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Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 15 of 77

Her relationship with Epstein began at a moment of extreme vulnerability
Ghislaine's life after the tragic death of our father. He (our father) was a powerful
and dominant figure. And as elder siblings we witnessed our father taking Ghislaine
under his wing whereby she became over dependent on his approval and vulnerable
to his frequent rapid mood swings, huge rages and rejections. This led her to
becoming very vulnerable to abusive andpowerful men who would be able to
take advantage of her innate good nature.

It is striking that Ghislaine did not show any perverse behaviour before she met
Epstein. Nor did she show any after leaving him, which she eventually managed
to do. The effect of our father's psychologically abusive treatment of her,
foreshadowed Epstein's own ability to exploit, manipulate and control her.

Exhibit A.

Another psychotherapist and family friend of some 55 years, James Martin Hollomon,
recalls his observations of Ghislaine’s father:

[T]heir father was narcissistic, demanding and highly controlling. He let
them know early that he was going to leave his large fortune to charity. So,
all the kids knew they had to "make it on their own" despite the wealth and
privilege in which they were growing up. As I got to know each of these kids,
including Ghislaine, I noticed that early on, every single one worked very
hard at their jobs, as Bob wouldn't bear any idleness, and each strove for their
father's and mother's respect through their intelligence and their own hard work.

Exhibit B.

Her twin sisters, Christine Malina Maxwell and Isabel Maxwell, attest to Ghislaine’s
work ethic:

[W]e were privileged, but we were not entitled and life was notalways perfect.
Unfortunately, our family also became a grieving family. Our eldest brother
Michaelwas gravely injured in a car accident just after Ghislaine was born; he
remained in a coma until his death when Ghislaine was seven years old. In spite
of this tragedy, I watched Ghislaine learn to adapt and to become a productive
and caring human being.

[B]oth of our parents had an incredible work ethic. We were all encouraged
from an early age to work to earn money and to respect the responsibility
that came with that privilege. I have witnessed that work ethic in Ghislaine.

Ghislaine had money because she worked very hard to earn it. Her positions
demanded hard, diligent work, great intelligence, great management skills,

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