Closing Argument by the Prosecution

MS. MOE: Ghislaine Maxwell was dangerous. She was a grown woman who preyed on vulnerable kids, young girls from struggling families. She targeted a girl whose father had just died. She targeted a girl whose mother was an alcoholic. She targeted a girl with a single mom who was struggling to raise her daughters. Maxwell was a sophisticated predator who knew exactly what she was doing. She ran the same playbook again and again and again. She manipulated her victims and she groomed them for sexual abuse. She caused deep and lasting harm to young girls. It is time to hold her accountable. Over the last few weeks, you've seen and heard a lot of evidence. You've heard from witnesses from all walks of life. You heard powerful testimony from women who told you about traumatizing events from their childhoods. You heard from people they talked to years ago about those events who corroborated their testimony. You heard from law enforcement officers who searched the properties where these crimes happened.

You heard from employees who worked for Maxwell and Epstein. In addition to those witnesses, you've seen documents, phone messages, FedEx records, a household manual, and a little black book with victim names. You also saw bank records showing the $30 million that Jeffrey Epstein paid to Ghislaine Maxwell. Ladies and gentlemen, this summation is our opportunity to explain how all of that evidence fits together, because the proof is in. It's clear, it's consistent, and it points to only one conclusion: Maxwell is guilty. So today, I want to talk to you about eight different reasons that you know Maxwell is guilty. After that, I'll discuss the charges in this case, and then I'll address some of the arguments the defense has made to you throughout this trial. So let's start with the eight reasons that you know Maxwell is guilty.

The first reason that you know Maxwell knew exactly what she was doing when she recruited and groomed young girls for abuse is that Maxwell and Epstein were partners. They were partners in crime who sexually exploited young girls together. So let's talk about the relationship between Maxwell and Epstein and how it shows you that Maxwell committed these crimes together with Jeffrey Epstein. The evidence at this trial showed you that Maxwell was Jeffrey Epstein's right hand. For many years they were in a romantic relationship; they were partners. In 2002, Maxwell wrote this essay; it's Government Exhibit 422. Now, you know that Maxwell wrote this essay because you saw the metadata that showed that the author of this document was G. Max, the defendant. And the document was on a computer that was registered to Maxwell. Here's that metadata.

So in this essay, here's how Maxwell described her relationship with Jeffrey Epstein: Jeffrey and Ghislaine have been together, a couple, for the last eleven years. They are, contrary to what many people think, rarely apart. I almost always see them together. Jeffrey and Ghislaine complement each other really well, and I cannot remember one without the other. On top of being great partners, they are also the best of friends. A couple for eleven years. Great partners. Rarely apart. Best of friends. Does that sound like a personal assistant compartmentalized from Jeffrey Epstein's life? Of course not. What Maxwell described in this essay is the relationship that you heard throughout this entire trial. Close partners who operated together. And, ladies and gentlemen, when you're with someone for eleven years, you know what they like. Epstein liked underage girls. He liked to touch underage girls. Maxwell knew it. Make no mistake. Maxwell was crucial to the whole scheme.

Epstein could not have done this alone. A single middle-aged man who invites a teenage girl to visit his ranch, to come to his house, to fly to New York, is creepy. That sets off alarm bells. But when that man is accompanied by a posh, smiling, respectable, age-appropriate woman, that's when everything starts to seem legitimate. And when that woman encourages those girls to massage that man, when she acts like it's totally normal for the man to touch those girls, it lures them into a trap. It allows the man to silence the alarm bells and get away with molesting those girls. Maxwell was the key to the whole operation. At this trial, you saw photographs that showed how close Maxwell and Epstein were over a span of many, many years. And the relationship that you saw in those photos was the same

MS. MOE: relationship that Maxwell described in an essay. They were close. They were partners. They were rarely apart. Let's take a look at some of those. You saw many photos for the many years that Maxwell and Epstein were partners. And what you're looking at here is a couple. Arms around each other, doting looks on their faces. Here are three more photographs. As you look through these, notice that they are getting older. Their haircuts change; time appears to be passing. But it's the same relationship the whole way through. Cheek-to-cheek, arms wrapped around each other. Here are three more. These photographs show you what their relationship was really like. They were incredibly close for many years. I want to show you two more photographs. That's Government Exhibit 313 and 342. On the left, you're looking at Maxwell and Epstein swimming naked together in a pool. They are not alone; someone else is taking the picture. They're laughing.

On the right, that's Maxwell massaging Epstein's foot with her breasts. She's smiling. A third person is taking the photograph. What you're looking at in these two photographs are two people with a sexual relationship. They were partners. And throughout this trial, you heard witnesses tell you how Maxwell made this kind of sexual behavior feel normal and casual. That's exactly what you're looking at in these photographs. Now, being the right hand to a multimillionaire came with serious benefits to Maxwell. As his partner, she had access to enormous wealth and she lived his luxury lifestyle. She spent her weeks flying around on Epstein's private jet from his mansion on the Upper East Side, to his ranch in New Mexico, to his villa in Palm Beach, to his apartment in Paris, and to his private island in the U.S. Virgin Islands. Together, they moved in a social circle of rich and famous people. Now, Maxwell was not just Epstein's partner; you learned that she was the lady of the house.

You heard from Juan Alessi, the house manager in Palm Beach, who told you all about Maxwell's place in that household from the early 1990s, until Alessi left in December of 2002. Here's Alessi's testimony about that. Juan Alessi told you that the day Maxwell came to the house, she took over right away; and she told Alessi that she was going to be the lady of the house. And what Alessi told you about Maxwell is backed up by the household manual, that document full of rules that you saw at trial. Those were rules that Maxwell put in place. You know she put those rules in place. Alessi testified that Maxwell gave him this manual. During Juan Alessi's testimony, you saw many pages from this manual, and you saw all the sections that talked about Maxwell and Epstein: What to serve them for breakfast, how to arrange their desks, where to put their stationery. I'm not going to go through all of those pages with you now, but here's just one example.

This section tells employees to make sure to set out two different sizes of Maxwell's notepads, one marked "Lady Ghislaine." Now, you can read through that entire manual when you deliberate, but you're just going to find two names throughout that whole household manual, it's Maxwell and Epstein's guests, Maxwell and Epstein's phone directories, Maxwell and Epstein's breakfast preferences, Maxwell and Epstein's phone messages, Maxwell and Epstein's phone lines, Maxwell and Epstein's residence. These were Maxwell and Epstein's rules. This manual was clear. She was the lady of the house. And no matter how hard the defense has tried to suggest throughout this trial that Maxwell was just an employee, that she didn't know what was going on, this document tells you otherwise. This manual makes crystal clear who mattered in that household in Palm Beach. It was Maxwell and Epstein together. Of course, Maxwell knew what was going on in that house.

She had a firm grip on everything that was happening there. She was Epstein's partner. Now, the household manual isn't the only document that you saw at this trial that showed you that Maxwell had a firm grip on that household and that she knew everything that was going on there. I want you to take a look at Government Exhibit 420. This document is dated in 2002. And the metadata tells you that it was written by, you guessed it, G. Max. This document shows you that Maxwell wrote out a detailed list of 13 different oils and lotions for massages in Palm Beach. She was intimately involved in all of the details of Epstein's so-called massages.

MS. MOE: In fact, even the sex toys in the massage room had to be returned to a basket in Maxwell's bathroom closet. That's what Mr. Alessi had to do. Here's his testimony about that. He told you about having to wash off dildos after the massages and how he would return them to a basket in Maxwell's closet, because that's where they were kept. Again and again, the evidence at this trial showed you how closely Maxwell was involved in Epstein's so-called massages. She managed all of the details right down to the lotions and the oils. She was in on the whole thing. So we were talking about the household manual. What else does the household manual tell you? You remember the disturbing warning in that manual. Here it is: Remember that you see nothing, hear nothing, say nothing, except to answer a question directed at you. Respect their privacy. You learned that this powerful warning to employees was effective. Here's Mr. Alessi's testimony about that.

He explained that this rule was a kind of warning that he was supposed to be blind, deaf, and dumb, to say nothing of their lives. Ladies and gentlemen, now that you've sat through this entire trial, you know exactly why Maxwell told workers in the house to see nothing, hear nothing, and say nothing. It's because she was Epstein's partner in crime. And in that house, behind closed doors, Maxwell and Epstein were committing horrifying crimes. That brings us to the second reason. The second reason that you know that Maxwell is guilty is that she ran the same playbook over and over and over again as she exploited young girls. The similarities between what happened to Jane and Annie and Carolyn and Kate are incredibly powerful evidence of the defendant's guilt. So I want to talk to you about the playbook that Maxwell ran again and again and again. Before we talk about this, remember that you heard from Dr.

