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Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 43 of 55

2. History and Characteristics of the Defendant

The history and characteristics of the defendant also weigh in favor of a Guidelines sentence.

Although many defendants come before sentencing courts with compelling mitigating factors from difficult upbringings, Maxwell is not among them. She has enjoyed a remarkable life of privilege, having lived in luxury and moved in social circles among the famous and powerful. And while the defendant may have had a marginally less positive experience than other exceptionally wealthy children, it is difficult to see how stern conversation at the family dinner table is an excuse for participating in a child exploitation scheme.

Moreover, the record at sentencing makes clear that the defendant has engaged in a significant pattern of dishonest conduct, which speaks volumes about her character. The defendant’s record includes the following:

- In 2016, the defendant testified under oath in a civil deposition in connection with a lawsuit brought by Virginia Roberts and lied repeatedly during her testimony. For example, she denied, among other things, having given Annie Farmer a massage. (PSR ¶ 75-76). As the evidence at trial established, that was a lie.

- Upon her arrest, the defendant was interviewed by Pretrial Services, and told them that the home she owned in New Hampshire was owned by a corporation, and that she was “just able to stay there.” (PSR ¶ 149). That was a lie, as were her statements to Pretrial Services about her finances. In an Order denying the defendant’s renewed application for bail, the Court remarked on the defendant’s “lack of candor” about her finances and concluded that the defendant had

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