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689 KB
Extraction Summary
7
People
2
Organizations
1
Locations
2
Events
4
Relationships
4
Quotes
Document Information
Type:
Legal filing / court document (defense sentencing memorandum)
File Size:
689 KB
Summary
This document is a page from a defense sentencing memorandum for Ghislaine Maxwell, filed in June 2022. The defense argues against applying 2004 sentencing guidelines, asserting that Maxwell had ceased participation in the conspiracy by 2002/2003 and was 'replaced' by Sarah Kellen for scheduling duties at the Palm Beach residence. The text cites testimony from Cimberly Espinosa, Juan Alessi, and a witness named Carolyn to support the claim that Maxwell had moved on to a relationship with Ted Waitt and was not involved in Epstein's conduct in late 2004.
People (7)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of sentencing arguments; defense claims she disengaged from conspiracy by 2002/2003.
|
| Jeffrey Epstein | Co-conspirator |
Mentioned regarding his criminal conduct in late 2004.
|
| Sarah Kellen | Associate/Employee |
Took over responsibility for scheduling massage appointments and answering phones at Palm Beach residence, replacing ...
|
| Cimberly Espinosa | Assistant to Maxwell |
Testified that Maxwell had 'moved on' from Epstein by 2002.
|
| Ted Waitt | Partner |
Person with whom Maxwell began a long-term relationship around 2002.
|
| Juan Alessi | Employee (House Manager) |
Testified regarding Sarah Kellen taking over duties in 2002.
|
| Carolyn | Witness/Victim |
Testified that Maxwell only scheduled appointments in the first year or two, then Kellen took over.
|
Timeline (2 events)
2002
Sarah Kellen hired and takes over scheduling duties at Palm Beach residence.
Palm Beach residence
November-December 2004
Time period of Epstein's criminal conduct cited by prosecution; defense argues Maxwell was not involved.
Unspecified
Locations (1)
| Location | Context |
|---|---|
|
Location where massage appointments were scheduled and conducted.
|
Relationships (4)
Defense argues Maxwell 'moved on' from Epstein by 2002.
Described as a 'long-term relationship' starting c. 2002.
Kellen 'replaced' Maxwell in scheduling duties.
Described as 'Ms. Maxwell's assistant'.
Key Quotes (4)
"variance would provide just punishment for the offense and promote respect for the law because it would punish Ms. Maxwell only for the conduct for which she was directly responsible"Source
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Quote #1
"by 2002 Ms. Maxwell had “moved on” from Epstein, had stopped coming to the office, and had begun a long-term relationship with Ted Waitt."Source
DOJ-OGR-00010430.jpg
Quote #2
"Sarah Kellen... “immediately took over” responsibility for answering the phones and scheduling the massage appointments at the Palm Beach residence as soon as she was hired."Source
DOJ-OGR-00010430.jpg
Quote #3
"In sum, the record is clear that by 2002 or 2003 at the latest Ms. Maxwell had stopped actively participating in the offense conduct and had been replaced by Kellen."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,081 characters)
Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 13 of 29
variance would provide just punishment for the offense and promote respect for the law because
it would punish Ms. Maxwell only for the conduct for which she was directly responsible, rather
than artificially inflating her sentence based on two months’ worth of Epstein’s criminal conduct
in which she was not involved.
it would punish Ms. Maxwell only for the conduct for which she was directly responsible, rather
than artificially inflating her sentence based on two months’ worth of Epstein’s criminal conduct
in which she was not involved.
There is no evidence in the record that Ms. Maxwell did anything in furtherance of the
conspiracy in November or December 2004. In fact, the evidence clearly showed that by that
time, Ms. Maxwell was in a committed relationship with another man and Sarah Kellen had
taken over responsibility for scheduling the massage appointments at the Palm Beach residence.
Ms. Maxwell’s assistant, Cimberly Espinosa, testified that by 2002 Ms. Maxwell had “moved
on” from Epstein, had stopped coming to the office, and had begun a long-term relationship with
Ted Waitt. (Tr. 2370-71, 2374, 2378-80). Juan Alessi testified that Sarah Kellen, whom he
recalled seeing for the first time towards the end of his employment in 2002, “immediately took
over” responsibility for answering the phones and scheduling the massage appointments at the
Palm Beach residence as soon as she was hired. (Tr. 832-33). Carolyn testified that Ms.
Maxwell called her to schedule massage appointments only in “the first year or two” and that
Sarah Kellen called her thereafter. (Tr. 1527). In sum, the record is clear that by 2002 or 2003 at
the latest Ms. Maxwell had stopped actively participating in the offense conduct and had been
replaced by Kellen.
conspiracy in November or December 2004. In fact, the evidence clearly showed that by that
time, Ms. Maxwell was in a committed relationship with another man and Sarah Kellen had
taken over responsibility for scheduling the massage appointments at the Palm Beach residence.
Ms. Maxwell’s assistant, Cimberly Espinosa, testified that by 2002 Ms. Maxwell had “moved
on” from Epstein, had stopped coming to the office, and had begun a long-term relationship with
Ted Waitt. (Tr. 2370-71, 2374, 2378-80). Juan Alessi testified that Sarah Kellen, whom he
recalled seeing for the first time towards the end of his employment in 2002, “immediately took
over” responsibility for answering the phones and scheduling the massage appointments at the
Palm Beach residence as soon as she was hired. (Tr. 832-33). Carolyn testified that Ms.
Maxwell called her to schedule massage appointments only in “the first year or two” and that
Sarah Kellen called her thereafter. (Tr. 1527). In sum, the record is clear that by 2002 or 2003 at
the latest Ms. Maxwell had stopped actively participating in the offense conduct and had been
replaced by Kellen.
Applying the 2004 Guidelines would significantly increase Ms. Maxwell’s sentencing
range based on a finding by a mere preponderance that her co-conspirator Epstein engaged in
offense conduct in the final two months of 2004 that Ms. Maxwell had nothing to do with and
was not personally responsible for. That result would be fundamentally unjust and contrary to
the purposes of sentencing. See United States v. Reuter, 463 F.3d 792, 793 (7th Cir. 2006)
range based on a finding by a mere preponderance that her co-conspirator Epstein engaged in
offense conduct in the final two months of 2004 that Ms. Maxwell had nothing to do with and
was not personally responsible for. That result would be fundamentally unjust and contrary to
the purposes of sentencing. See United States v. Reuter, 463 F.3d 792, 793 (7th Cir. 2006)
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DOJ-OGR-00010430
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