663.pdf

Type

pdf

Source set

house-oversight-doj

Pages

77

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Searchable text available

OCR confidence

0.9126607274300952

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Extracted text

Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page1of77 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, -against- S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. SENTENCING MEMORANDUM ON BEHALF OF GHISLAINE MAXWELL Bobbi C. Sternheim Law Offices of Bobbi C. Sternheim 225 Broadway, Suite 715 New York, NY 10011 212-243-1100 Christian R. Everdell COHEN & GRESSER LLP 800 Third Avenue New York, NY 10022 212-957-7600 Jeffrey S. Pagliuca Laura A. Menninger HADDON, MORGAN & FOREMAN P.C. 950 17 Street, Suite 1000 Denver, CO 80202 303-831-7364 Attorneys for Ghislaine Maxwell DOJ-OGR-00010447 

Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 2 of 77 On behalf of our client, Ghislaine Maxwell, we respectfully submit this memorandum in connection with sentencing, which is scheduled for June 28, 2022. As set forth below, we request that the Court grant Ms. Maxwell a significant variance below the advisory Sentencing Guidelines range of 292 - 365 months and below the 240-month sentence recommended by the Probation Department (“Probation”). Ghislaine Maxwell stands before the Court because of her association with Jeffrey Epstein decades ago in the 1990s and early 2000s. Never before that time and never again in the roughly 20-year period since the conduct underlying this case occurred has Ms. Maxwell ever been accused of a crime, much less a scheme to sexually abuse minors. The witnesses at trial testified about Ms. Maxwell’s facilitation of Epstein’s abuse, but Epstein was always the central figure: Epstein was the mastermind, Epstein was the principal abuser, and Epstein orchestrated the crimes for his personal gratification. Indeed, had Ghislaine Maxwell never had the profound misfortune of meeting Jeffrey Epstein over 30 years ago, she would not be here. Epstein avoided a significant sentence when he was first prosecuted in Florida for these offenses and then evaded any further punishment by dying a month after his arrest and …

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