Rocchio, an expert psychologist who specializes in treating victims of sexual abuse for the trauma they suffered as a result of their childhood experiences. She told you that childhood sexual abuse typically occurs in an established relationship by a perpetrator who's known to the victim. Dr. Rocchio explained to you that perpetrators are able to abuse kids by using a series of techniques called grooming. She walked you through the stages of grooming. Here they are: Identifying and selecting the child. Obtaining access and isolating the child. Engaging in manipulation in order to build trust and attachment. Desensitizing the child to physical touch and sexual content. And finally, maintaining control over the child to continue abuse and decrease the likelihood that the victim will report. So let's talk through the ways that Maxwell and Epstein ran this exact playbook. First, the ways that they selected these girls tells you that they were targeting vulnerable kids.

It is not an accident that Jane and Kate and Annie and Carolyn all came from single-mother households. It is not an accident that all of their families were struggling in different ways. What that tells you is that Maxwell and Epstein selected these girls carefully. When Jane was 14, her father had just died and her family was struggling financially. She didn't have her own bed to sleep in. Things were really tough at home. She had big dreams of working in the arts one day. She was talented. When Annie was 16, she lived with her mother who was supporting her daughters by herself on a limited income. Annie was hoping to go to a good college. When Kate was 17, she lived with her mother who had been sick. Things were difficult at home and Kate was alone a lot. And she was dazzled by this impressive woman who made her feel special. When Carolyn was 14, she lived with her mom, a single mom who was an alcoholic.

She had previously been sexually abused by family members and she told Maxwell about that. Make no mistake. Selecting these girls was predatory behavior. Maxwell and Epstein picked vulnerable girls. They found kids who needed something. They were exploiting that need. So what was the next stage of the playbook? It was isolating the girls. Maxwell and Epstein got them alone in Epstein's enormous houses, alone on trips to Epstein's sprawling ranch, his mansion on the Upper East Side. They got them alone in massage rooms. They were away from their parents. Remember how Jane told you that her mother was never invited when she would spend time with Maxwell and Epstein? That was by design. It was Maxwell's design. Maxwell was

MS. MOE: hanging out with these girls alone, isolating them and befriending them. And remember how Annie's mom told you that Epstein called her to invite Annie to New Mexico? Remember how Annie's mom explained that Epstein said about 20 to 25 girls would be there and so would his wife, Ghislaine. And remember how Annie told you that when she got to New Mexico, she found herself alone with Maxwell and Epstein? They were isolating these girls for a reason. Then came the next step in the playbook: Making these girls feel special, giving them gifts, making friends, giving them money, promising to help with their futures, promises like sending Annie on a trip to Thailand or helping to pay for Jane's voice lessons and tuition. They were building a relationship. They were building trust for what was going to come next. Once the girls were manipulated this way, Maxwell helped Epstein normalize sexual situations and sexual touching.

For Annie, it started with Maxwell telling her how to massage Epstein's feet. And it escalated to Maxwell touching Annie's breasts in a so-called massage. For Kate too it started with Maxwell asking her to rub Epstein's feet. For Jane it started with Maxwell being topless by the pool, and then Maxwell talking about boyfriends and sex with Jane. And it escalated to sexualized massages. Again and again throughout this trial, you heard about how these girls were asked to perform sexualized massages on Jeffrey Epstein. While we're talking about physical touch, let me just pause here and point out that Annie, Carolyn, and Jane all testified that Maxwell touched their breasts. They all had very specific memories about that. Here's Carolyn's testimony about that: You remember that she told you about Maxwell coming into the massage room when Carolyn was naked. Maxwell touched Carolyn's breasts and told her that she had a good body.

Jane told you about Maxwell touching her breasts too during sexual encounters with Maxwell and Epstein during so-called massages. Maxwell did it to Annie, too. Here's her testimony about that. Here's what she said about how that made her feel: I was very uncomfortable and fearful and wanted to get off the table, that massage table, and wanted it to be over with. Ladies and gentlemen, Maxwell touched these girls' bodies. Three different women told you about Maxwell touching their breasts when they were kids in massage rooms on massage tables and in the context of so-called massages. It's not an accident. It happened again and again and again. It is powerful evidence of Maxwell's guilt. And the woman they all described to you when they took that stand, when they talked about their memories of her, ladies and gentlemen, they were describing the same woman. Not just her name and her physical appearance, but what she was like. These girls knew her. They knew Maxwell.

Charming, sophisticated, engaging, impressive. A woman who moved in a social circle that was intimidating. These witnesses were describing the same woman, Ghislaine Maxwell. They knew her. The relationships that Maxwell cultivated with these girls were essential to the scheme. Those relationships helped Maxwell and Epstein maintain control of these girls for years. Jane didn't become Epstein's so-called goddaughter by accident. Maxwell helped establish a close relationship that became a cover for sexual abuse. The patterns you saw throughout this trial, the playbook that Maxwell ran for years, is just one of the many ways that you know that Maxwell is guilty. I want to talk to you now about what Maxwell and Epstein did to Jane. That's the third way that you know that Maxwell is guilty. This is Jane. Jane turned 14 years old in the summer of 1994, when she met Maxwell at a summer camp for kids. Maxwell and Epstein told her that Epstein was a wealthy donor who gave scholarships.

But you learned that meeting Maxwell and Epstein at summer camp was the beginning of years of sexual abuse. What Jane told you about meeting Maxwell in summer camp in 1994 is backed up by documents. So let's talk about it. Here's Jane's application to Interlochen for the summer of 1994. She weighed 90 pounds and she just finished the seventh grade. There can't be any question that Jane was at Interlochen that summer. And there also cannot be any question that Maxwell was there that summer, too. Let's take a look at the flight records. They show you that on August 18th, 1994, Jeffrey Epstein flew to Traverse

MS. MOE: City, Michigan. That's where Interlochen is. And sure enough, two days later, on the 20th, Maxwell was on the flight home with him. She's right there in the flight records, "GM." She's listed on it as a passenger on the plane ride home. These flight records prove to you that Maxwell was there that summer. That's when she met Jane. That's how it all started. You also know that Epstein and Maxwell were there in August of 1994 because Epstein had donated a scholarship lodge. Here's the letter you saw from Interlochen; it's dated February 1994. And they are thanking Epstein for donating the money to build a scholarship lodge. Government Exhibit 745 is a photograph of that lodge. And most importantly, you know that Maxwell was at Interlochen that summer because Maxwell got a letter from Interlochen in December 1994, just months after she'd met Jane at camp.

The folks at Interlochen were writing Maxwell to tell her that they found an envelope while they were cleaning the Epstein lodge and they wanted to return it to her. So when Jane told you about meeting Maxwell and Epstein at summer camp in 1994, you know that's the truth. What Jane didn't know that summer, but what you learned at this trial, is that Maxwell and Epstein were targeting her for sexual abuse. By the time she started spending time with Maxwell and Epstein in Palm Beach, she was an 8th grader. She was in middle school. Epstein told Jane's mother that he would help Jane; that he gave scholarships. That was the cover. But once Maxwell and Epstein started spending time with Jane alone, they started grooming her for abuse right away. Jane described how Maxwell acted like she was an older sister figure; how she went to the movies with Maxwell and Epstein. They took her shopping. They bought her white underwear. Epstein gave her money. She saw Maxwell topless by the pool.

And by the way, you know that's true because now you've seen Maxwell topless by the pool too. Jane told you about how Maxwell would chitchat with her, talking about school and then about boyfriends and sex. There was a purpose for all of this. Maxwell and Epstein were setting the stage for what was going to come next. Jane told you about how one day after this initial grooming, Epstein walked her down to the pool house. He pulled her onto his lap and started masturbating on her. Here's her testimony about that: She was frozen in fear. She had never seen a penis before. It was horrifying. What did Maxwell do next? She started teaching Jane how to massage Epstein. Here's her testimony about that: Maxwell would show her how Jeffrey likes to be massaged. And you know what happened next: Fully ramping up, breaking down barriers, making it all seem okay. Maxwell and Epstein started sexually abusing Jane during these so-called massages.

Maxwell played an essential role in these abusive massages. As Jane told you, Maxwell was the person most frequently in the room when Epstein molested her. Along with Epstein, Maxwell gave Jane instructions on how to massage Epstein. Here's her testimony about that: Showing you, you know, what he likes; what -- you know, what men, what women like, sort of touching on breasts and touching his penis. And while all of this was happening, while Jane was being abused, Maxwell was right there acting casually and behaving like all of this was normal. She was doing that because she was trying to normalize sexual abuse. Here's Jane's testimony about that: It seemed very casual, like it was -- like it was very normal, like it was not a big deal. She's describing how Maxwell would act during those massages. She said, It made me feel confused because that did not feel normal to me. I'd never seen anything like this or felt any of this and it was very embarrassing.

