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Case 1:20-cr-00330-PAE Document 663 _ Filed 06/15/22 Page3of77 threats continue while she is incarcerated.' It would be a travesty of justice for her to face a sentence that would have been appropriate for Epstein. In its Final Presentence Investigation Report (“PSR”), Probation recommended a sentence of 240 months’ imprisonment, a slight downward variance from the sentence recommended by the advisory Guidelines. We have submitted objections directly to Probation which are amplified in an accompanying submission.* We respectfully submit that in light of the circumstances discussed below, including extraordinary punitive conditions of solitary confinement and the ongoing COVID-19 pandemic, a sentence below the 240 months recommended by Probation would be “sufficient, but not greater than necessary” to achieve the objectives of sentencing articulated in 18 U.S.C. § 3553(a). The Context of the Case This is not the first time the events in this case were investigated and resolved. This case is a revival of a prosecution commenced in the Southern District of Florida (“SDFL”) against Epstein, which resulted in a state court conviction pursuant to a non-prosecution agreement. The plea and sentence were negotiated without notice to Epstein’s victims. The “sweetheart” deal created an uproar among his victims and the public, which was fueled by and featured in on-going coverage in The Miami Herald. The public outcry led to removal of Alexander Acosta from his cabinet post as Secretary of Labor for his role as U.S. Attorney for SDFL overseeing the Epstein ' Most recently, an inmate in Ms. Maxwell’s unit threatened to kill her, claiming that an additional 20 years’ incarceration would be worth the money she’d receive for murdering Ms. Maxwell. See PSR 418. ° See PSR at 46-63 and the accompanying “Memorandum of Ghislaine Maxwell in Support of Her Objections to the Presentence Investigation Report,” filed separately. DOJ-OGR-00010449