DOJ-OGR-00021554.pdf

Case 22-1426, Document 78, 06/29/2023, 3536039, Page124 of 217 SA-378 M6SQmax1 9 1 to be blind, deaf and dumb, and to say nothing of Epstein's and 2 Ms. Maxwell's lives. 3 Paragraph 26, there's an objection to the 4 characterization concerning the defendant's identification and 5 isolation of minor girls as inconsistent with the trial 6 evidence. I overrule this objection for the same reasons as 7 articulated with respect to paragraph 22. In addition, the 8 trial evidence established that the defendant and Epstein 9 isolated girls by spending time with them alone away from their 10 families. For example, Annie's testimony regarding the trip to 11 New Mexico. Jane's testimony that she would spend time at the 12 Palm Beach residence alone with Epstein and the defendant. 13 Paragraphs 27 and 28 the defendant makes two 14 objections: First, to the assertion that the defendant and 15 Epstein developed a scheme that created a "constant stream of 16 girls who recruited each other." And, second, she objects to 17 the assertion that she encouraged minor girls to bring other 18 minor girls to provide Epstein with sexualized massages. 19 Again, based on the trial testimony and evidence, I 20 overrule the objection. It supported the information in these 21 paragraphs. The evidence indicated the scheme started with the 22 defendant's recruitment of Virginia. Virginia then enlisted 23 Carolyn in addition to at least two other girls. Carolyn in 24 turn recruited at least three friends, and those friends then 25 brought more girls. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00021554