You know, it's all these mixed emotions. When you're 14, you have no idea what's going on. Ladies and gentlemen, none of this was normal. It was not okay. It was deeply disturbing. They were molesting an underage girl. That's what Maxwell did. And Jane told you about all the ways in which she was sexually abused during these so-called massages. You saw in her face how hard it was for her to talk to you about that. It was hard to hear. She told you about having to touch Epstein's penis, how Epstein touched her vagina and used vibrators; how he put a back massager on her vagina, even when she said it hurt. She told you that Maxwell touched her breasts, that there were

MS. MOE: hands everywhere. She also told you that Maxwell and Epstein would sometimes involve her in horrifying group encounters with other women. The sexual abuse didn't just happen in Florida. You learned that Maxwell and Epstein started taking Jane on trips to Epstein's house in New York. She flew to New York on commercial flights, but also in the private jet. Ask yourselves, does it seem normal to you that two adults were spending their weekends on trips with a 14-year-old girl? Absolutely not. There was nothing normal about that. And your common sense tells you they weren't bringing her to New York for some kind of scholarship or mentoring program. They were bringing her to New York to be molested, and that is exactly what happened. And by the way, you know that Maxwell and Epstein weren't simply charitable, wealthy people who were just trying to help young girls. There are real ways, official ways, that you can help and mentor young people, but that's not what they did at all.

There wasn't some scholarship foundation, there certainly weren't any scholarship boys. There were no applications or legitimate selection criteria. To qualify, you just had to be a pretty, young, vulnerable girl. That's who they were targeting. Jane told you about those trips with Maxwell and Epstein to New York when she was 14 and 15 and 16. She told you about the abuse that happened there. He would use vibrators on me. He would put his fingers in my vagina. He would start to masturbate and he would ask me to straddle his face. He would ask me to, like, squeeze his nipples really hard while he came. Let's talk about the house in New York where that happened. Here's the massage room in New York. As you look at these photos -- we're going to look at two -- let me read to you from the transcript what Jane testified about this room. And you're going to see she's describing this very same massage room. Here's what she said: It was off the master bathroom. Notice the bathroom on the left.

And it looked like it was maybe supposed to be like a giant walk-in closet. And it was very dark. There was a built-in bookcase on the right-hand side, and there was a stereo system and there was, like, music playing. And I don't know if it was painted dark, but -- or maybe that was the lighting, but it sort of had this red mood. And then there was just a giant black massage table in the middle of it. Ladies and gentlemen, you know that Jane has been in this massage room because it looks exactly like she remembered. During the years that Maxwell and Epstein abused Jane, she was literally growing up in front of their eyes. She turned 15 and 16 and 17. This went on for years. They maintained a coercive relationship with her into her early twenties. Now, I've already talked about some of the ways that Jane's testimony was corroborated. I want to talk to you now about the many other ways that Jane's testimony is backed up by all of the other evidence in this case.

First, you heard from Juan Alessi, who remembered Jane. Here's his testimony about that. He remembered that she looked about 14 or 15, and that she spent time with Maxwell and Epstein at the house. Here's his testimony about that: Alessi remembered the school that Jane went to because he would be sent to pick her up there sometimes. He also remembered driving Jane to the airport with Maxwell and Epstein. Here's part of his testimony about that. You know that Jane traveled with Maxwell and Epstein because Jane told you that. But you also know it because Alessi told you about that. And you know it because the flight records show it too. So let's take a look at Government Exhibit 662. So in the flight records, you learned that the pilots didn't always see the passengers or learn their names; sometimes they just wrote one female or one passenger. Here's an example from January of 1995.

And, of course, you know that Maxwell and Epstein wouldn't have been eager to have a pilot log the name of the kid they were bringing on trips. They wouldn't be eager to introduce her to the pilots until she got older. But Jane is listed on several flights in these records. Here's the first one where her name appears. It's November 1996, when Jane was just 16 years old. Here she is on a flight from Palm Beach to Teterboro Airport. That's the airport they would use when they were flying to New York. What you're looking at is cold, hard proof that Jane was an underage girl being transported to New York. And while

MS. MOE: Maxwell isn't listed on the flight log for the flight there, you know she was there because you look -- if you look at the second entry right below that, she's on the flight log leaving New York the very next flight. That's how you know that Maxwell was in New York too. She's right there. Here's the next flight where Jane's name appears. It's May 1997. A flight from Teterboro to New Mexico. They were traveling from New York to New Mexico. On the day of this flight, Jane was still just 16 years old. The flight log here shows just Maxwell, Epstein, and Jane. And Jane told you about going on a trip alone to New Mexico with just Maxwell and Epstein. Why on earth were Maxwell and Epstein flying alone to New Mexico with a 16-year-old girl? They were doing it for the same reason they did that to Annie Farmer, ladies and gentlemen. That's the playbook. Let's take a look at just one more flight.

And remember, these aren't the only trips that Jane took; they are just the ones that happen to be captured in the flight logs when she flew on the jet. So here is Jane in April 1998 flying with Maxwell and Epstein from Palm Beach to Teterboro, a trip to New York when Jane was 17. And by the way, remember when defense counsel showed you pictures of an older woman with Jane's first name, who worked as a personal assistant, and they suggested to you that maybe that's the Jane on these flight logs? That's the photo they showed you. Ladies and gentlemen, that was completely misleading. The pilots told you that there were only ever two passengers with that first name, and they met the second person, the person in this photo, years later. And you heard testimony from someone from the DMV to show you that this adult woman in that picture was 11 old when these flights took off. She obviously wasn't working as a personal assistant when she was 11. It's not her. It's Jane on those flight logs.

You know the girl on those flights was Jane. In addition to all of that corroboration, you've also heard testimony from Matt, who dated Jane for several years in the mid 2000s. He told you that he had conversations with Jane more than a decade before this case. And what Jane told him back then is consistent with what she told you at this trial. She told Matt that she had a godfather named Jeffrey Epstein who paid for things when she was growing up. It started when she was 14, and she had to do things she didn't want to do. She told him it involved massage and that there was a woman who made her feel comfortable. Here are two portions of Matt's testimony: She said that it started at 14. There was a woman in the house who made her feel comfortable. You know that woman is Maxwell, because when Matt learned that Maxwell had been arrested in this case, he called Jane and asked her, Is that the woman you told me about all of those years ago? And Jane told him that it was.

Now, Jane didn't tell Matt all of the details; she just told him the money wasn't free. And Matt told you about how when Jane would talk about this, she was -- and I'm quoting from the transcript -- ashamed, embarrassed, horrified. Jane couldn't share all of the details with Matt; it took her a long time to be able to do that. You heard expert testimony at this trial from Dr. Rocchio who told you about just how common that is. Dr. Rocchio has spent literally decades treating real-world patients for trauma caused by sexual abuse. She's an expert. And she told you that it's actually uncommon for kids to disclose that they've been abused when it happens. Here's her testimony about that. In fact, as Dr. Rocchio told you, victims are less likely to tell, and they are more likely to delay telling the closer they are to the perpetrator. And you heard about how Maxwell was like a big sister to Jane; how Epstein was Jane's so-called godfather.

It was this close relationship that made it hard for Jane to talk about the abuse, especially given everything that you learned about what was going on at home for Jane and what her mother was like. Remember how Matt told you he was there when Jane confronted her mother years later? Here's his testimony about that. Jane told her mother that she -- that the money was not free, and that there was no way she couldn't have known that it wasn't free. At this trial, you heard expert testimony from Dr. Rocchio about how it's hard for victims of childhood sexual abuse to tell someone that they've been abused. And when they

MS. MOE: do tell, here's what Dr. Rocchio explained to you. She said, Disclosure is a process that unfolds over time. So individuals will typically begin the disclosure maybe by alluding to what's happened in a general sense or the gist of what's happened. Let me pause here and say that's exactly what happened with Matt. She's alluding to what happened, giving the gist of it, but not all the details. It's just too hard. Here's the rest of her testimony. And then it's only over time they will begin to talk more specifically about what has happened. And even in therapy, oftentimes disclosure of the most intimate or difficult details is something that's very hard and individuals are very reluctant to do. Dr. Rocchio has explained to you that's what happens in these cases, and she's an expert in the psychology of sexual trauma.

Now, the defense cross-examined Jane about why she didn't immediately tell someone about the abuse she suffered when she was 14 and 15 and 16, as if that would have been easy. And, in fact, when the defense points out that Jane wasn't able to tell people what really happened to her, they're actually pointing to what makes this a textbook case of child sexual abuse. How else do you know that Jane told you the truth? It's because her testimony is corroborated by the testimony of Annie and Carolyn and Kate, whose experiences were strikingly similar, as we've already discussed. It's not a coincidence. You can consider all of the witnesses' testimony as corroborating testimony as you consider what happened to each one of them. Let me just say one last thing about Jane. Defense counsel asked Jane in cross-examination whether she remembered some of the first names of people who were present for group sexualized encounters. She remembered five names: Emmy, Kelly, Sophie, Eva, and Michelle. And keep in mind, she was a kid, right; it's not like she's taking people's IDs in the room when she's being sexually assaulted, but that's what she can remember. The defense seized on two of those names, Eva and Michelle. Here's the transcript where they asked about this on cross.

