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699 KB
Extraction Summary
7
People
6
Organizations
0
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Legal filing (defense sentencing memorandum)
File Size:
699 KB
Summary
This document is page 17 of a defense sentencing memorandum filed on June 15, 2022, in the case against Ghislaine Maxwell. The defense argues against the application of sentencing guideline § 4B1.5 ('Repeat and Dangerous' sex offenders), asserting that Maxwell has not committed crimes in nearly 20 years, is not attracted to minors, and acted only as a facilitator for Epstein's impulses rather than having them herself. The text contrasts her behavior with case law examples of violent repeat offenders and highlights her subsequent crime-free life involved with partners who had children.
People (7)
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Subject of the sentencing memo; defense argues she is not a repeat offender or dangerous, and has lived crime-free fo...
|
| Jeffrey Epstein | Associate/Co-conspirator |
Described as the one with 'proclivities' and 'uncontrollable impulses' while Maxwell's role was to facilitate his abuse.
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| Broxmeyer | Defendant in cited case law |
Cited as an example of a defendant to whom sentencing adjustments typically apply.
|
| Suarez | Defendant in cited case law |
United States v. Suarez citation.
|
| Santos | Defendant in cited case law |
United States v. Santos citation.
|
| Sanchez | Defendant in cited case law |
United States v. Sanchez citation.
|
| McGrain | Defendant in cited case law |
United States v. McGrain citation.
|
Organizations (6)
| Name | Type | Context |
|---|---|---|
| The Government |
Prosecution; asserting that guideline § 4B1.5 should apply to Maxwell.
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| DOJ |
Department of Justice (referenced in footer stamp DOJ-OGR-00010434).
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| 3d Cir. |
Third Circuit Court of Appeals (legal citation).
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| 5th Cir. |
Fifth Circuit Court of Appeals (legal citation).
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| 11th Cir. |
Eleventh Circuit Court of Appeals (legal citation).
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| W.D.N.Y. |
Western District of New York (legal citation).
|
Timeline (2 events)
Early 2000s
Time period when Maxwell allegedly 'moved on from Epstein'
Unspecified
Relationships (2)
Text states Maxwell's role was to 'facilitate Epstein's sexual abuse' and that she moved on from him in the early 2000s.
Text mentions 'two long-term relationships with men who had young children' post-Epstein.
Key Quotes (4)
"According to the trial record, it was Epstein who had such proclivities, whereas Ms. Maxwell’s role was to facilitate Epstein’s sexual abuse."Source
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Quote #1
"Put simply, Ms. Maxwell is not “dangerous” and there is no risk that Ms. Maxwell will ever “repeat” the offense."Source
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Quote #2
"Indeed, after she moved on from Epstein in the early 2000s, Ms. Maxwell was involved in two long-term relationships with men who had young children and was actively involved in their lives without even the slightest hint of impropriety."Source
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Quote #3
"There is absolutely no evidence that Ms. Maxwell is attracted to minors or has the sort of uncontrollable impulses that would compel her to re-offend."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,151 characters)
Case 1:20-cr-00330-PAE Document 662 Filed 06/15/22 Page 17 of 29
The case law bears this out. The adjustment is typically applied to defendants (virtually
all of whom are male) who repeatedly and often violently sexually abuse or exploit children for
their own sexual gratification and who are caught soon after or while still engaging in that
behavior. See, e.g., Broxmeyer, 699 F.3d at 284-88; United States v. Suarez, No. 21-1721, 2022
WL 1449174, at *1-*2 (3d Cir. May 9, 2022); United States v. Santos, No. 21-10381, 2022 WL
1196761, at *1-*3 (5th Cir. Apr. 22, 2022); United States v. Sanchez, 30 F.4th 1063, 1067-76
(11th Cir. 2022); United States v. McGrain, No. 6:20-cr-06113 (EAW), 2022 WL 287350, at *1-
*6 (W.D.N.Y. Feb. 1, 2022).
all of whom are male) who repeatedly and often violently sexually abuse or exploit children for
their own sexual gratification and who are caught soon after or while still engaging in that
behavior. See, e.g., Broxmeyer, 699 F.3d at 284-88; United States v. Suarez, No. 21-1721, 2022
WL 1449174, at *1-*2 (3d Cir. May 9, 2022); United States v. Santos, No. 21-10381, 2022 WL
1196761, at *1-*3 (5th Cir. Apr. 22, 2022); United States v. Sanchez, 30 F.4th 1063, 1067-76
(11th Cir. 2022); United States v. McGrain, No. 6:20-cr-06113 (EAW), 2022 WL 287350, at *1-
*6 (W.D.N.Y. Feb. 1, 2022).
In sharp contrast, Ms. Maxwell has never been accused of any sex offenses—or any
crimes, for that matter—in the almost 20-year period since the conduct at issue in this case
ended. There is absolutely no evidence that Ms. Maxwell is attracted to minors or has the sort of
uncontrollable impulses that would compel her to re-offend. According to the trial record, it was
Epstein who had such proclivities, whereas Ms. Maxwell’s role was to facilitate Epstein’s sexual
abuse. Indeed, after she moved on from Epstein in the early 2000s, Ms. Maxwell was involved
in two long-term relationships with men who had young children and was actively involved in
their lives without even the slightest hint of impropriety. Most importantly, the government
concedes that Ms. Maxwell is not a danger to the community. The government never made that
assertion in connection with Ms. Maxwell’s numerous bail applications and there is no evidence
whatsoever to support such a claim. Put simply, Ms. Maxwell is not “dangerous” and there is no
risk that Ms. Maxwell will ever “repeat” the offense. Accordingly, there is no basis to apply
§ 4B1.5, which is meant to apply only to “Repeat and Dangerous” sex offenders.
crimes, for that matter—in the almost 20-year period since the conduct at issue in this case
ended. There is absolutely no evidence that Ms. Maxwell is attracted to minors or has the sort of
uncontrollable impulses that would compel her to re-offend. According to the trial record, it was
Epstein who had such proclivities, whereas Ms. Maxwell’s role was to facilitate Epstein’s sexual
abuse. Indeed, after she moved on from Epstein in the early 2000s, Ms. Maxwell was involved
in two long-term relationships with men who had young children and was actively involved in
their lives without even the slightest hint of impropriety. Most importantly, the government
concedes that Ms. Maxwell is not a danger to the community. The government never made that
assertion in connection with Ms. Maxwell’s numerous bail applications and there is no evidence
whatsoever to support such a claim. Put simply, Ms. Maxwell is not “dangerous” and there is no
risk that Ms. Maxwell will ever “repeat” the offense. Accordingly, there is no basis to apply
§ 4B1.5, which is meant to apply only to “Repeat and Dangerous” sex offenders.
The government asserts that § 4B1.5 should apply as long as the offense conduct fits
within the text of the guideline, to which it claims to be faithfully adhering. See PSR at 60. It is
within the text of the guideline, to which it claims to be faithfully adhering. See PSR at 60. It is
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DOJ-OGR-00010434
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