136 H3vlgiu2 ih his right-hand player then is Ms. Maxwell, and in the 2 conspiracy, again, in our view -- we understand the defense 3 will take a differing point of view on this, but in our view, 4 the conspiracy's next echelon is Kellen and Marcinkova. 5 And so for example, Ms. Giuffre has made allegations 6 about certain things. Ms. Maxwell can't remember or denies 7 them, so of course Ms. Giuffre then looks to corroborate her 8 allegations of a conspiracy, and the first person she goes to 9 is Epstein, and you're familiar with that. The second and 10 third people that she goes to are Kellen and Marcinkova, 1a because they report immediately to Ms. Maxwell in the 12 conspiracy. And Ms. Giuffre is going to be talking about that 13 during the course of the trial, and immediately the jury is 14 going to wonder, well, gosh, I wonder what Kellen says about 15 that? I wonder what Marcinkova says about that? And your 16 Honor will recall that we went to great lengths to get them to de testify. They were evading service, in our view. We 18 ultimately had to come to your Honor to get alternative 19 service, and it was only at that point that we were able to 20 have them sit for their depositions. They sat for their 21 depositions now, and what we hear from the defense, if I 22 understand it, is that we don't have a good-faith basis for 23 asking Kellen and Marcinkova, gee, weren't you a part of this 24 sex trafficking and sex abuse conspiracy? I think the way they 25 put it in their brief is, all of this evidence shows nothing SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011439