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681 KB
Extraction Summary
2
People
3
Organizations
2
Locations
4
Events
1
Relationships
4
Quotes
Document Information
Type:
Legal filing (sentencing memorandum)
File Size:
681 KB
Summary
This is page 1 (marked as page 2 of the filing) of a sentencing memorandum filed on June 15, 2022, on behalf of Ghislaine Maxwell. The defense requests a sentence significantly below the guideline range of 292-365 months and below the Probation Department's recommended 240 months. The text argues that Maxwell is being unfairly treated as a proxy for the deceased Jeffrey Epstein, whom the defense characterizes as the true mastermind and principal abuser.
People (2)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Client |
Facing sentencing; defense argues she is being used as a proxy for Epstein.
|
| Jeffrey Epstein | Associate/Deceased |
Described by defense as the 'mastermind' and 'principal abuser' who orchestrated the crimes.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Probation Department |
Recommended a 240-month sentence for Maxwell.
|
|
| DOJ |
Referenced in footer stamp (DOJ-OGR).
|
|
| The Court |
Addressed in the memorandum regarding sentencing decisions.
|
Timeline (4 events)
1990s-2000s
Relationships (1)
Document states she is before the court because of her association with him; describes meeting him as a 'profound misfortune.'
Key Quotes (4)
"Epstein was the mastermind, Epstein was the principal abuser, and Epstein orchestrated the crimes for his personal gratification."Source
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Quote #1
"Indeed, had Ghislaine Maxwell never had the profound misfortune of meeting Jeffrey Epstein over 30 years ago, she would not be here."Source
DOJ-OGR-00010448.jpg
Quote #2
"Ms. Maxwell cannot and should not bear all the punishment for which Epstein should have been held responsible."Source
DOJ-OGR-00010448.jpg
Quote #3
"Since Epstein’s death, her life has been threatened and death"Source
DOJ-OGR-00010448.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (1,960 characters)
Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 2 of 77
On behalf of our client, Ghislaine Maxwell, we respectfully submit this memorandum in
connection with sentencing, which is scheduled for June 28, 2022. As set forth below, we request
that the Court grant Ms. Maxwell a significant variance below the advisory Sentencing Guidelines
range of 292 - 365 months and below the 240-month sentence recommended by the Probation
Department (“Probation”).
connection with sentencing, which is scheduled for June 28, 2022. As set forth below, we request
that the Court grant Ms. Maxwell a significant variance below the advisory Sentencing Guidelines
range of 292 - 365 months and below the 240-month sentence recommended by the Probation
Department (“Probation”).
Ghislaine Maxwell stands before the Court because of her association with Jeffrey Epstein
decades ago in the 1990s and early 2000s. Never before that time and never again in the roughly
20-year period since the conduct underlying this case occurred has Ms. Maxwell ever been accused
of a crime, much less a scheme to sexually abuse minors. The witnesses at trial testified about Ms.
Maxwell’s facilitation of Epstein’s abuse, but Epstein was always the central figure: Epstein was
the mastermind, Epstein was the principal abuser, and Epstein orchestrated the crimes for his
personal gratification. Indeed, had Ghislaine Maxwell never had the profound misfortune of
meeting Jeffrey Epstein over 30 years ago, she would not be here.
decades ago in the 1990s and early 2000s. Never before that time and never again in the roughly
20-year period since the conduct underlying this case occurred has Ms. Maxwell ever been accused
of a crime, much less a scheme to sexually abuse minors. The witnesses at trial testified about Ms.
Maxwell’s facilitation of Epstein’s abuse, but Epstein was always the central figure: Epstein was
the mastermind, Epstein was the principal abuser, and Epstein orchestrated the crimes for his
personal gratification. Indeed, had Ghislaine Maxwell never had the profound misfortune of
meeting Jeffrey Epstein over 30 years ago, she would not be here.
Epstein avoided a significant sentence when he was first prosecuted in Florida for these
offenses and then evaded any further punishment by dying a month after his arrest and detention
in New York. But this Court cannot sentence Ms. Maxwell as if she were a proxy for Epstein
simply because Epstein is no longer here. Ms. Maxwell cannot and should not bear all the
punishment for which Epstein should have been held responsible. Ms. Maxwell has already
experienced hard time during detention under conditions far more onerous and punitive than any
experienced by a typical pretrial detainee, and she is preparing to spend significantly more time
behind bars. Her life has been ruined. Since Epstein’s death, her life has been threatened and death
offenses and then evaded any further punishment by dying a month after his arrest and detention
in New York. But this Court cannot sentence Ms. Maxwell as if she were a proxy for Epstein
simply because Epstein is no longer here. Ms. Maxwell cannot and should not bear all the
punishment for which Epstein should have been held responsible. Ms. Maxwell has already
experienced hard time during detention under conditions far more onerous and punitive than any
experienced by a typical pretrial detainee, and she is preparing to spend significantly more time
behind bars. Her life has been ruined. Since Epstein’s death, her life has been threatened and death
1
DOJ-OGR-00010448
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