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Case 1:20-cr-00330-PAE Document 737 Filed 07/22/22 Page 57 of 101 57
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1 out who they were and who they might be some day when they grew
2 up. These kids had hopes and dreams for their future and the
3 defendant used those dreams as her tool to abuse them.
4 We ask the Court to take an unflinching look at the
5 defendant's actions and consider what that tells you about who
6 she really is. What kind of person persuades young girls to
7 massage the feet of a middle-aged man? What kind of person
8 gets a 16-year-old girl all alone at a ranch in the middle of
9 nowhere and tells her to take off her clothes and get on a
10 massage table so that she can grope that girl's chest? What
11 kind of person teaches a 14-year-old girl how a middle-aged man
12 likes his penis to be touched? What kind of person sees a
13 17-year-old girl on the street and pulls over so that she can
14 persuade that girl to come to a house of horrors where that
15 young girl will be trafficked for sex? What kind of person
16 flies around on a plane with underage girls so that when her
17 boyfriend travels, he always has a young girl to touch? What
18 kind of person would use their privilege, their power in this
19 world to intentionally prey on the vulnerable, young girls from
20 struggling families: Girls without fathers, girls who needed
21 help. These are the actions of a person who was indifferent to
22 the suffering of other human beings.
23 The defendant's actions were not a one-time mistake;
24 not at all. Maxwell was an adult woman, and she made the
25 choice, week in, week out for years to commit crimes with

SOUTHERN DISTRICT REPORTERS, P.C. .
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(212) 805-0300
DOJ-OGR-00011576