MS. MOE: So in the defense case, they happened to find two people with the first names, Michelle and Ava, and they brought them down to court to try to discredit Jane. But here's the thing, Jane never testified that Michelle Healey and Eva Dubin were in the room when she was abused. She did not say that. Defense counsel asked her about a Michelle and an Eva. They expressly did not ask Jane if she knew those people's last names. They didn't show Jane pictures of Eva Dubin or Michelle Healey to see if those were the people she was referencing. They left it really vague on purpose. But trying to discredit Jane this way makes no sense. Your common sense tells you that those aren't the only Michelles and Evas in the whole wide world. And you can take a look at excerpts from Government Exhibit 52. That's the black contact book. Remember, there were pages from Epstein and Maxwell's contact book, and we're going to talk more about this book later.

But you're going to see this book had another Eva in it and three Michelles. Of course there were other Michelles and Evas out there and other people with those names in Epstein's life. Calling these women to testify was completely meaningless and it was a total sideshow. Don't be distracted by that. It was meaningless. Ladies and gentlemen, the evidence tells you that Jane told you the truth at this trial because you could see and hear her yourself. You met Jane. It was powerful testimony and it was difficult to hear, but you know from your direct observations that she was telling you the truth. You also know it was true because her testimony was extensively corroborated by Alessi, by Matt, and by documents like the flight records, school records, and camp records.

And you know it because you recognize the same playbook they ran with Jane when you compare it with what Epstein and Maxwell did with the other witnesses at this trial, and the lengths the defense went to, to try to discredit Jane, just tells you how devastating her testimony was. It proves Maxwell is guilty. Jane was a kid in middle school. She was sexually exploited by Ghislaine Maxwell and Jeffrey Epstein. If you believe Jane's testimony, the defendant is guilty on counts One through Four of the indictment. I want to talk to you now about Annie. The fourth reason that you know that Maxwell is guilty is Annie Farmer. Here's Annie. Annie told you about meeting Jeffrey Epstein in New York in December 1995. She was 16 years old. Epstein said that he was taking an interest in her as a student and he talked to Annie about college. Then Epstein took her to the movies with her sister, Maria. During that movie, he held Annie's hand and rubbed her arm.

He hid it from Maria, but he was rubbing Annie's arm during the movie. He was trying to desensitize Annie to his touch. Here's part of Annie's teenage diary entry about the trip to the movies. It tells you a few things. First, this diary tells you that this isn't a new story. It's right there in her teenage diary, her high school diary from 1986. And what you saw in Annie's diary was just how confusing this experience was for a teenage girl. This diary entry was a perfect illustration about how kids being groomed for sexual abuse wrestled with understanding that confusing experience. Annie wrote about how she went back and forth about how this was weird, and you can see her in her diary struggling to rationalize what is obviously inappropriate behavior, because this adult was being nice to her, he had made promises, he was important to her sister's career, and he held a position of trust. That's exactly how grooming works. I want you to notice one thing more about this diary.

You'll notice towards the bottom that Annie wrote down, the one thing that kind of weirded me out about it was that he let go of my hand when he was talking to Maria. Annie told you about how in the movie theater when Epstein was touching her, he had to hide it from Maria. I want you to remember that, because we're going to talk about it in a few minutes. Now, Maxwell wasn't there for the trip to New York, but you know that she was absolutely there for what happened next, as she and Epstein tried to escalate things with Annie. In the spring of 1996 when Annie was 16, she flew all by herself to New Mexico to stay with Maxwell and Epstein. She thought it had to do with a potential scholarship, and so did her mother, who took the witness stand and told you that she

MS. MOE: remembered Annie going on this trip with Maxwell and Epstein, and that she thought it was a trip for multiple scholarship students who would be chaperoned by Ghislaine Maxwell. But when Annie got to New Mexico, she was alone. She was alone with Epstein and Maxwell. She was alone with them, with no chaperone, no other students. She was alone with two sexual predators. Over the course of the weekend, Maxwell engaged in textbook grooming behavior with Annie. First, Maxwell starting chatting her up, asking her about her life. She was charming her. Then Maxwell took Annie on a shopping trip. They bought her boots and Maxwell picked out a hair product for Annie. What came next? Maxwell and Epstein took Annie to a movie theater where Epstein began holding Annie's hand and rubbing her foot and her arm. He was doing the same thing he had done in New York, but now he was doing it openly.

He was doing it openly because this time he was doing it with Maxwell, and he didn't have to hide it from Maxwell because she was in on the whole thing. So what did Annie tell you about next? Well, Maxwell started rationing things up to the next level. Here's her testimony about that. It was decided that I would learn how to give Epstein a foot massage. Maxwell wanted to show me how to rub his feet, and so that was something I should learn how to do. And so she sat and held one of his feet and instructed me to hold his other foot and showed me how to rub it. Maxwell started to teach Annie how to give Epstein a foot massage. Now, did Maxwell know that Epstein liked foot massages? Of course she did. You saw that photo of Maxwell massaging Epstein's feet with her breasts. Ladies and gentlemen, your common sense tells you, it is not normal for an adult woman to teach a 16-year-old girl to rub a middle-aged man's feet.

That is not part of some mentoring program, it's not part of a scholarship entry program. You know exactly what that was about, and when Maxwell did it, she knew exactly what she was doing, she was trying to get Annie to touch Epstein. They were confusing her boundaries. They were moving the line slowly and gradually for what would come next. This was classic grooming behavior. It's what Maxwell did to Jane and it's also, by the way, what Maxwell did to Kate. So let's take a moment to look at Kate's testimony about that. Kate told you that when Maxwell introduced her to Epstein, she said, why don't you give his feet a little squeeze to show him how strong you are. Why was Maxwell asking these teenage girls to touch Epstein's feet? It's obvious. She was trying to get these girls to touch Jeffrey Epstein. She was trying to normalize touch. She was doing it because she was a predator. For Annie, things didn't stop with foot massages. Maxwell pushed things further.

Annie told you about how Maxwell insisted on giving Annie a massage, and during that massage, Maxwell folded down the sheet, exposing Annie's breasts, and began touching her breasts. Ladies and gentlemen, there are a lot of things you can say about a woman in her 30s groping the breasts of a 16-year-old girl, but a therapeutic massage is not one of them. That's not on a list of spa treatments anywhere. What Maxwell was doing was the same thing that she did to other girls — she was introducing touch, she was normalizing sexualized massages, she was breaking down barriers, she was moving the line forward, slowly, but surely. And what happened next is exactly what Maxwell was trying to set up. Towards the end of the trip, Epstein came into Annie's room and got into her bed saying that he wanted to cuddle. A man in his 40s was in her bed. He wrapped his arms around her and pressed his body against her. Just imagine how terrifying that would be for a 16-year-old girl.

She's alone on a ranch in the middle of nowhere, and the adults in charge are the woman who groped her breasts and the man who's now in her bed trying to cuddle her. You learned that Annie got away. She got out of bed and she hid in her bathroom. What Maxwell and Epstein were trying to do, what they successfully did with other girls, it didn't work on Annie. And Annie told you that, after that, on the last day, Maxwell suddenly seemed very disinterested in her. Ladies and gentlemen, Maxwell lost interest in Annie because her scheme didn't work. When Annie wouldn't cuddle with Epstein, when they couldn't take things further, Maxwell dropped the act. She didn't have to pretend to be charming

MS. MOE: anymore because she didn't have any use for Annie anymore, and that was the end of the trip. After that, Annie never spoke to Maxwell or Epstein again. She went to her junior prom and then she spent the summer in Thailand on a trip that Epstein had paid for. And by the way, Annie and her high school boyfriend, David Mulligan, and Annie's mom all remember that Annie went to Thailand that summer. During the defense case, the defense called someone to testify about border patrol records, but don't let any spotty border records from the 1990s distract you for a minute. She obviously went to Thailand that summer. We're looking at a photograph of it right here. When Annie got home from Thailand, her mother had asked her what had happened in New Mexico, she wanted to know what had happened on that trip. Here's Janice Swain's testimony about that. She told you that Annie said, I don't want to talk about it, I'm just not going to let it ruin my life.

But not long after this happened, Annie told her high school boyfriend what Maxwell and Epstein had done. She told him about meeting Maxwell on the trip to New Mexico. You heard from David Mulligan at this trial. Here's his testimony about what Annie told him. She said that Maxwell was very charming, very pretty, she greeted her when she arrived, and I remember that they had a day around town where Maxwell took her shopping. He even remembered that Annie said that Maxwell had bought her cowboy boots. But most importantly, Annie told him that Maxwell had given her a massage and touched her breasts. Here's his testimony about that. He remembered what Annie told him, that Maxwell had touched her, that she had touched her breasts during the massage, and in 2006, Annie told the FBI the same thing. Here's her testimony about that. She told them about Maxwell in 2006 — 15 years ago. That's one of the many ways that you know that Annie is telling the truth.

She has been consistently describing since the 1990s what Maxwell did to her, and what Maxwell did to Annie is powerful evidence of her guilt. I want to talk to you now about what Maxwell and Epstein did to Carolyn. That's the fifth way that you know Maxwell is guilty. This is Carolyn when she was a teenage girl. Carolyn met Maxwell through a girl she knew named Virginia Roberts. So I'm going to start by talking to about Virginia Roberts. This is Government Exhibit 113 and 114. That's Virginia. This is the same girl that Juan Alessi remembered. He told you about how he was driving to Mar-a-Lago one day. He was driving Maxwell one day by Mar-a-Lago, and Maxwell saw this girl and told him to pull over. Maxwell got out of the car and went to go talk to that girl. Here's his testimony. She told me to stop — John, stop — and I stopped the car and she opened the door and she went towards this girl as she was coming down the ramp. She went to go talk to this girl.

