTRICT REPORTERS, P.C. ... (212) 805-0300 DOJ-OGR-00021035