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673 KB
Extraction Summary
4
People
3
Organizations
0
Locations
3
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing (sentencing memorandum)
File Size:
673 KB
Summary
This page is from a defense sentencing memorandum filed on June 15, 2022, in the case against Ghislaine Maxwell. The defense argues that Maxwell is not a danger to the community, citing her lack of criminal history outside the charges (20-30 years prior) and her subsequent stable family life. It further argues that a harsh guidelines sentence is unnecessary for deterrence, as she has already lost her marriage and stepchildren and endured pre-sentence incarceration.
People (4)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the sentencing memorandum; described as posing no threat to the community and having learned a painful les...
|
| Jeffrey Epstein | Associate |
Mentioned regarding Maxwell's past association with him and her life 'after leaving Epstein.'
|
| Two men | Former Partners |
Unnamed individuals with whom Maxwell had committed, long-term relationships after leaving Epstein.
|
| Young children | Stepchildren/Children of partners |
Children of Maxwell's former partners who continue to support her.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Probation |
Government department that recommended a sentence.
|
|
| The government |
Prosecution; noted as never having argued Maxwell was a danger to the community during bail applications.
|
|
| DOJ |
Department of Justice, indicated in the footer stamp 'DOJ-OGR'.
|
Timeline (3 events)
Relationships (2)
Text mentions 'her association with Epstein' and 'leaving Epstein'.
Text mentions 'committed, long-term relationships with two men'.
Key Quotes (5)
"Ms. Maxwell poses no threat to the public and there is no risk that she will reoffend upon her release from custody."Source
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Quote #1
"Apart from the conduct at issue in this case, which occurred almost 20 to 30 years ago, Ms. Maxwell has never once been accused of a crime, much less sexual abuse of minors."Source
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Quote #2
"Ms. Maxwell is not a dangerous criminal or a habitual offender."Source
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Quote #3
"This is Ms. Maxwell’s only brush with the law."Source
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Quote #4
"[She] has lost her marriage and her stepchildren, and has been harshly punished during pre-sentence incarceration."Source
DOJ-OGR-00010465.jpg
Quote #5
Full Extracted Text
Complete text extracted from the document (1,931 characters)
Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 19 of 77
significantly below the sentence recommended by the advisory Sentencing Guidelines and below
the sentence recommended by Probation.
the sentence recommended by Probation.
Ms. Maxwell is Not a Danger to the Community
Ms. Maxwell poses no threat to the public and there is no risk that she will reoffend upon
her release from custody. The government has never argued, in connection with Ms. Maxwell’s
bail applications or otherwise, that Ms. Maxwell is a danger to the community; nor could they.
Apart from the conduct at issue in this case, which occurred almost 20 to 30 years ago, Ms.
Maxwell has never once been accused of a crime, much less sexual abuse of minors. In fact, after
leaving Epstein, Ms. Maxwell was involved in committed, long-term relationships with two men,
both of whom had young children who continue to support her. Ms. Maxwell is not a dangerous
criminal or a habitual offender. She is someone who wants nothing more than to live a normal
family life – something she was denied because of her association with Epstein and will now
almost certainly never have. The public does not need to be protected from Ms. Maxwell and such
considerations should have no weight in determining her sentence.
her release from custody. The government has never argued, in connection with Ms. Maxwell’s
bail applications or otherwise, that Ms. Maxwell is a danger to the community; nor could they.
Apart from the conduct at issue in this case, which occurred almost 20 to 30 years ago, Ms.
Maxwell has never once been accused of a crime, much less sexual abuse of minors. In fact, after
leaving Epstein, Ms. Maxwell was involved in committed, long-term relationships with two men,
both of whom had young children who continue to support her. Ms. Maxwell is not a dangerous
criminal or a habitual offender. She is someone who wants nothing more than to live a normal
family life – something she was denied because of her association with Epstein and will now
almost certainly never have. The public does not need to be protected from Ms. Maxwell and such
considerations should have no weight in determining her sentence.
A Guidelines Sentence is Not Necessary to Achieve Specific or General Deterrence
A guidelines sentence for Ms. Maxwell would not serve the sentencing goals of either
specific or general deterrence. A significant sentence is not necessary to achieve the goal of
individual deterrence here. This is Ms. Maxwell’s only brush with the law. Ms. Maxwell has
already learned a painful lesson from her arrest and prosecution, has lost her marriage and her
stepchildren, and has been harshly punished during pre-sentence incarceration. Ms. Maxwell
has already shown that she will not reoffend and does not need to be further deterred from
committing crimes in the future.
specific or general deterrence. A significant sentence is not necessary to achieve the goal of
individual deterrence here. This is Ms. Maxwell’s only brush with the law. Ms. Maxwell has
already learned a painful lesson from her arrest and prosecution, has lost her marriage and her
stepchildren, and has been harshly punished during pre-sentence incarceration. Ms. Maxwell
has already shown that she will not reoffend and does not need to be further deterred from
committing crimes in the future.
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DOJ-OGR-00010465
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