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Case 1:20-cr-00330-PAE Document 663 _ Filed 06/15/22 Page2of77 On behalf of our client, Ghislaine Maxwell, we respectfully submit this memorandum in connection with sentencing, which is scheduled for June 28, 2022. As set forth below, we request that the Court grant Ms. Maxwell a significant variance below the advisory Sentencing Guidelines range of 292 - 365 months and below the 240-month sentence recommended by the Probation Department (“Probation’’). Ghislaine Maxwell stands before the Court because of her association with Jeffrey Epstein decades ago in the 1990s and early 2000s. Never before that time and never again in the roughly 20-year period since the conduct underlying this case occurred has Ms. Maxwell ever been accused of a crime, much less a scheme to sexually abuse minors. The witnesses at trial testified about Ms. Maxwell’s facilitation of Epstein’s abuse, but Epstein was always the central figure: Epstein was the mastermind, Epstein was the principal abuser, and Epstein orchestrated the crimes for his personal gratification. Indeed, had Ghislaine Maxwell never had the profound misfortune of meeting Jeffrey Epstein over 30 years ago, she would not be here. Epstein avoided a significant sentence when he was first prosecuted in Florida for these offenses and then evaded any further punishment by dying a month after his arrest and detention in New York. But this Court cannot sentence Ms. Maxwell as if she were a proxy for Epstein simply because Epstein is no longer here. Ms. Maxwell cannot and should not bear all the punishment for which Epstein should have been held responsible. Ms. Maxwell has already experienced hard time during detention under conditions far more onerous and punitive than any experienced by a typical pretrial detainee, and she is preparing to spend significantly more time behind bars. Her life has been ruined. Since Epstein’s death, her life has been threatened and death DOJ-OGR-00010448