his right-hand player then is Ms. Maxwell, and in the

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 136 H3vlgiu2 his right-hand player then is Ms. Maxwell, and in the conspiracy, again, in our view we understand the defense will take a differing point of view on this, but in our view, the conspiracy's next echelon is Kellen and Marcinkova. And so for example, Ms. Giuffre has made allegations about certain things. Ms. Maxwell can't remember or denies them, so of course Ms. Giuffre then looks to corroborate her allegations of a conspiracy, and the first person she goes to is Epstein, and you're familiar with that. The second and third people that she goes to are Kellen and Marcinkova, because they report immediately to Ms. Maxwell in the conspiracy. And Ms. Giuffre is going to be talking about that during the course of the trial, and immediately the jury is going to wonder, well, gosh, I wonder what Kellen says about that? I wonder what Marcinkova says about that? And your Honor will recall that we went to great lengths to get them to testify. They were evading service, in our view. We ultimately had to come to your Honor to get alternative service, and it was only at that point that we were able to have them sit for their depositions. They sat for their depositions now, and what we hear from the defense, if I understand it, is that we don't have a good-faith basis for asking Kellen and Marcinkova, gee, weren't you a part of this sex trafficking and sex abuse conspiracy? I think the way they put it in their brief is, all of this evidence shows nothing SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011439