And sure enough, he saw Virginia at the house later that day. When she arrived, Alessi brought her to see Maxwell. After that, he remembered that Virginia started coming to the house and spending time with Maxwell and Epstein. He told you about that. We'll talk more in a moment about Virginia, but I want to be very clear that the Virginia Roberts that Carolyn told you about is the very same Virginia Roberts that Juan Alessi told you about. It's the same girl that Maxwell pulled over to talk to. Now Carolyn testified that when she was about 14, Virginia told her about a way to make money giving a massage to a wealthy man. They went over to that man's house in Palm Beach and met Maxwell there. Here's her testimony about that. Virginia said this was her friend, Carolyn, and Maxwell responded, you can bring her upstairs and show her what to do. You know exactly what Maxwell meant, sexual contact was about to happen in the massage room, and that's exactly what happened next.

Virginia and Carolyn got undressed and started massaging Epstein in the massage room, and then Virginia and Epstein started having sex in front of Carolyn in the massage room. Carolyn sat on the couch in the massage room while it happened. This is the massage room. That's the couch on the left. On the walls on the left, there were nude drawings. Ladies and gentlemen, this was not a place for a therapeutic massages, it is a place where Maxwell and Epstein's victims were sexually abused. You take a look at the drawings on the left, here is a zoom-in from the search video, there are the drawings. And

MS. MOE: while we're talking about this space where things happened, I want to pause here and show you the entrance to the master bedroom in the Palm Beach house close by the massage room. You're going to notice a large photo of a young girl pulling her underwear down, and when you see that, you'll understand what Maxwell understood, that Maxwell understood what was happening in that house. The first visit for Carolyn to this house was the beginning of years of sexual abuse. Carolyn told you about how Maxwell would call her to set up appointment times for these so-called massages, and sometimes Sarah Kellen would call, too. Here's her testimony about that. She told you that Maxwell would call and set up appointment times. She said for the first year or two, Maxwell would call, and then Sarah would call after that point. And you know that's true because Carolyn said that twice when she gave deposition testimony under oath in 2009. Here's the first one.

This is Carolyn's deposition testimony from 2009. "Q. In fact, Mr. Epstein himself did not contact you on each occasion and request you to come, did he? "A. No. He would have Sarah or Maxwell call me." Here's the second one. "Q. And on these occasions that you called to see if you could go over there and give him a massage, did you talk to him or did you talk to others at his house? "A. I talked to Sarah or Maxwell. I've also talked to -- I don't know if it's a cook or someone else that was there that took phone messages." She said it twice. In 2009, Carolyn testified under oath that Maxwell called her to schedule sexualized massages. And you know all of this is true because you have heard testimony from Sean, Carolyn's boyfriend at the time, who told you that Carolyn started making money by going over to Jeffrey Epstein's house. He remembered that happening a couple weeks after he met Virginia Roberts in 2001 when Carolyn was just 14 years old.

He also remembered that Carolyn told him that she interacted with Maxwell inside of Epstein's house. Here's his testimony about that. Sean even remembered how Carolyn couldn't pronounce Maxwell's first name. When Carolyn went to that house, she had conversations with Maxwell. Maxwell asked her if she'd ever used sex toys, and she said no. Maxwell asked her about her plans for the future. They talked about personal things in Carolyn's life. Carolyn told Maxwell about her upbringing and her home life, that her mother was an alcoholic and that Karen had been molested by her grandfather when she was younger. Maxwell also talked to Carolyn about travel. Maxwell invited her to travel with them, and Carolyn told her that she couldn't, that she was too young, she didn't have a passport, and her mother wouldn't let her go.

It should come as no surprise to you, ladies and gentlemen, that Maxwell asked this young girl to travel with them, because that's what Maxwell and Epstein had been doing for years at this point — trips with Jane when she was 14, 15, 16; spending a weekend in New Mexico with Annie when she was 16. And we're about to talk in a few minutes about just how many flight records there are that show that Virginia Roberts flew with Maxwell and Epstein when she was 17 years old. This was Maxwell's playbook for years, and she tried to get Carolyn to travel, too. What happened to Carolyn in the years that she was abused in that house in Palm Beach is hard to talk about. You remember her testimony. She told you about being paid to give sexualized massages to Epstein, how he touched her breasts, put a vibrator on her vagina, and how every massage ended with Epstein ejaculating. Ladies and gentlemen, that's what happened to Jane, too.

It's one of the many ways that you know that Carolyn is telling the truth. Now, remember when Carolyn told you that Epstein sent her packages, that he sent her lingerie? You know that's true because you saw FedEx records that proved that Epstein sent her packages. This is Government Exhibit 803. It's a record of a package sent to Carolyn in October of 2002, when she was 15. It's a package from New York from Epstein's office, and it wasn't the only package. Here's another, Government Exhibit 801. Again, Carolyn was 15. And here's another, Government Exhibit 802. Again, Carolyn was 15. Carolyn told you that she got packages from Epstein from New York, and she did. You can see that here in black and white. That's Government Exhibits 801, 802, and 803. Who else was sending packages from Epstein's office

MS. MOE: from this very same time period? Maxwell. She used the same account to send packages. You see Maxwell's name on each of these FedEx account invoices. Maxwell was a part of the operation just like Carolyn told you. You also learned about phone messages that Carolyn left in the Palm Beach house on those message pads. Those phone messages corroborate Carolyn's testimony. They prove to you that she was there. So let's talk about two of them. First, this is Government Exhibit 608. Carolyn testified that this was her mother's phone number. She wrote it down so she wouldn't have to say it out loud at trial, and we marked it as an exhibit. That same phone number is all over the message pads from the Palm Beach house, phone message after message. This is Government Exhibit 1-B. It's the same phone number, and that's Carolyn's full name, first and last. It's from 2004. And remember, we were just looking at FedEx records from 2002. What's the message here?

That she wants to work for Epstein today. What you were looking at is a phone message from an underage girl who needs money and is being exploited. This is Government Exhibit 3-E. It's the same phone number and that's Carolyn's full name. What's the message? It's that Kim wants to work. Just like Carolyn told you, she brought other friends to the house to give massages. Ladies and gentlemen, Carolyn's testimony was extensively corroborated in this case. Her name is on FedEx records and phone messages. She has been on the record since 2009 about Maxwell calling her for appointments. And her exboyfriend, Sean, confirmed that Carolyn went to that house to make money for years and that she interacted with Maxwell at that house. You know that Carolyn told you the truth. That's what the evidence tells you. Her testimony was backed up by the other evidence in this case and it was corroborated by what Annie and Kate and Jane told you about Maxwell and how she operated for years.

What Carolyn told you is powerful evidence that Maxwell was conspiring with Epstein to abuse underage girls. Maxwell sent a teenage girl into a massage room with an adult man. She knew exactly what she was doing. If you believe Carolyn's testimony, the defendant is guilty on counts One, Three, Five, and Six. And I'll talk about those counts later on. That brings us to reason six. The sixth way that you know Maxwell is guilty is because Maxwell and Epstein kept a little black book with their victims' names in it. It is a powerfully incriminating document. So I want to start by going back to the household manual. And what the manual shows you is that Maxwell and Epstein had a phone directory, and they kept several copies of it in the house. There was a copy in the pool area, there was a copy in their cars, there was a copy of it in the master bedroom, and most importantly, there was a copy right on Maxwell's desk. Here's the part of the manual that tells you that.

There was a copy on her desk. And they're not just any directories. In the manual, they're the JE and GM telephone directories. Jeffrey Epstein and Ghislaine Maxwell. When Juan Alessi testified, he was asked about a little black book and he testified that he recognized it as one of those books. So let's take a look at Government Exhibit 52-G, which is a page from that book. Here it is. So the section on this page is titled "Massage Florida." I'm going to highlight a few specific entries in a moment, but first let's just start with the basics. You'll notice just how many names there are. Who needs that many masseuses? That's the first sign that something is off here. And a second thing that you're going to notice is that all of the names here are female. The third thing that you're going to notice is that there are notes next to some of the names, things like mom, dad, or parents. Use your common sense, ladies and gentlemen.

