This legal document, part of a court filing, argues for a significant prison sentence (360 to 660 months) for a defendant convicted of sexually exploiting underage girls. It refutes the defendant's arguments for a lighter sentence by citing legal precedents (Stinson, Sash) that prioritize the plain text of sentencing guidelines over conflicting commentary. A footnote dismisses the defendant's comparison of her potential sentence to that of Epstein's as a flawed argument based on different guideline structures.
This legal document, part of a court filing, argues that a defendant's actions satisfy the requirements for a 'covered sex crime' under the U.S. Sentencing Guidelines. The prosecution asserts that the defendant engaged in a pattern of prohibited sexual conduct, including transporting victims (Jane) and non-consensual touching (Jane and Carolyn), justifying a sentencing enhancement. The document refutes the defendant's claim that the guideline is inapplicable, citing case law and the original congressional intent to ensure lengthy incarceration for such offenders.
This legal document, part of a court filing, argues for a sentencing enhancement against the defendant, identified as Maxwell. It presents evidence of her leadership role in a criminal conspiracy, citing her authority over an associate named Kellen, which is supported by flight records on Epstein's planes and her delegation of illicit tasks. The document then justifies a specific two-point "Undue Influence" enhancement by referencing U.S. Sentencing Guidelines concerning crimes where an adult participant influences a minor.
This document is a page from a legal filing (likely a government sentencing memorandum) arguing for sentencing enhancements for Ghislaine Maxwell. It details her role as an 'organizer' and 'second in command' who supervised Epstein's staff (including pilots Visoski and Rodgers and house manager Alessi) and directed the activities of Sarah Kellen and victims like Virginia and Carolyn. The text cites trial testimony to establish that Maxwell ran an extensive operation facilitating Epstein's abuse of minors.
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