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Case 1:20-cr-00330-PAE Document 672 Filed 06/24/22 Page 2 of 68

LAW OFFICES OF BOBBI C. STERNHEIM

Victim Impact Statements at Issue

Without stating its position regarding standing under the CVRA, the government has provided seven witness impact statements allegedly authored by the following: Annie Farmer (Exhibit A), “Kate” (Exhibit B), Virginia Giuffre (Exhibit C),, Maria Farmer (Exhibit D), Sarah Ransome (Exhibit E), Teresa Helm (Exhibit F), and Juliette Bryant (Exhibit G).¹ Annie Farmer, a minor at the time of the offense, and “Kate” were both named in the indictment and each testified at trial. Virginia Giuffre did not testify at trial but testimony and exhibits support that she was a minor when she interacted with Epstein and Ms. Maxwell during the time period of the indictment. Annie Farmer and Ms. Giuffre qualify as victims under the CVRA: both were minors when they interacted with Epstein and Ms. Maxwell during the period of the charged offenses. “Kate” was not a minor during the time period, and the jury was charged as such. Maria Farmer, Sarah Ransome, and Teresa Helm were not minors during the time they allegedly interacted with Epstein and Ms. Maxwell. Ms. Ransome’s alleged interaction occurred beyond the period of the charged offenses. It is unknown whether Juliette Bryant was a minor or when she allegedly interacted with Epstein and Ms. Maxwell.

The victim impact statements recount abuse and injuries suffered by the Individuals. Allegations alone do not serve to automatically qualify the Individuals as statutory victims under the CVRA. Their statements do not link the alleged abuse and injuries “directly and proximately” to federal offense conduct whose essential qualifying element is that the victim was a minor at the time of the offense.

¹ The statements of Virginia Giuffre, Annie Farmer, Maria Farmer, Teresa Helm, and Juliette Bryant were submitted on the letterhead of their mutual attorney, Sigrid S. McCawley, Esq. “Kate’s” statement was accompanied by a motion by her attorney, Bradley J. Edwards, Esq. The statement of Sarah Ransome, referenced in a letter to the Court by her attorney, Robert Y. Lewis, Esq. (Dkt. 666), appears to have been submitted directly by Ms. Ransome. Proposed redactions are reflected in each Exhibit.

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