When you contact a professional masseuse, you don't need to call her mom or dad. Just looking at this page tells you that none of this was legitimate. These were millionaires who could hire the top massage therapists in the whole world, but Maxwell had a book with dozens of entries in a massage section that makes absolutely clear that these were not real massages by professional masseuses. In fact, this book makes clear that some of the entries were for kids. So let's talk about one of those entries. The entry here on the left is Virginia, parents. I want you to take a look at the phone number, ladies and gentlemen. You've seen it

MS. MOE: somewhere else at this trial, and here it is. This is Government Exhibit 823. It's the employment record for Sky Roberts. You saw Virginia Roberts' birth certificate, so you know that Sky Roberts is Virginia's dad. He was an employee at Mar-a-Lago, which, as Juan Alessi testified, is the place where Maxwell met Virginia Roberts. Take a look at the phone number listed for Sky Roberts on this document. It's the same number on Government Exhibit 52-G, the contact book. And Virginia is also, by the way, on flight records with Maxwell when she was 17 years old. Let's take a look, and as we do, you're going to see the initials "G.M." for Ghislaine Maxwell on every single one. Here's the first one. Two flights, JE, GM, ET, Virginia. JE, GM, AT, Virginia. It's from 2000. She was 17 years old. Here's another page. JE, GM, ET, Virginia Roberts. Here's another, JE, GM, ET, Virginia Roberts. There is another one, JE, GM, ET, Virginia Roberts. This is 2001 when Virginia Roberts was 17.

They were flying around with a 17-year-old girl. But back to the black book, there is more to talk about. Remember Sean, Carolyn's boyfriend? There is an entry for him, too, under an entry for Carolyn, Carolyn's boyfriend's house. That entry has Carolyn's first and last name. That same phone number that you're looking at here is on three messages from the message pads, and here they are. It's Government Exhibits 2-U, 2-P, and 2-O. And if you take a look at the date on the two messages on the left, they're from 2003 when Carolyn was 16. There's the phone number. It's the same. In fact, the message in the middle is from just a month past Carolyn's 16th birthday. There is more. There is an entry in here for Carolyn with her full name. That number is on phone messages from 2003, too. Here they are. One says Carolyn, two say Caroline, but you know it's the same person, you know it's Carolyn because the phone number is the same. Who else is in this book?

Remember how Sean told you that he would bring a 16-year-old girl named Melissa to the house with Carolyn? It's this girl in the photograph with Carolyn. She's the one right next to Carolyn. That's Melissa's birth certificate. Sean told you this is the girl. And sure enough, there are two entries under massage for Melissa, Carolyn's friend. Here they are. Again, remember how you learned that, by this point, things operated like a pyramid scheme. Virginia brought Carolyn, Carolyn brought Melissa and other girls. One girl would bring another, who would bring another. Ladies and gentlemen, this book, Maxwell's book, it proves to you that Maxwell is guilty. What you'll see in this book corroborates the witnesses who testified at this trial. She had victim names written in a little black book. This document is powerful evidence of the defendant's knowledge and intent. These were not real massages. What was happening was sexual abuse with underage girls.

Maxwell knew it, she was part of it, she was responsible for it, and the fact that she had a little black book with her victims' names in it proves to you that she is guilty. That brings us to the seventh reason that you know Maxwell is guilty. It's the money. Now, we've already talked about Epstein's luxurious lifestyle and all of the perks that Maxwell got from being his partner in crime, but it wasn't just getting to live in the mansions and flying on the private jets, maxwell got millions of dollars from Epstein. You learned that between 1999 and 2007, Jeffrey Epstein gave Maxwell about $30 million, and you know exactly what that money was for. First, in 1999, Epstein sent Maxwell $18.3 million. $18.3 million — here's the transaction. And then, in 2002, Epstein paid Maxwell $5 million — here's the transaction. And last but not least, in 2007, Epstein paid Maxwell $7.4 million. $18.3 million, $5 million, $7.4 million. It's a total of $30.7 million.

At this point, you got to ask yourselves, what was Maxwell doing for Epstein that was worth more than $30 million? Your common sense tells you that you don't give someone $30 million unless they're giving you exactly what you want, and what Epstein wanted was to touch underage girls. When Maxwell took that money, she knew what it was for and now you do, too. It was payment for committing terrible crimes with Jeffrey Epstein. That brings us to reason number 8 that you know that Maxwell is guilty. When you zoom out and look at the big picture, the timeline over the years, it's obvious that Maxwell

MS. MOE: spent a decade aiding and abetting Jeffrey Epstein's crimes, that they were coconspirators, partners crime. Let's talk about the timeline the big picture. In 1994, Maxwell met Jane. In that same year, Maxwell and Epstein started sexually abusing Jane, and that often happened in the context of massages. That same year, in 1994, Maxwell met Kate, too, and Epstein initiated sexual contact with Kate also in the context of massages, massages in which Maxwell delivered Kate to Epstein. In 1995 and 1996, Maxwell was still in contact with Kate, encouraging Kate to travel to see her and Epstein, and in that same period, Maxwell was traveling with Jane, still exploiting Jane, in Palm Beach, in New York, and in New Mexico. And in the spring of 1996, Annie Farmer went to New Mexico where Maxwell groomed her for sexual abuse, where Maxwell massaged Annie's breasts. In 1999, Epstein sent Maxwell $18.3 million, and the abuse continued. Maxwell recruited Virginia Roberts at Mar-a-Lago.

In 2000, Virginia Roberts was 17 years old and flying with Maxwell and Epstein on Epstein's private jet. And in 2001, Virginia Roberts was still 17 and still flying on the jet with Maxwell and Epstein. They were flying around with a teenage girl. In 2001, Virginia brought Carolyn to the Palm Beach house. Carolyn was 14 years old. That's when Carolyn met Maxwell and Epstein, and that was the beginning of the pyramid scheme of abuse, the scheme that no longer required Maxwell to personally find young girls for Epstein, girls like Carolyn incentivized by extra cash were now bringing their friends, girls who needed money. And one year later in 2002, Epstein paid Maxwell $5 million. In 2002, 2003, and 2004, Carolyn was sexually abused in Epstein's Palm Beach massage room. Maxwell called to schedule some of the appointments. Carolyn was 15, 16, and 17 years old.

Remember how the defense tried to suggest to you that because Maxwell had started dating some other guy named Ted Waitt around 2004, she was no longer around Epstein. You know that's not true and here's why. You saw that household manual, Government Exhibit 606, that was dated in February of 2005, the manual that outlined what Epstein and Maxwell demanded in the Palm Beach house. She was still the lady of the house. And in 2005, the Palm Beach Police Department searched Epstein's house. And what did the police notice during their search? They found a desk with Ghislaine Maxwell's stationery on top. And in 2007, two years later, Epstein paid Maxwell $7.4 million. When you take a step back and you look at this timeline and think about the big picture, it is crystal clear that Maxwell knew about and was deeply involved in Epstein's sexual abuse of children. Take a moment and just reflect on how deeply strange this whole situation was.

For years, Maxwell took trips on Epstein's private planes with Epstein and teenage girls. For years, Maxwell was right by Epstein's side as numerous teenage girls came to visit him inside his homes. There were teenage boys, by the way. For years, Maxwell watched a parade of these girls come to massage him. For years, she kept a list in her little black book with dozens of female names, definitely no boys. For years, Maxwell lived in houses with Epstein that were decorated with nude females, including sexualized pictures of girls. For years, Maxwell slept in a bedroom in Palm Beach that had two bathrooms attached to it, one filled with nude drawings and stocked with a massage table and all the different types of massage oils and lotions that Epstein liked, and the other, Maxwell's bathroom where the dildo was stored. And over those years, Epstein paid Maxwell millions and millions of dollars. Ladies and gentlemen, look at the big picture and use your common sense.

She knew, she was complicit, she is guilty. Ladies and gentlemen, that's eight reasons why you know the defendant is guilty. Let's turn and talk about the charges against the defendant. Here are the six counts. I'm going to talk through them briefly, but I want you to keep in mind that Judge Nathan will give you detailed instructions about the law, and you should listen closely when she does. What Judge Nathan says about the law controls here. First, I want to talk to you about something called aiding and abetting. For counts Two, Four, and Six, which we're going to discuss in just a moment, Maxwell is guilty if she committed those crimes herself, but you can also find her

MS. MOE: guilty under an aiding and abetting theory. In other words, if you find that Epstein committed these crimes and that Maxwell assisted him, she is just as guilty as if she had committed those acts herself. And we talked about the overwhelming evidence that Maxwell aided and abetted these crimes. She was an essential accomplice, complicit in an extensive scheme to abuse young girls. So let's talk first about Count Two, which is enticement to engage in an illegal sexual activity. This count is about Jane and how Maxwell and Epstein enticed her to travel in interstate commerce, in other words, to go across state lines to New York to be abused. The first element of that crime is that the defendant knowingly persuaded, or induced, or enticed, or coerced Jane to travel in interstate commerce. In other words, did the defendant in some way cause Jane to travel across state lines. You know that Maxwell induced Jane to travel because Jane told you about traveling with Maxwell to New York.

Jane flew on commercial flights and also on the private jets. She told you about how Maxwell assisted with her travel arrangements, and Juan Alessi confirmed this, because he remembered driving Jane with Maxwell, Epstein, and Jane right up to the plane. He watched them board together. Ladies and gentlemen, Jane didn't end up in New York by accident, it was a direct result of Maxwell's actions, aiding and abetting Epstein as part of an ongoing pattern of abuse. You also know that Maxwell enticed Jane to New York because Jane told you about the pattern of her relationship with Maxwell and Epstein. She told you that Epstein gave her money and gifts and paid for school. That money wasn't free, and part of the cause was getting Jane on the plane with them to go to New York where she was sexually abused. That is inducement, that is enticement, that is coercion. The second element is that Jane traveled in interstate commerce.

