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748 KB
Extraction Summary
7
People
3
Organizations
4
Locations
3
Events
4
Relationships
4
Quotes
Document Information
Type:
Court filing / sentencing memorandum
File Size:
748 KB
Summary
This document is a page from a Government sentencing filing (Case 1:20-cr-00330-PAE) arguing for a 'Four-Point Leadership Enhancement' under sentencing guidelines. It asserts that the defendant (Ghislaine Maxwell) was a leader of an 'otherwise extensive' criminal conspiracy involving Jeffrey Epstein, spanning the UK, Virgin Islands, and three states. The text cites testimony from victims (Carolyn, Virginia) and staff (Juan Alessi, pilots) to demonstrate the scale of the operation and the defendant's role in recruiting victims and managing Epstein's properties.
People (7)
| Name | Role | Context |
|---|---|---|
| The Defendant (Ghislaine Maxwell) | Defendant / Organizer / Leader |
Described as a close associate of Epstein, organizer of criminal activity, ran Epstein's properties.
|
| Jeffrey Epstein | Co-conspirator |
Described as having a criminal relationship with the defendant.
|
| Carolyn | Victim / Witness |
Testified she was recruited by Virginia and recruited other minor victims.
|
| Virginia (Giuffre) | Victim / Recruiter |
Recruited Carolyn; was recruited by the defendant while Juan Alessi was driving.
|
| Juan Alessi | Staff / Witness |
Testified he was driving when the defendant stopped to recruit Virginia.
|
| Sarah Kellen | Associate / Staff |
Mentioned as an individual involved in the criminal activity.
|
| Two Pilots | Staff / Witnesses |
Testified about transporting minor victims on Epstein's planes.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| The Government |
Agrees with Probation Office regarding sentencing enhancement.
|
|
| Probation Office |
Recommended the four-point leadership enhancement.
|
|
| Supreme Court |
Referenced for case law precedent (Peugh).
|
Timeline (3 events)
Unknown (Historic)
Locations (4)
| Location | Context |
|---|---|
|
Location where the conspiracy spanned.
|
|
|
Location where the conspiracy spanned.
|
|
|
Managed by the defendant, locations of criminal activity.
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|
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Unspecified US states where conspiracy occurred.
|
Relationships (4)
remained a close associate... continued to profit from their criminal relationship
Carolyn testified that she was recruited by Virginia
Alessi testified that he was driving when the defendant stopped
Defendant
→
Recruiter/Recruit
→
Virginia
defendant stopped to recruit Virginia
Key Quotes (4)
"the defendant remained a close associate of Jeffrey Epstein and continued to profit from their criminal relationship, long past 2004."Source
DOJ-OGR-00010560.jpg
Quote #1
"The defendant’s conspiracy spanned at least five victims in three states, the United Kingdom, and the U.S. Virgin Islands..."Source
DOJ-OGR-00010560.jpg
Quote #2
"Juan Alessi testified that he was driving when the defendant stopped to recruit Virginia."Source
DOJ-OGR-00010560.jpg
Quote #3
"Carolyn testified that she was recruited by Virginia and that Carolyn recruited other minor victims."Source
DOJ-OGR-00010560.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,216 characters)
Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 25 of 55
What the record makes clear is that the defendant remained a close associate of Jeffrey
Epstein and continued to profit from their criminal relationship, long past 2004. There is nothing
punitive about applying the 2004 Guidelines, which apply here as a matter of law. If anything, the
fact that the defendant will be sentenced under the 2004 Guidelines, and not the higher range under
the 2021 Guidelines, should be a factor that warrants a higher sentence. Indeed, the Supreme Court
has expressly noted that sentencing courts may consider subsequent increases in offense levels for
precisely that purpose. See Peugh, 569 U.S. at 549.
Epstein and continued to profit from their criminal relationship, long past 2004. There is nothing
punitive about applying the 2004 Guidelines, which apply here as a matter of law. If anything, the
fact that the defendant will be sentenced under the 2004 Guidelines, and not the higher range under
the 2021 Guidelines, should be a factor that warrants a higher sentence. Indeed, the Supreme Court
has expressly noted that sentencing courts may consider subsequent increases in offense levels for
precisely that purpose. See Peugh, 569 U.S. at 549.
B. The Four-Point Leadership Enhancement Applies
The Government agrees with the Probation Office that the enhancement in U.S.S.G.
§ 3B1.1 applies because the defendant was the organizer or leader of a criminal activity that was
“otherwise extensive.” The defendant’s conspiracy spanned at least five victims in three states,
the United Kingdom, and the U.S. Virgin Islands, including at Epstein’s various properties, which
the defendant ran, over the course of a decade. It involved the participation of numerous members
of the defendant and Epstein’s staff, whether knowing or unknowing, and the use of minor victims
to recruit other minor victims. See U.S.S.G. § 3B1.1 app. n.3 (“In assessing whether an
organization is ‘otherwise extensive,’ all persons involved during the course of the entire offense
are to be considered,” and use of “the unknowing services of many outsiders could be considered
extensive.”). For instance, Carolyn testified that she was recruited by Virginia and that Carolyn
recruited other minor victims. Juan Alessi testified that he was driving when the defendant stopped
to recruit Virginia. Two pilots testified about transporting minor victims on Epstein’s planes. That
alone is five individuals involved in the criminal activity, without even counting the defendant
herself, Epstein, and Sarah Kellen. See United States v. Kent, 821 F.3d 362, 369 (2d Cir. 2016)
(explaining that a scheme is “otherwise extensive” if it involves “the functional equivalent” of
§ 3B1.1 applies because the defendant was the organizer or leader of a criminal activity that was
“otherwise extensive.” The defendant’s conspiracy spanned at least five victims in three states,
the United Kingdom, and the U.S. Virgin Islands, including at Epstein’s various properties, which
the defendant ran, over the course of a decade. It involved the participation of numerous members
of the defendant and Epstein’s staff, whether knowing or unknowing, and the use of minor victims
to recruit other minor victims. See U.S.S.G. § 3B1.1 app. n.3 (“In assessing whether an
organization is ‘otherwise extensive,’ all persons involved during the course of the entire offense
are to be considered,” and use of “the unknowing services of many outsiders could be considered
extensive.”). For instance, Carolyn testified that she was recruited by Virginia and that Carolyn
recruited other minor victims. Juan Alessi testified that he was driving when the defendant stopped
to recruit Virginia. Two pilots testified about transporting minor victims on Epstein’s planes. That
alone is five individuals involved in the criminal activity, without even counting the defendant
herself, Epstein, and Sarah Kellen. See United States v. Kent, 821 F.3d 362, 369 (2d Cir. 2016)
(explaining that a scheme is “otherwise extensive” if it involves “the functional equivalent” of
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DOJ-OGR-00010560
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