This page is from a defense sentencing memorandum filed on June 15, 2022, in the case against Ghislaine Maxwell. The defense argues that Maxwell is not a danger to the community, citing her lack of criminal history outside the charges (20-30 years prior) and her subsequent stable family life. It further argues that a harsh guidelines sentence is unnecessary for deterrence, as she has already lost her marriage and stepchildren and endured pre-sentence incarceration.
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