We've already discussed how you know that Jane traveled from New York from out of state. You know that from Jane's testimony, from Juan Alessi's testimony, and from the flight records. The third element is that the defendant intended that Jane would engage in sexual activity for which any person can be charged with a criminal offense under New York law, and you're going to learn that it's a crime to engage in sexual contact with a kid under 17 who is too young to consent. And the evidence shows you that Maxwell absolutely intended that Jane would be abused in New York. That was the whole point of bringing her there, so that Epstein could have access to Jane. They weren't traveling for mentorship or scholarships, they weren't traveling with an underage girl because they were friends, they were getting her to travel so that she could be molested and that's exactly what happened. The evidence shows you that the defendant is guilty on Count Two.

Now let's talk about Count Four, it's transportation of an individual under age 17 to engage in illegal sexual activity. And again, this count is about Jane. The first element is that the defendant knowingly transported Jane in interstate commerce. Here we're talking about the travel itself. The last count we looked at was about enticement to travel, this one is about the travel itself. We've already talked about how Jane was transported to New York, and for this count, all that's required is that the defendant was actively engaged, either personally or through an agent, in making travel arrangements, or that she aided and abetted Epstein.

MS. MOE: Thank you, your Honor. Maxwell did not need to physically transport Jane herself or even be present for transportation, but again, Jane told you that Maxwell helped with her travel arrangements and that Maxwell was on flights with Jane. Juan Alessi confirmed that. The flight records confirm that. The second element here is that the defendant transported Jane with the intent that Jane would engage in sexual activity for which any person can be charged with a criminal offense under New York law. We've already talked about this one and how the evidence conclusively proves that Maxwell intended for Jane to be sexually abused on these trips. I want to emphasize here that there is no requirement that abuse in New York actually happened or that the defendant was the one who committed the abuse. The crime is transporting Jane with the intent that she will be abused.

Ladies and gentlemen, when Maxwell was helping arrange travel for Jane, when she got on that plane with Jane, Maxwell knew exactly what she was doing, and she knew exactly what Epstein was going to do to Jane. The crime happened the moment they crossed state lines. And to be very clear, when Epstein flew Jane to New York and Maxwell aided and abetted him, that's enough, too. The last element is that the defendant knew Jane was less than 17 years old. And you know that the defendant knew that Jane was under 17, ladies and gentlemen, she met her at a summer camp for kids. She was too young to drive. Maxwell knew this girl for years, when she was 14 and 15 and 16. She would talk to Jane where they would spend time together. Maxwell absolutely knew that she was under 17. And through all these elements, when we're talking about the defendant's knowledge and intent, I want you to think about Kate.

She told you about how the defendant asked her to deliver tea to Epstein wearing a schoolgirl outfit. That is striking evidence that Maxwell knew Jeffrey Epstein had a sexual preference for schoolgirls. And after Kate delivered tea in that schoolgirl outfit and Epstein initiated sexual contact with Kate, later that day, Maxwell asked Kate if she had fun. Maxwell told Kate that she was a good girl. Kate also told you about how Maxwell complained about Epstein's need to have sex three times a day, how Maxwell was constantly looking for someone to give him blowjobs. That makes it crystal clear exactly what Maxwell intended when she was taking Jane on these trips. Jane was there to satisfy Epstein's constant need for sexual gratification. The evidence proves to you that Maxwell is guilty on Count Four. Now let's talk about Count Six, it's sex trafficking an individual under age 18. This count is about Carolyn.

The first element is that the defendant knowingly recruited, enticed, harbored, transported, provided, or obtained Carolyn. You heard about how the defendant called Carolyn for massage appointments with Epstein. She was recruiting, enticing, providing, and obtaining Carolyn every single time she did that. The second element is that the defendant knew that Carolyn was under age 18. Ladies and gentlemen, Carolyn was a 14-year-old girl. She came to the house over and over again and interacted with Maxwell. She talked about her home life, she told Maxwell she was too young to travel, that her mother wouldn't let her go on trips. She was a girl who had just dropped out of middle school. There just can't be any question that Maxwell knew Carolyn was underage. And we're talking about the counts one by one, but I want to step back and ask you to keep in mind, you don't have to set aside all of the evidence you heard in this case when you examine each count, it's the opposite.

The pattern throughout the case tells you that the defendant knew these girls were under age and she knew that they were going to be molested. You should consider all of that evidence as you examine each count. The third element of Count Six is that the defendant knew Carolyn would be caused to engage in a commercial sex act. And here, a commercial sex act just means a sex act in exchange for money. That's what happened to Carolyn. She was paid hundreds of dollars every time that she was abused. Sometimes Maxwell handed over the cash herself. And we've been talking all morning about the overwhelming evidence that Maxwell knew these girls would be sexually abused in those so-called massages. She absolutely knew. Finally, there is a fourth element here. In

MS. MOE: interstate commerce here means something a little different than the first two counts we talked about. We're not talking about travel across state lines. Instead, we're talking about an effect on interstate commerce. So when Carolyn got packages from New York, when she was abused on a massage table that was manufactured in California, that proves that there was at least a minimal effect on interstate commerce, which is all that's required for this count. Finally, there are three conspiracy counts that charge Maxwell with conspiring with Epstein to commit the three crimes that we just talked about. I expect Judge Nathan will instruct you that a conspiracy just means an agreement to break the law. The crime is the agreement and taking some step to carry it out. So the question for you here is, did Maxwell agree with Epstein to commit these crimes. The conspiracy counts are counts One, Three, and Five. The first two conspiracy counts are from 1994 to 2004.

Those counts are about Jane, Carolyn, and Annie. Those counts charge a conspiracy related to enticement and travel, as we've just discussed. We've already talked about how Maxwell and Epstein completed these crimes as to Jane. For the conspiracy charges, even though Carolyn and Annie were not sexually abused in New York, everything about the defendant's and Epstein's interactions with those girls makes it clear that that is what they both intended. Maxwell groomed both Annie and Carolyn as part of a broader agreement with Epstein to provide him with underage girls for abuse. You heard about all of the steps the defendant took in those years in furtherance of that conspiracy, how Maxwell traveled with Jane and groomed Annie for abuse after she had already visited Epstein in New York, how the defendant asked Carolyn to travel, too. This went on for years. Count Five is the sex trafficking conspiracy count which spans from 2000 to 2004, and this count relates to Carolyn and Virginia.

You heard about the steps the defendant took in those years with Carolyn and Virginia. She was taking steps to traffic girls for sex, recruiting Virginia Roberts at Mar-a-Lago, transporting Virginia to other states with Epstein, sending Carolyn up to the Palm Beach massage room on her first visit, calling Carolyn for massage appointments in Florida so that she could engage in commercial sex acts. The defendant took so many steps in furtherance of the conspiracies charged in the indictment, the evidence about that was overwhelming, it went on for years. But let me say this, because it's very important. For each of the conspiracy counts, to find the defendant guilty, you only have to find that she did it once, that there existed one moment in time in all of those years where she agreed to do this, and that Maxwell or Epstein took some step to carry out the agreement. That's it. If you find that one moment happened, the defendant is guilty. Let me say one last thing about the law.

For each of the counts, I expect Judge Nathan will instruct you about something called venue. We're required to prove that it's more likely than not that just one act in furtherance of the crimes took place here in the Southern District of New York. There just cannot be any question about that. For the first four counts, you heard about Jane's trips to Manhattan, which is in the Southern District of New York. For counts One and Three, you also heard about Annie's trip to Manhattan. And for counts Five and Six, you saw the packages sent from Manhattan, you heard about Maxwell calling Carolyn to schedule sexualized massages when Maxwell was in New York.

MS. MOE: That's more than enough for venue on each count. So that's all that I'm going to say about the law. We've proved to you that the defendant has committed all six crimes charged in the indictment. I want to switch gears and talk to you about one last topic. I want to talk to you about the arguments the defense has made to you at this trial. Now, before I get into this, let me be clear that Maxwell has no burden to put on a defense or to put on any witnesses or evidence on her behalf. The government has the burden of proof beyond a reasonable doubt. We embrace that burden and we've carried it. But in this case, Maxwell chose to cross-examine witnesses, to make arguments, and to call witnesses. You can -- and should -- scrutinize that carefully. In her opening statement, defense counsel said something to you about Maxwell being blamed for something a man did. Let me be very clear. The evidence at this trial showed you that Ghislaine Maxwell made her own choices.

She committed crimes hand-in-hand with Jeffrey Epstein. She was a grown woman who knew exactly what she was doing. And now she's sitting here in this courtroom being held accountable for breaking the law. That's what this trial is about. That's what the evidence tells you. And at the beginning of this trial, defense counsel said to you that this case was about manipulation, money, and memory. And you know what? Defense counsel was exactly right, but not in the way she meant. Not at all. This case was absolutely about manipulation. You learned about how Maxwell manipulated young girls, making them believe that she was their friend, making them feel special, all so they could be molested by a middle-aged man. And you heard from Dr. Rocchio, an expert psychologist, and you learned about how perpetrators manipulate their victims in a process called grooming. The evidence in this case overwhelmingly shows you that that's exactly what Maxwell did to these girls.

