DOJ-OGR-00011547.pdf

Case 1:20-cr-00330-PAE Document 737 Filed 07/22/22 Page 28 of 101 28 M6SQmax1 your Honor. If the Court remembers the record evidence, there was some evidence of money moving, but it was to buy a helicopter that was not for her. We heard testimony from Larry Visoski that he often kept assets of cars in his name for Mr. Epstein. That doesn't make Larry Visoski a participant in the criminal endeavors. I think it's a stretch for the government to point to that as some sort of evidence of continued involvement or continued profit after the end date of the conspiracy. I just wanted to make that one point, your Honor. THE COURT: Anything on that, Ms. Moe? MS. MOE: Your Honor, with respect to the financial transaction, we offered that along with other evidence to refute the claim that the defendant had moved on, which, as we noted, is an expression that has no legal meaning. And so contrary to the assertion that the defendant had moved on and was no longer associated with Epstein, the trial evidence established that she remained a close associate for many years, and that is the purpose for which we offered that evidence. THE COURT: Understood. Thank you. I do want to address -- do you have other -- I want to ask about 3(b)(1). MR. EVERDELL: Yes, your Honor. THE COURT: I think it's for the government. So as I see the question here, the guidelines require me to find that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00011547