681-01.pdf
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- pdf
- Source set
- house-oversight-doj
- Pages
- 7
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- Searchable text available
- OCR confidence
- 0.9227276917528283
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Extracted text
Case 1:20-cr-00330-PAE Document 681-1 Filed 06/26/22 Page1of7 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, Plaintiff V. Case No. 1:20-cr-330 GHISLAINE MAXWELL, Defendant. 44444 4 aa MOTION OF KATE TO BE ALLOWED TO DELIVER A VICTIM IMPACT STATEMENT AT SENTENCING Jane Doe, who testified at the trial in this matter under the pseudonym Kate, through undersigned counsel, files this motion for the Court to be allowed to deliver a victim impact statement, orally and in court, at the sentencing of Ghislaine Maxwell on June 28. In support of this motion, the undersigned states as follows: INTRODUCTION At trial of Ghislaine Maxell, Kate testified about her experience with Ghislaine Maxwell. The jury found that Maxwell had committed crimes charged in the indictment beyond a reasonable doubt. Now, at sentencing, the Court has greater freedom to consider the full scope of the harms that Maxwell’s crimes have caused. See 18 U.S.C. § 3661 (“no limitation shall be placed on the information concerning the background, character, and conduct of a person convicted of an offense which a court of the United States may receive and consider for the purpose of imposing an appropriate sentence.”). Kate seeks to assist the Court in that effort by providing an oral victim impact statement at sentencing. DOJ-OGR-00010737
Case 1:20-cr-00330-PAE Document 681-1 Filed 06/26/22 Page2of7 FACTUAL BACKGROUND At this point in the proceedings, it is clear the defendant Maxwell was involved in a far- reaching sex trafficking conspiracy. Defendant Maxwell was found guilty by a jury of a “decade- long unlawful agreement with the Defendant’s continuous coconspirator, Jeffrey Epstein. The overarching conspiracy—which, as the Government argued and proved at trial, employed a single ‘playbook’ to groom and sexually abuse underage girls—constitutes a single conspiracy offense with multiple victims.” DE 657 at 2-3. Now, defendant Maxwell is to be sentenced for h…
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