And make no mistake, this trial was absolutely about money. The evidence showed you that Maxwell and Epstein were a wealthy couple who used their privilege to prey on kids from struggling families. Let me stop and say this: I want you to think about the few $100 that Carolyn got every time that she was sexually abused. And I want you to think about the $30 million that Ghislaine Maxwell got from Jeffrey Epstein. This case is about the way that Ghislaine Maxwell and Jeffrey Epstein exploited kids from struggling families. So when defense counsel talks to you about money, just think about that. This trial was also about memory. When the witnesses took that witness stand, they told you about searing memories of childhood sexual abuse, traumatic memories that they've carried with them for years. That is what the evidence at this trial showed you. Next, the defense has tried to argue to you that Maxwell, that maybe she was just too busy to commit these crimes. So let's talk about that.

The employees you heard from at this trial told you that Maxwell had all kinds of people who worked for her. She had personal assistants who she interviewed in the back of a limo, a woman to walk her dog. But despite all of this, the defense tried to argue that maybe Maxwell was so busy managing all of the details of Epstein's life, that maybe she wasn't involved in these crimes; that maybe she was so busy ordering sand to be delivered to Epstein's private island, that she just didn't know what was going on right in front of her. That's the argument. The argument that Maxwell did not know what was going on is flatly contradicted by the evidence in this case. Maxwell participated in the abuse; of course she knew what was happening. And in the moments where she wasn't in the room, she absolutely knew what was going on.

The argument that Maxwell didn't know what was happening in the houses that she managed and lived in with the man she was sleeping with, what was going on with young girls she met in person and interacted with frequently, that argument is absolutely absurd and you should reject it completely. So next, the defense has repeatedly attacked Jane, Annie, Carolyn, and Kate, claiming that they are liars or that their memories are faulty or maybe it's both. They argued both to you during this trial. They are doing that because the testimony of the witnesses in this case is devastating evidence of Maxwell's guilt; because if you believe them, Maxwell is guilty. You are the finders of the fact. You're the judges of

MS. MOE: the truth. And your common sense tells you that only one of three things can be true about Kate, Jane, Annie, and Carolyn: Either they are all misremembering the same thing, or they're outright lying, or they're telling the truth. So I want to talk through those one-by-one. First, the defense has suggested to you that perhaps Jane and Kate and Annie and Carolyn are all talking about fake memories. But that's what they testified about, that they are getting it wrong; that their memories are faulty. Four women have testified at this trial about Maxwell. They all describe the same woman, the same playbook. They didn't imagine what happened to them. Your common sense tells you that just cannot be true. They are not all somehow suffering from the same mass delusion. And while time has passed, they told you very clearly that they remember being exploited by Maxwell and Epstein. Your common sense tells you that being molested is not something that you forget ever.

You remember an adult woman groping your breasts. You remember a middle-aged man touching your vagina. You remember feeling scared and frozen and trapped and confused. Your common sense tells you these women know what happened to them in their own lives. They know it. These are powerful memories of trauma, and they've carried these haunting memories with them for years. But when the defense talks about memory, they want to talk about experiments, experiments that Professor Loftus performed in a lab, experiments like the one where she tried to convince people that they saw Bugs Bunny at Disneyland; experiments where she told people that a stop sign was a yield sign. Don't be distracted by that. Loftus has made a career of being a witness for the defense. And she said in her book by that name, she doesn't even pretend to be an impartial expert. She admits she is an advocate for the defense.

And over the years, as she has admitted, she has been paid by criminal defendants to testify on their behalf. She's made a name for herself as a witness for the defense in high-profile trials. And most importantly, this case isn't about Bugs Bunny, it isn't about stop signs; it's about sexual abuse, repeated sexual abuse of teenage girls. Loftus told you, never done a study about that. So all of that testimony she gave about implanted memories or corrupted memories, it was totally irrelevant to the facts of this case. And that's because those experiments are nothing like what happened here. And Loftus was basically forced to admit that on cross-examination. Remember that study she described about telling people that they were lost in a mall? Remember that she only was able to trick 25 percent of the participants about that? But, more importantly, another researcher then did a follow-up study, and that researcher tried to implant two false memories.

She tried to implant the lost-in-the-mall story, and also a story about an unpleasant bodily intrusion, a rectal enema. Now, some people were tricked about getting lost in the mall, but no one had a false memory about getting a rectal enema. Why is that? Your common sense tells you that kind of experience is the sort of thing you can't trick someone into believing. You cannot suggest that. You can't make it up. A rectal enema is the kind of thing you'd only remember if it really happened, kind of like sexual abuse. And again, Loftus basically had to admit this on cross-examination. She said the core memory of trauma is stronger than other types of memory. She admitted that. People might forget some of the peripheral details, but the core of the traumatic event, those memories are much stronger. You don't need a paid expert to tell you that, ladies and gentlemen. It's just common sense. You remember something like this. Her testimony was a total distraction.

You saw the witnesses yourself. They were not talking about one time that they saw a fake car crash. They were telling you about how they were sexually abused again and again and again. You heard them tell you about their worst memories, and that's why this is a case about memory. As jurors, you understand how memory works from your own lives, and that's how you know it just doesn't make any sense to say that Jane and Annie and Carolyn and Kate all imagined this, or that they're experiencing some kind of false memory of something that never happened. Again and again at this trial you saw the lengths the defense went to in order to

MS. MOE: try to discredit the witnesses, because their testimony was devastating evidence of Maxwell's guilt. I want to talk about that for just a moment. Let's talk about just two examples. Remember that in a cross-examination of Jane, when the defense repeatedly tried to suggest that Jane had said on her application to Interlochen that nothing was difficult for her? This is Defense Exhibit J-3. This went on for question after question, as the defense tried to suggest that Jane was lying about her difficult home life. Here it is. The defense pointed her to the Interlochen application twice to suggest this. Here's part of the transcript where that happened. You wrote that. When asked about something difficult, nothing has been difficult for me; correct? I guess I did. But then you saw the actual application, the whole thing. What was that question really about? List two difficult works performed in orchestra, band, or an ensemble within the past year.

And Jane answered: Nothing has been difficult for me. So what does that mean? The defense spent a long time trying to discredit Jane with a line that was really about orchestra music. Even Jane didn't realize she was being misled this way until she was shown the question itself on redirect. Here's another example: Remember how Jane was asked about a legal document called an interrogatory? She told you that she'd never seen this document before and she had no idea what it was. And the defense suggested to you that this legal document means that Jane said nobody else besides Epstein had been involved in her abuse. There's this long question here. But guess what: Here's the portion that the defendant didn't show you and didn't read to you. It says, Maxwell facilitated the sexual abuse of Jane and was frequently present when the sexual abuse of Jane occurred. It's right there in that same document.

They didn't read that part to you; instead, they plucked parts out of context to create a misimpression. Finally, I also expect the defense will make arguments to you about property records in London. Those all came in by stipulation on Friday. They'll say that Maxwell didn't live at 44 Kinnerton Street in 1994, when Kate met her; and that she lived -- that Maxwell lived in another house nearby in London. But that's just another distraction and here's why: Maxwell herself testified under oath in a 2019 deposition, here it is, that she had lived at 44 Kinnerton Street since 1992 or 1993. So either the defendant lived there the whole time or she mixed up her two London houses and Kate did too. Either way, it just doesn't matter. So next, the defense has argued to you that Jane and Kate and Carolyn and Annie are all lying. The defense has asked you to believe that Jane and Kate and Annie and Carolyn, that they are all lying for money.

But none of that makes any sense when you look at it closely. It doesn't make any sense when you look at the evidence. Now, all four women have testified that they submitted claims to the Jeffrey Epstein Victim Compensation Program. They were awarded millions of dollars. And that happened well before this trial. Their civil lawsuits are over. Those cases are done and the witnesses don't get anything out of testifying at this trial. They were clear in their testimony. They have no financial stake in the outcome of this trial. None. And one of the other ways you know the witnesses aren't making this up is that multiple other witnesses backed up what they told you. Think about all of the other witnesses in this case. Juan Alessi, David Mulligan, Janice Swain, and the witnesses called Matt and Shawn. Think about all the ways their testimony was backed up by documents, all of the other evidence in the case.

Your common sense tells you the witnesses are not lying and they just cannot be all misremembering the same thing. That just leaves one conclusion: That Maxwell is guilty and you should convict her. Let me take a step back and say this: Ladies and gentlemen, look at the evidence together, all of the evidence, and use your common sense. The evidence points to only one conclusion: That Ghislaine Maxwell sexually exploited young girls. She trafficked underage girls for sex. When you consider all of the evidence and use your common sense, you will reach the only verdict consistent with the evidence: Maxwell is guilty.