DOJ-OGR-00021589.pdf

Case 22-1426, Document 78, 06/29/2023, 3536039, Page159 of 217 M6SQmax1 44 1 conviction. Visoski testified that Maxwell partially owned the 2 jet, and both pilots testified that she would tell them when to 3 fly Epstein or schedule flights for herself. The evidence at 4 trial demonstrates that Epstein and the defendant had the 5 pilots fly victims of the conspiracy. Across the timeframe of 6 all counts of conviction, Alessi, Visoski and Rodgers provided 7 personalized services that were peculiarly tailored to the 8 defendant's offenses and were not fungible services generally 9 available to the public. Again, I'm citing from the Carrozzella 10 case, 105 F.3d at 804. 11 In addition to these unknowing participants that testified at 12 trial, I find by a preponderance of the evidence that there were 13 other unknowing persons led by Maxwell. As Epstein's number one, 14 Ms. Maxwell managed Epstein's numerous households and interviewed, 15 hired and oversaw the household staff. The defendant had her own 16 personal assistants, like Sarah Kellen and another individual. 17 From the record, I can't determine the precise number of these 18 other individuals that unknowingly assisted Epstein and the 19 defendant in their criminal activity, but I find an adequate basis 20 in the record that the number is sufficient to make the activity 21 extensive within the meaning of 3B1.1(a) from 1994 to 2004. See 22 United States v. Archer, 671 F.3d 149 (2d Cir. 2011). 23 Last, the defendant objects to enhancement 2G1.1(b)(4)(B). 24 That provision increases the offense level by 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00021589