Micron Document

EPSTEIN
page 6 / 907 . OCR, unverified

sex toys. She was unaware that he was engaging in sexual

activity with anyone other than her in the 1990s and 2000s.

She never gave Epstein a massage. The credible testimony and

evidence admitted at trial disproves these assertions which

were made under oath.

Paragraph 79, the defendant objects to the

characterization of the offense conduct as contrary to the

trial record. Here, defense hasn't provided any reason

specifying this, and I don't see one. So based on the written

objection, it's overruled.

Paragraph 81, the defendant objects to the assertion

that Ms. Maxwell had direct responsibility for any sexualized

massages that several women or any other people that Carolyn

may have brought to Epstein's residence may have performed, and

she contends there's no record that she interfaced with these

individuals. I am prepared to overrule that objection.

The paragraph makes clear that these individuals did

not interact directly with Ms. Maxwell. Nevertheless, for the

reasons explained a little while ago in overruling the

objections to paragraphs 27 and 28, I do conclude that the


vidence at trial established that the defendant's recruitment

of Virginia set the recruitment scheme in motion that resulted

SOUTHERN DISTRICT REPORTERS, P.C.»

(212) 805-0300

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Case 1:20-cr-00330-PAE Document 779 Filed 08/22/22 Page16of101 16
M6SQmaxl

in the abuse of these individuals.

Paragraph 82, the objection is to the assertion that

the records recovered from the Palm Beach residence during the

2005 search reveal that additional minors provided Epstein with

sexualized massages between 2001 and 2004. Again, I overrule

the objection. The trial record including message pads, phone

book entries, and testimony of witnesses establishes by a

preponderance that the information contained in this paragraph

is accurate.

Paragraph 83, so there was a revision here. I'm not

po
.

sure if there is a continuing objection, Mr. Everdel The

previous objection was to the assertion that the defendant is

responsible for the victimization of untold number of other

victims. The probation department adopted the government's

suggestion, revised the paragraph to assert that the defendant

is responsible for the victimization of additional minor

victims. To the extent there is a continuing objection,

overrule it for the reasons stated regarding paragraphs 27 and

28.

Paragraph 85 is an objection to the inclusion of

Kate's victim impact statement and her status under the CVRA.

We have litigated the question of Kate's ability to make a

statement here. I believe that defense's ultimate position was

that with the requested redactions, there were no objections to

her making a statement. Do I have that right?

SOUTHERN DISTRICT REPORTERS, P.C.»

(212) 805-0300

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Case 1:20-cr-00330-PAE

M6SQmaxl

MR.

EVERDELL:

THE

COURT: So

Document 779

That's corre

I did reject

for the reasons explained in my order.

Filed 08/22/22

Ct,

the request

And as

Page 17 of 101


your Honor.

for redactions

[ explained in

overruling the objection to paragraphs 39 to 45,

testimony and her statement are relevan

I've indicated she may give.

pertaining to

turn to thos

when we g

EVERDELL:

calculation objections and th

that?

MR.
offense level
the financial

THE

continuing ob

requests and

penalties

COURT:

Yes,

And wi

fine and assets and the like.

t to the fin

Yes, your Ho

for now?

precisely,

I think otherwise that's it

for what

th that,

Mr.

e.

Everdell,

Kate's

t to sentencing which
there's objections

I think we can

okay with

nor.

So we'll delay the

ones related to

and we'll pick those up.

I understand to be

jections after probation responded to your

assertions.

MR.
highlight is
according to
penalties.

representatio

EVERDELL:

paragraph 173,

ns that

on covering t
it does deal

TH

ma

and 193.

hat later,

with the

COURT:

Yes,

Agree with that,

Your Honor,

there was an objection,

Mr.

Everdell?

the only one

[ believe

it's

that I would

framed

which de

we take issue with, but i+

als with the

financial

The government made in their response some

fF you're planning

we can reserve that till later because

financial penalties.

I have objections to 172,

178, 192

SOUTHERN D

STR

CT RE

PO

RTERS, P.C.»