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Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 44 of 55

“misrepresent[ed] key facts to Pretrial Services and, by extension, the Court.” (PSR
¶ 172, December 28, 2020 Opinion at 14-16).

• On November 1, 2021, the Court allocuted the defendant about whether she had
engaged in plea discussions with the Government. Although the Court’s question
called for a yes or no answer about plea offers, the defendant elected to volunteer
the following: “I have not committed any crime.” (November 1, 2021 Tr. at 113).
That was a lie.

• In preparation for sentencing, the defendant was interviewed by the Probation
Office, and she refused to provide any information about the circumstances of her
marriage and, accordingly, the Probation Office was unable to verify these facts.
(PSR at 145). Moreover, the defendant reported that she had almost no assets, a
sharp contrast from the defendant’s earlier representation to the Court—in pursuit
of bail—that she had approximately $22 million in assets. (PSR ¶ 172). In short,
the defendant apparently decides when she wishes to disclose facts to the Court,
and those facts shift when it serves the defendant’s interests.

Moreover, even now, at sentencing, the defendant has shown no acceptance of
responsibility, and her submission fails to even mention, much less accept responsibility for, the
harm she has caused her victims. Instead, her entire submission is an effort to cast herself as a
victim: of her father, of Epstein, of the media, of prosecutors, of the Bureau of Prisons. Although
much of the defendant’s sentencing memorandum aims to cast aspersions on the Government,
these claims are baseless. This Office did what it always does in any case: it followed the facts
and law. The investigation uncovered that the defendant committed terrible crimes, and that is
what this case is about. The Court should see the defendant’s attack on the Government’s motives

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