DOJ-OGR-00010694.jpg
611 KB
Extraction Summary
5
People
3
Organizations
2
Locations
2
Events
3
Relationships
3
Quotes
Document Information
Type:
Legal filing (court document)
File Size:
611 KB
Summary
This page from a legal filing (Case 1:20-cr-00330-PAE) argues for the right of victims named Sarah and Elizabeth to read their Victim Impact Statements at Ghislaine Maxwell's sentencing. It details the severe psychological and physical trauma suffered by both victims, including suicide attempts and hospitalizations, resulting from the 'Epstein/Maxwell trap.' The document cites the Crime Victim’s Rights Act (CVRA) and relevant case law to support the victims' right to be heard.
People (5)
| Name | Role | Context |
|---|---|---|
| Sarah | Victim |
Described the Epstein/Maxwell dynamic as 'Hotel California', attempted suicide twice, submitted a Victim Impact State...
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| Elizabeth | Victim |
Suffered mental breakdowns, unable to hold a job, submitted a Victim Impact Statement.
|
| Ghislaine Maxwell | Defendant |
Subject of the sentencing hearing; described as creating a 'trap' with Epstein.
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| Jeffrey Epstein | Perpetrator |
Mentioned in the context of the 'Epstein/Maxwell quid pro quo' and 'trap'.
|
| Robert Y. Lewis | Declarant |
Submitted a declaration dated June 23, 2022, referenced in the text.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Probation Office |
Recipient of the Victim Impact Statements for the Presentence Investigation Report.
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| Department of Justice (DOJ) |
Implied by the footer code 'DOJ-OGR'.
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| United States District Court |
Implied by the case header and references to 'the Court'.
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Timeline (2 events)
Locations (2)
| Location | Context |
|---|---|
|
Metaphor used by victim Sarah to describe the inability to leave the Epstein/Maxwell situation.
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General location where Sarah was treated after suicide attempts and Elizabeth for breakdowns.
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Relationships (3)
Epstein/Maxwell quid pro quo
victim of Maxwell’s conspiracy crimes
extricating themselves physically from the Epstein/Maxwell trap
Key Quotes (3)
"Sarah described the Epstein/Maxwell quid pro quo as the 'Hotel California;' you can check-out any time you like, but you can never leave."Source
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Quote #1
"After being a victim of Maxwell’s conspiracy crimes, Sarah attempted suicide twice, both times ending up in the hospital with serious physical injuries."Source
DOJ-OGR-00010694.jpg
Quote #2
"The Crime Victim’s Rights Act (“CVRA”) defines the term 'crime victim' as a 'person directly and proximately harmed as a result of the commission of a Federal offense....'"Source
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Quote #3
Full Extracted Text
Complete text extracted from the document (1,844 characters)
Case 1:20-cr-00330-PAE Document 675 Filed 06/25/22 Page 3 of 21
activity was demanded in return. And soon the sex overcame everything else. Sarah described the
Epstein/Maxwell quid pro quo as the “Hotel California;” you can check-out any time you like, but
you can never leave.
Epstein/Maxwell quid pro quo as the “Hotel California;” you can check-out any time you like, but
you can never leave.
Both VISs provide relevant background information regarding Maxwell’s character and
conduct. Both statements further describe that for many years after finally extricating themselves
physically from the Epstein/Maxwell trap, they suffered serious mental and physical illnesses.
Elizabeth discusses numerous hospitalizations for mental breakdowns and being unable to hold
down a job. After being a victim of Maxwell’s conspiracy crimes, Sarah attempted suicide twice, both
times ending up in the hospital with serious physical injuries.
conduct. Both statements further describe that for many years after finally extricating themselves
physically from the Epstein/Maxwell trap, they suffered serious mental and physical illnesses.
Elizabeth discusses numerous hospitalizations for mental breakdowns and being unable to hold
down a job. After being a victim of Maxwell’s conspiracy crimes, Sarah attempted suicide twice, both
times ending up in the hospital with serious physical injuries.
Both Sarah and Elizabeth have submitted VISs to the probation office for inclusion in the
Presentence Investigation Report. See Declaration of Robert Y. Lewis, dated June 23, 2022.
Presentence Investigation Report. See Declaration of Robert Y. Lewis, dated June 23, 2022.
For the reasons set forth below, the Court should allow Sarah and Elizabeth to read their
victim impact statements at Maxwell’s sentencing hearing.
victim impact statements at Maxwell’s sentencing hearing.
ARGUMENT
I. These Victims Have a Statutory Right to be Heard Under the Crime Victim’s Rights Act
The Crime Victim’s Rights Act (“CVRA”) defines the term “crime victim” as a “person
directly and proximately harmed as a result of the commission of a Federal offense....” 18 U.S.C.
§ 3771(e). This definition was based on earlier restitution statutes which “all demonstrate a clarion
congressional intent to provide restitution to as many victims and in as many cases as possible.”
United States v. Martin, 128 F.3d 1188, 1190 (7th Cir. 1997) (quoted in United States v. Kamuvaka,
719 F.Supp.2d 469, 475 (E.D. Pa. 2010)). In relying on these far–reaching statutes to craft the
directly and proximately harmed as a result of the commission of a Federal offense....” 18 U.S.C.
§ 3771(e). This definition was based on earlier restitution statutes which “all demonstrate a clarion
congressional intent to provide restitution to as many victims and in as many cases as possible.”
United States v. Martin, 128 F.3d 1188, 1190 (7th Cir. 1997) (quoted in United States v. Kamuvaka,
719 F.Supp.2d 469, 475 (E.D. Pa. 2010)). In relying on these far–reaching statutes to craft the
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DOJ-OGR-00010694
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