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749 KB
Extraction Summary
8
People
4
Organizations
0
Locations
2
Events
3
Relationships
5
Quotes
Document Information
Type:
Legal filing / court document (defense sentencing memorandum or reply)
File Size:
749 KB
Summary
This document is page 5 of a defense filing (dated June 24, 2022) related to the sentencing of Ghislaine Maxwell. It argues that the definition of 'victim' under the CVRA is narrower than sentencing guidelines and asserts that Maxwell's due process rights must be protected against new allegations in victim impact statements from accusers Annie Farmer and 'Kate' that were not cross-examined at trial. The document also attempts to impeach the credibility of Virginia Giuffre, noting she did not testify and alleging in a footnote that she failed to disclose prior abuse by a man named Ron Eppinger.
People (8)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the sentencing hearing; document argues for her due process rights.
|
| Bobbi C. Sternheim | Defense Attorney |
Listed in the letterhead as 'Law Offices of Bobbi C. Sternheim'.
|
| Annie Farmer | Accuser/Witness |
One of two accusers who testified at trial and submitted a victim impact statement.
|
| Kate | Accuser/Witness |
One of two accusers who testified at trial and submitted a victim impact statement (referred to by pseudonym).
|
| Virginia Giuffre | Accuser |
Mentioned during trial but not called as a government witness; her credibility is challenged by the defense.
|
| Alan Dershowitz | Third Party |
His counsel sent letters to the government cautioning them (context cut off).
|
| Ron Eppinger | Alleged Sex Trafficker |
Mentioned in a footnote as a 65-year-old sex trafficker who allegedly abused Giuffre before she met Epstein.
|
| Jeffrey Epstein | Associate |
Mentioned in footnote regarding the timeline of Giuffre's abuse.
|
Organizations (4)
| Name | Type | Context |
|---|---|---|
| Law Offices of Bobbi C. Sternheim | ||
| The Court |
Made rulings precluding defense arguments; presiding over sentencing.
|
|
| The Government |
Did not call Giuffre as witness; recipient of letters from Dershowitz's counsel.
|
|
| 4th Circuit Court of Appeals |
Cited in case law United States v. Blake.
|
Timeline (2 events)
Unknown (Trial dates)
Relationships (3)
Footnote mentions Giuffre meeting 'Epstein and Ms. Maxwell'.
Footnote claims Giuffre was abused by Eppinger prior to meeting Epstein.
Both testified at trial and submitted impact statements.
Key Quotes (5)
"The definition of 'victim' in the CVRA does not mirror the various definitions of 'victim' in the guidelines."Source
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Quote #1
"Ms. Maxwell’s Due Process Rights Must Be Safeguarded"Source
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Quote #2
"Of the four accusers who testified at trial, only two – Annie Farmer and 'Kate'- have submitted victim impact statements."Source
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Quote #3
"Virginia Giuffre was mentioned during trial but was not called as a government witness. Her credibility remains in issue."Source
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Quote #4
"Absent from Ms. Giuffre’s statement is any mention of her abuse by a 65-year-old sex trafficker, Ron Eppinger, pre-dating her meeting Epstein and Ms. Maxwell"Source
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Quote #5
Full Extracted Text
Complete text extracted from the document (2,234 characters)
Case 1:20-cr-00330-PAE Document 672 Filed 06/24/22 Page 5 of 68
LAW OFFICES OF BOBBI C. STERNHEIM
LAW OFFICES OF BOBBI C. STERNHEIM
allocution at sentencing Id. §3771(a)(4), (e). The definition of “victim” in the CVRA does not
mirror the various definitions of “victim” in the guidelines. Cf. United States v. Blake, 81 F.3d
498, 506 n.5 (4th Cir. 1996) (“The definition of victim provided in [the statute] is much narrower
than the one in the guidelines.”) Therefore, the terms should not be conflated. It cannot be
assumed that “relevant conduct” for guidelines purposes is the same as “related conduct” for
purposes of determining statutory victim status under a scheme or conspiracy-based offense. Nor
does the term “victim,” as variously appearing in the guidelines, inform the determination of
statutory victim status under the CVRA.
mirror the various definitions of “victim” in the guidelines. Cf. United States v. Blake, 81 F.3d
498, 506 n.5 (4th Cir. 1996) (“The definition of victim provided in [the statute] is much narrower
than the one in the guidelines.”) Therefore, the terms should not be conflated. It cannot be
assumed that “relevant conduct” for guidelines purposes is the same as “related conduct” for
purposes of determining statutory victim status under a scheme or conspiracy-based offense. Nor
does the term “victim,” as variously appearing in the guidelines, inform the determination of
statutory victim status under the CVRA.
Ms. Maxwell’s Due Process Rights Must Be Safeguarded
The CVRA affords victims the right of confrontation against their alleged abusers.
The Act does not provide a reciprocal right to a defendant, whose due process rights rest in the
opportunity to cross-examine an alleged victim during trial. Of the four accusers who testified at
trial, only two – Annie Farmer and “Kate”- have submitted victim impact statements. To the
extent permitted by the Court’s rulings, the defense had the opportunity to challenge their
allegations and credibility during the trial. Under Federal Rule of Evidence 412, the Court
precluded the defense from raising certain issues during trial. Both Annie Farmer and “Kate”
raise issues in their written statements that were not disclosed by the government or revealed
during their testimony and should not be permitted to be aired during sentencing [REDACTED]
[REDACTED]. To the extent such
portions of their statements are redacted, we will not press objection for CVRA victims. Virginia
Giuffre was mentioned during trial but was not called as a government witness. Her credibility
remains in issue.² By letters to the government, counsel for Alan Dershowitz have cautioned the
The Act does not provide a reciprocal right to a defendant, whose due process rights rest in the
opportunity to cross-examine an alleged victim during trial. Of the four accusers who testified at
trial, only two – Annie Farmer and “Kate”- have submitted victim impact statements. To the
extent permitted by the Court’s rulings, the defense had the opportunity to challenge their
allegations and credibility during the trial. Under Federal Rule of Evidence 412, the Court
precluded the defense from raising certain issues during trial. Both Annie Farmer and “Kate”
raise issues in their written statements that were not disclosed by the government or revealed
during their testimony and should not be permitted to be aired during sentencing [REDACTED]
[REDACTED]. To the extent such
portions of their statements are redacted, we will not press objection for CVRA victims. Virginia
Giuffre was mentioned during trial but was not called as a government witness. Her credibility
remains in issue.² By letters to the government, counsel for Alan Dershowitz have cautioned the
² Absent from Ms. Giuffre’s statement is any mention of her abuse by a 65-year-old sex trafficker, Ron
Eppinger, pre-dating her meeting Epstein and Ms. Maxwell, which she recounted in her memoir -
Eppinger, pre-dating her meeting Epstein and Ms. Maxwell, which she recounted in her memoir -
5
DOJ-OGR-00010596
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