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681 KB
Extraction Summary
3
People
4
Organizations
1
Locations
3
Events
2
Relationships
5
Quotes
Document Information
Type:
Legal filing (sentencing memorandum)
File Size:
681 KB
Summary
This document is page 3 of a sentencing memorandum filed on June 15, 2022, on behalf of Ghislaine Maxwell (Case 1:20-cr-00330-PAE). The defense argues that a 240-month sentence recommended by Probation is excessive given the conditions of her confinement (solitary, threats against her life) and argues she should not receive a sentence appropriate for Epstein. It also provides context regarding the previous 'sweetheart deal' Epstein received in Florida under Alexander Acosta, noting the public outcry that followed.
People (3)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the sentencing memorandum; referred to as 'Ms. Maxwell' in footnotes; facing sentencing.
|
| Jeffrey Epstein | Co-conspirator (Deceased) |
referenced for comparison regarding sentencing; subject of previous SDFL prosecution.
|
| Alexander Acosta | Former U.S. Attorney / Secretary of Labor |
Removed from cabinet post for his role as U.S. Attorney for SDFL overseeing the Epstein case.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Probation |
Probation Department; recommended a sentence of 240 months.
|
|
| Southern District of Florida (SDFL) |
Jurisdiction where previous prosecution against Epstein commenced.
|
|
| The Miami Herald |
News publication featured in ongoing coverage of the Epstein case.
|
|
| Department of Justice (DOJ) |
Implied by footer 'DOJ-OGR'.
|
Timeline (3 events)
Historical
Revival of prosecution commenced in SDFL against Epstein resulting in NPA
Southern District of Florida
Recent (relative to June 2022)
Death threat against Ghislaine Maxwell by another inmate
Prison (Maxwell's unit)
Ghislaine Maxwell
Unnamed Inmate
Locations (1)
| Location | Context |
|---|---|
|
Location of previous Epstein prosecution.
|
Relationships (2)
Acosta was U.S. Attorney for SDFL overseeing the Epstein case.
Document argues against Maxwell receiving a sentence appropriate for Epstein.
Key Quotes (5)
"It would be a travesty of justice for her to face a sentence that would have been appropriate for Epstein."Source
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Quote #1
"Probation recommended a sentence of 240 months’ imprisonment"Source
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Quote #2
"extraordinary punitive conditions of solitary confinement and the ongoing COVID-19 pandemic"Source
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Quote #3
"The 'sweetheart' deal created an uproar among his victims and the public"Source
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Quote #4
"claiming that an additional 20 years’ incarceration would be worth the money she’d receive for murdering Ms. Maxwell."Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,031 characters)
Case 1:20-cr-00330-PAE Document 663 Filed 06/15/22 Page 3 of 77
threats continue while she is incarcerated.¹ It would be a travesty of justice for her to face a
sentence that would have been appropriate for Epstein.
sentence that would have been appropriate for Epstein.
In its Final Presentence Investigation Report (“PSR”), Probation recommended a sentence
of 240 months’ imprisonment, a slight downward variance from the sentence recommended by
the advisory Guidelines. We have submitted objections directly to Probation which are amplified
in an accompanying submission.² We respectfully submit that in light of the circumstances
discussed below, including extraordinary punitive conditions of solitary confinement and the
ongoing COVID-19 pandemic, a sentence below the 240 months recommended by Probation
would be “sufficient, but not greater than necessary” to achieve the objectives of sentencing
articulated in 18 U.S.C. § 3553(a).
of 240 months’ imprisonment, a slight downward variance from the sentence recommended by
the advisory Guidelines. We have submitted objections directly to Probation which are amplified
in an accompanying submission.² We respectfully submit that in light of the circumstances
discussed below, including extraordinary punitive conditions of solitary confinement and the
ongoing COVID-19 pandemic, a sentence below the 240 months recommended by Probation
would be “sufficient, but not greater than necessary” to achieve the objectives of sentencing
articulated in 18 U.S.C. § 3553(a).
The Context of the Case
This is not the first time the events in this case were investigated and resolved. This case
is a revival of a prosecution commenced in the Southern District of Florida (“SDFL”) against
Epstein, which resulted in a state court conviction pursuant to a non-prosecution agreement. The
plea and sentence were negotiated without notice to Epstein’s victims. The “sweetheart” deal
created an uproar among his victims and the public, which was fueled by and featured in on-going
coverage in The Miami Herald. The public outcry led to removal of Alexander Acosta from his
cabinet post as Secretary of Labor for his role as U.S. Attorney for SDFL overseeing the Epstein
is a revival of a prosecution commenced in the Southern District of Florida (“SDFL”) against
Epstein, which resulted in a state court conviction pursuant to a non-prosecution agreement. The
plea and sentence were negotiated without notice to Epstein’s victims. The “sweetheart” deal
created an uproar among his victims and the public, which was fueled by and featured in on-going
coverage in The Miami Herald. The public outcry led to removal of Alexander Acosta from his
cabinet post as Secretary of Labor for his role as U.S. Attorney for SDFL overseeing the Epstein
__________________________________________________________________
¹ Most recently, an inmate in Ms. Maxwell’s unit threatened to kill her, claiming that an additional 20 years’
incarceration would be worth the money she’d receive for murdering Ms. Maxwell. See PSR ¶18.
¹ Most recently, an inmate in Ms. Maxwell’s unit threatened to kill her, claiming that an additional 20 years’
incarceration would be worth the money she’d receive for murdering Ms. Maxwell. See PSR ¶18.
² See PSR at 46-63 and the accompanying “Memorandum of Ghislaine Maxwell in Support of Her
Objections to the Presentence Investigation Report,” filed separately.
Objections to the Presentence Investigation Report,” filed separately.
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DOJ-OGR-00010449
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