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Extraction Summary
2
People
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Organizations
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Locations
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Events
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Relationships
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Quotes
Document Information
Type:
Court filing / legal brief (sentencing submission)
File Size:
687 KB
Summary
This document is page 11 of a legal filing (Document 675) from June 25, 2022, in the case against Ghislaine Maxwell. It argues that the Court should hear from all victims of Maxwell's sex trafficking conspiracy during sentencing, citing legal precedents (such as United States v. Salutric) that allow judges to consider a defendant's broader criminal history and uncharged acts. The text emphasizes that victim impact statements regarding background and conduct are essential for determining a fair sentence.
People (2)
| Name | Role | Context |
|---|---|---|
| Elizabeth | Victim/Petitioner |
Respectfully submits that hearing victim information will assist the Court in sentencing.
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| Ghislaine Maxwell | Defendant |
Subject of the sentencing hearing; described as conducting a 'long-running and wide-ranging sex trafficking conspiracy'.
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Organizations (3)
| Name | Type | Context |
|---|---|---|
| Seventh Circuit |
Federal Court of Appeals cited for legal precedent regarding sentencing factors.
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| United States District Court |
Implied by case caption (PAE) and references to 'This Court'.
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| Department of Justice (DOJ) |
Indicated by the Bates stamp 'DOJ-OGR'.
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Timeline (1 events)
2022-06-25
Filing of Document 675 in Case 1:20-cr-00330-PAE
United States District Court
Locations (2)
| Location | Context |
|---|---|
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Jurisdiction of cited case United States v. Goss.
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Jurisdiction of cited case Krebs v. New York State Div. of Parole.
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Relationships (1)
Elizabeth submits arguments regarding Maxwell's sentencing for sex trafficking.
Key Quotes (3)
"Elizabeth respectfully submit that hearing their unique 'information concerning the background, character, and conduct' of Maxwell will assist the Court in imposing a fair and just sentence."Source
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Quote #1
"This Court should follow the same approach and hear from all victims of Maxwell’s long–running and wide–ranging sex trafficking conspiracy."Source
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Quote #2
"Uncharged criminal acts (and the injuries inflicted upon the victims of those acts) have a bearing on whether the offense of conviction was an aberration or part of a larger pattern of criminal behavior"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (2,137 characters)
Case 1:20-cr-00330-PAE Document 675 Filed 06/25/22 Page 11 of 21
Elizabeth respectfully submit that hearing their unique “information concerning the background,
character, and conduct” of Maxwell will assist the Court in imposing a fair and just sentence.
character, and conduct” of Maxwell will assist the Court in imposing a fair and just sentence.
A good illustration of these principles comes from the Seventh Circuit’s decision in United
States v. Salutric, 775 F.3d 948, 951–52 (7th Cir. 2015). In that case, the Seventh Circuit observed
that “[i]n arriving at an appropriate sentence, a sentencing judge necessarily must consider not only
the offense of conviction but the defendant’s broader criminal record and history.” Id. at 951. This
point follows from the rationale that “[u]ncharged criminal acts (and the injuries inflicted upon the
victims of those acts) have a bearing on whether the offense of conviction was an aberration or part
of a larger pattern of criminal behavior, the likelihood of the defendant re–offending, and the need
for specific deterrence.” Id., See also United States v. Laraneta, 700 F.3d 983, 987 (7th Cir. 2012). The
Seventh Circuit explained that the federal “Criminal Code makes clear that ‘[n]o limitation shall be
placed on the information concerning the background, character, and conduct of a person convicted
of an offense, which a court of the United States may receive and consider for the purpose of
imposing an appropriate sentence’.” 775 at 952 (quoting 18 U.S.C. § 3661).
States v. Salutric, 775 F.3d 948, 951–52 (7th Cir. 2015). In that case, the Seventh Circuit observed
that “[i]n arriving at an appropriate sentence, a sentencing judge necessarily must consider not only
the offense of conviction but the defendant’s broader criminal record and history.” Id. at 951. This
point follows from the rationale that “[u]ncharged criminal acts (and the injuries inflicted upon the
victims of those acts) have a bearing on whether the offense of conviction was an aberration or part
of a larger pattern of criminal behavior, the likelihood of the defendant re–offending, and the need
for specific deterrence.” Id., See also United States v. Laraneta, 700 F.3d 983, 987 (7th Cir. 2012). The
Seventh Circuit explained that the federal “Criminal Code makes clear that ‘[n]o limitation shall be
placed on the information concerning the background, character, and conduct of a person convicted
of an offense, which a court of the United States may receive and consider for the purpose of
imposing an appropriate sentence’.” 775 at 952 (quoting 18 U.S.C. § 3661).
This Court should follow the same approach and hear from all victims of Maxwell’s long–
running and wide–ranging sex trafficking conspiracy. See also United States v. Goss, 325 F. Supp. 3d
932, 936 (E.D. Wis. 2018) (affirming the court’s consideration of information at sentencing that was
not, strictly speaking, a “victim” impact statement because the “court can consider information from
a variety of sources” when imposing sentence). Matters of social welfare directly impact decisions
regarding the appropriateness of a criminal sentence. Krebs v. New York State Div. of Parole, No. 9:08-
CV-255NAMDEP, 2009 WL 2567779, at *2 (N.D.N.Y. Aug. 17, 2009) (allowing consideration of
running and wide–ranging sex trafficking conspiracy. See also United States v. Goss, 325 F. Supp. 3d
932, 936 (E.D. Wis. 2018) (affirming the court’s consideration of information at sentencing that was
not, strictly speaking, a “victim” impact statement because the “court can consider information from
a variety of sources” when imposing sentence). Matters of social welfare directly impact decisions
regarding the appropriateness of a criminal sentence. Krebs v. New York State Div. of Parole, No. 9:08-
CV-255NAMDEP, 2009 WL 2567779, at *2 (N.D.N.Y. Aug. 17, 2009) (allowing consideration of
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