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Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22
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Given the exceptionally serious nature of the defendant's years-long participation in the
sexual abuse of minors, consideration of the relevant factors under 18 U.S.C. § 3553(a) weighs
heavily in favor of a sentence within the Guidelines range of 360 to 660 months' imprisonment.
Most significantly, the nature and seriousness of the offense, the harm to victims, the need to
promote respect for the law, and the history and characteristics of the defendant weigh heavily in
favor of a Guidelines sentence.
The Government addresses each of these factors in turn below. However, certain aspects
of the defendant's submission bear addressing up front. First, the Court should reject the
defendant's request for a reduced sentence in light of conditions at the Metropolitan Detention
Center. The defendant's claims are inaccurate and in fact, the defendant has enjoyed remarkable
privileges as a high-profile inmate that vastly exceed the benefits accorded to the average inmate.
It is unsurprising that a woman who had led a life of incredible luxury should complain about her
life as a prisoner, but that fact does not come close to meriting leniency at sentencing, much less
the extraordinary degree of leniency the defendant seeks.
If anything stands out from the defendant's sentencing submission, it is her complete
failure to address her offense conduct and her utter lack of remorse. Instead of showing even a
hint of acceptance of responsibility, the defendant makes a desperate attempt to cast blame
wherever else she can. On that score, the defendant's attempt to cast aspersions on the Government
for prosecuting her, and her claim that she is being held responsible for Epstein's crimes, are both
absurd and offensive. Maxwell was an adult who made her own choices. She made the choice to
sexually exploit numerous underage girls. She made the choice to conspire with Epstein for years,
working as partners in crime and causing devastating harm to vulnerable victims. She should be
held accountable for her disturbing role in an extensive child exploitation scheme.
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