HOUSE_OVERSIGHT_011439

id.

ne)

life)

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