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Case 1:20-cr-00330-PAE Document663_ Filed 06/15/22 Page 20 of 77 Nor can general deterrence be used to justify a harsh sentence for Ms. Maxwell. Probation identifies two groups of potential offenders who will purportedly be deterred from committing future crimes as a result of Ms. Maxwell’s sentence: (1) sexual predators who exploit and degrade minor victims and (2) “untouchable individuals who feel their privilege and affluence entitle them to victimize others without fear or consequence.” PSR at 67. With regard to the first group, courts have expressed legitimate doubt as to whether people who have a sexual predilection for minors can be deterred at all. See, e.g., United States v. D.M., 942 F. Supp. 2d 327, 346 (E.D.N.Y. 2013) (“[T]he compulsive behavior and disorders motivating many offenders is less susceptible to general deterrence.”). With regard to the second group, the purported justification sweeps far too broadly. Rather than identify a particular class of similarly situated defendants who will be deterred from committing specific crimes, Probation essentially makes the sweeping assertion that a harsh sentence for Ms. Maxwell is necessary to deter rich people from exploiting poor people. See PSR at 67. That is not the purpose of general deterrence and should not be given any weight in determining the appropriate sentence. A Below Guidelines Sentence Would Provide Just Punishment, Promote Respect for the Law, and Avoid Unwarranted Sentencing Disparities While the offense conduct is indisputably serious, the record reflects that Epstein was the main offender. Given the foregoing discussion, a shorter term of incarceration for Ms. Maxwell best serves the long-term goals of punishment. A significantly below-guidelines sentence in this case would also promote respect for the law by demonstrating that the justice system considers each person who comes before the Court as an individual. A sentence tailored to Ghislaine Maxwell’s particular circumstances—would appropriately distinguish between this defendant and more culpable individuals similarly charged. See United States v. Dorvee, 616 F.3d 174, 187 (2d Cir. 2010) (“[C]Jourts must guard against unwarranted similarities among sentences for defendants 19 DOJ-OGR-00010466