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Case 1:20-cr-00330-PAE Document670 Filed 06/22/22 Page3of55 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK FA RE BOR RR RE X UNITED STATES OF AMERICA -V.- i S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. wince ee ns RR RR EERE Xx PRELIMINARY STATEMENT Ghislaine Maxwell played an instrumental role in the horrific sexual abuse of multiple young teenage girls. As part of a disturbing agreement with Jeffrey Epstein, Maxwell identified, groomed, and abused multiple victims, while she enjoyed a life of extraordinary luxury and privilege. In her wake, Maxwell left her victims permanently scarred with emotional and psychological injuries. That damage can never be undone, but it can be accounted for in crafting a just sentence for Maxwell’s crimes. The Government respectfully submits this memorandum in connection with the sentencing of Maxwell in the above-captioned case, which is scheduled for June 28, 2022, and in response to the defendant’s June 15, 2022 sentencing memorandum and objections to the Pre-Sentence Investigation Report prepared by the United States Probation Office. For the reasons set forth below, the Government maintains that under the United States Sentencing Guidelines (the “Guidelines” or “U.S.S.G.”), the applicable sentencing range is 360 months to life imprisonment. Because the statutory maximum penalty is 660 months’ imprisonment, the Guidelines range becomes 360 to 660 months’ imprisonment. DOJ-OGR-00010538