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642 KB
Extraction Summary
3
People
2
Organizations
1
Locations
2
Events
3
Relationships
7
Quotes
Document Information
Type:
Legal document
File Size:
642 KB
Summary
This legal document, page 24 of a court filing dated December 2, 2024, discusses the legal standards for reviewing a court sentence for procedural and substantive reasonableness. It specifically addresses a finding by the District Court that Maxwell supervised her assistant, Sarah Kellen, which was based on testimony from two of Epstein's pilots. This testimony was deemed credible and corroborated by other testimony describing Maxwell as Epstein's 'number two and the lady of the house' in Palm Beach.
People (3)
| Name | Role | Context |
|---|---|---|
| Maxwell |
Subject of a District Court finding that she supervised Sarah Kellen and was described as Epstein's 'number two and t...
|
|
| Sarah Kellen | Maxwell's assistant |
Mentioned as being supervised by Maxwell, based on testimony from Epstein's pilots.
|
| Epstein |
Mentioned as the employer of pilots who testified, and the owner of the house in Palm Beach where Maxwell was 'the la...
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| District Court | government agency |
The court whose sentencing and findings are being reviewed in this document.
|
| United States | government |
Mentioned as a party in several legal case citations (United States v. Cavera, Gall v. United States, United States v...
|
Timeline (2 events)
Two of Epstein's pilots testified that Sarah Kellen was Maxwell's assistant.
District Court
Epstein's pilots
The District Court found that Maxwell supervised Sarah Kellen, applying a four-level leadership enhancement to her sentence.
District Court
Locations (1)
| Location | Context |
|---|---|
|
Location where Maxwell was described as Epstein's 'number two and the lady of the house'.
|
Relationships (3)
The District Court found that Maxwell 'supervised' Sarah Kellen, who was identified as Maxwell's assistant based on pilot testimony.
Testimony described Maxwell as Epstein's 'number two and the lady of the house' in his Palm Beach residence.
The document refers to 'two of Epstein's pilots' who provided testimony.
Key Quotes (7)
"amounts to review for abuse of discretion."Source
— United States v. Cavera
(Describing the standard of review for a sentence's reasonableness.)
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Quote #1
"fails to calculate (or improperly calculates) the Sentencing Guidelines range, treats the Sentencing Guidelines as mandatory, fails to consider the [Section] 3553(a) factors, selects a sentence based on clearly erroneous facts, or fails adequately to explain the chosen sentence."Source
— United States v. Robinson
(Explaining what constitutes procedural error by a district court in sentencing.)
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Quote #2
"are guidelines—that is, they are truly advisory."Source
— Cavera
(Emphasizing the nature of the Sentencing Guidelines.)
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Quote #3
"generally free to impose sentences outside the recommended range"Source
— Unknown (cited from Cavera)
(Describing a District Court's discretion in sentencing.)
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Quote #4
"informed and individualized judgment."Source
— Unknown (cited from Cavera)
(The basis on which a District Court can impose sentences outside the recommended range.)
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Quote #5
"supervised"Source
— District Court
(The court's finding regarding Maxwell's relationship with Sarah Kellen.)
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Quote #6
"number two and the lady of the house"Source
— Unknown witness testimony
(A description of Maxwell's role in Epstein's Palm Beach residence, used to corroborate other testimony.)
DOJ-OGR-00021901.jpg
Quote #7
Full Extracted Text
Complete text extracted from the document (1,674 characters)
Case 22-1426, Document 121-2, 12/02/2024, 3637741, Page24 of 26
We review a sentence for both procedural and substantive
reasonableness, which “amounts to review for abuse of discretion.”⁵²
We have explained that procedural error is found when a district court
“fails to calculate (or improperly calculates) the Sentencing Guidelines
range, treats the Sentencing Guidelines as mandatory, fails to consider
the [Section] 3553(a) factors, selects a sentence based on clearly
erroneous facts, or fails adequately to explain the chosen sentence.”⁵³
The District Court did none of that. It is important to emphasize that
the Sentencing Guidelines “are guidelines—that is, they are truly
advisory.”⁵⁴ A District Court is “generally free to impose sentences
outside the recommended range” based on its own “informed and
individualized judgment.”⁵⁵
reasonableness, which “amounts to review for abuse of discretion.”⁵²
We have explained that procedural error is found when a district court
“fails to calculate (or improperly calculates) the Sentencing Guidelines
range, treats the Sentencing Guidelines as mandatory, fails to consider
the [Section] 3553(a) factors, selects a sentence based on clearly
erroneous facts, or fails adequately to explain the chosen sentence.”⁵³
The District Court did none of that. It is important to emphasize that
the Sentencing Guidelines “are guidelines—that is, they are truly
advisory.”⁵⁴ A District Court is “generally free to impose sentences
outside the recommended range” based on its own “informed and
individualized judgment.”⁵⁵
With respect to the four-level leadership enhancement, the District
Court found that Maxwell “supervised” Sarah Kellen in part because
of testimony from two of Epstein’s pilots who testified that Kellen was
Maxwell’s assistant. The District Court found that testimony credible,
in part because it was corroborated by other testimony that Maxwell
was Epstein’s “number two and the lady of the house” in Palm Beach,
Court found that Maxwell “supervised” Sarah Kellen in part because
of testimony from two of Epstein’s pilots who testified that Kellen was
Maxwell’s assistant. The District Court found that testimony credible,
in part because it was corroborated by other testimony that Maxwell
was Epstein’s “number two and the lady of the house” in Palm Beach,
___
⁵² United States v. Cavera, 550 F.3d 180, 187 (2d Cir. 2008) (en banc). “Regardless of whether
the sentence imposed is inside or outside the Guidelines range, the appellate court must
review the sentence under an abuse-of-discretion standard.” Gall v. United States, 552 U.S.
38, 51 (2007).
⁵² United States v. Cavera, 550 F.3d 180, 187 (2d Cir. 2008) (en banc). “Regardless of whether
the sentence imposed is inside or outside the Guidelines range, the appellate court must
review the sentence under an abuse-of-discretion standard.” Gall v. United States, 552 U.S.
38, 51 (2007).
⁵³ United States v. Robinson, 702 F.3d 22, 38 (2d Cir. 2012).
⁵⁴ Cavera, 550 F.3d at 189.
⁵⁵ Id.
24
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