EPSTEIN
page 3 / 907 . OCR, unverified
because a
Paragraph thr Is
MR. E
VERDELL:
THE C
OURT:
MR. E
VERDELL:
The defendant also worked with
objection.
23.
thr
that a continuing objection,
Paragraph three,
objections
see as your
Epstein to
Mr.
tting my submissions.
identified and
first
I do credit
fter seeing her in the Mar-a-Lago parking
identify and
to this
Everdell?
apologize.
Yes,
THE C
OURT:
regarding
is
tha
saved under the user name
reas
that the de
t the compu
the essay in
onabl
overrul
th
your Honor.
infer
ne
The second objection is
transferred Ms
conspiracy.
. Maxwe
1]
approximat
the conclusion that
the paragraph.
fendant authored the essay.
objection.
Ms.
your Honor?
The first
Maxwell was
"Ghislaine."
overrul
th
Metadata indicat
ter was registered to "GMax" and the documen
the
objection
supported by the trial evidence
ted
C was
to the assertion that
overru
e that objection.
SOUTHERN D
STR
GI
PORT
(212)
805-0300
BRS, PseG.
Bank statements
Epstein
tely $23 million during the
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Case 1:20-cr-00330-PAE
M6SQmaxl
admitted at trial showed that accounts under
wired approximately $23 million over two occasions during the
Document 779
conspiracy to accounts of
assertion t
control ove
inference t
bearing her
As
the record
townhouse,
hat
r these accounts does not undermin
hat the de
name,
to the
that Eps
testimony that the det
So
"Ghislaine Maxwell."
fendant controlled the
Filed 08/22/22
The det
Page 8 of 101
Epstein's name
Epstein's accountant may have had access to and
th
reasonable
funds in accounts
tein bought the det
overrule that objection because
Fendant told her that
defendant her New York townhouse.
Paragraph 25
being operated through a culture of
fendant her New Yor
that is established by a preponderanc
third objection that there's no evidence in
credit Kate's
Epstein bought the
is an objection to the characterization
you're not maintaining an
I think that the def
fault is we
of the Palm Beach residenc
silence.
You'll let me know if
objection.
MR. EVERDELL: Yes.
are, your Honor.
THE COURT: Understood.
overrule this objection.
indicates that this was the case.
manual instructed employees to "see nothing,
nothing."
credit Mr.
Alessi's testimony that he understood
this
instruction to be a kind of
For example,
hear
SOUTH
E RN
STR
GI
(PORTERS, P.C.*
(21
2)
805-0300
Evidence at trial
the household
nothing,
warning that he was supposed
k City
Fendant's
say
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Case 1:20-cr-00330-PAE
M6SQmaxl
to be blind, deaf
Ms.
characterization concerning the de
Paragraph 26,
Document
and dumb,
Maxwell's lives.
isolation of
evidence.
overrule this objection
#79
fendant's
Filed 08/22/22
and to say nothing of
Page 9 of 101 9
Epstein's and
identi
there's an objection to the
fication and
articulated with respect to paragraph 22.
trial evidence established
isolated girls by spending
families.
Palm
New Mexico.
Beach residence alone
objections:
Epstein developed a
For example,
Paragraphs
th
fF minor girls as inconsistent with the
In addi
at the defendant and
time with them alone away
trial
for the same reasons as
tion, the
Epstein
from their
Annie's testimony regarding the trip to
Jane's testimony that she would spend time at the
wi
and 28
First, to the as
scheme
girls who recruited
each othe
that created a
th Epstein and the defendant.
the defendant makes two
sertion that the defendant and
r." And,
second,
"constant stream of
she objects to
the assertion that she encouraged minor girls to bring other
minor girls to provide
overrul
Again,
th
based on the
It s
paragraphs.
de
Carolyn in addition to at
turn recruited at least
objection.
The evidence indicated th
fendant's recruitment of Vi
lea
three
brought more girls.
trial testimony and evidence,
upported the
in
formation
Epstein with sexualized massages.
in these
schem
rginia.
st
friends,
SOUTHERN D
STR
GI
PORT
ERS,
(212
) 805-0300
2)
Virginia then enlis
two other girls.
and those
started with the
ted
Carolyn in
friends then
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