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Case 1:20-cr-00330-PAE Document670 Filed 06/22/22 Page4of55 Given the exceptionally serious nature of the defendant’s years-long participation in the sexual abuse of minors, consideration of the relevant factors under 18 U.S.C. § 3553(a) weighs heavily in favor of a sentence within the Guidelines range of 360 to 660 months’ imprisonment. Most significantly, the nature and seriousness of the offense, the harm to victims, the need to promote respect for the law, and the history and characteristics of the defendant weigh heavily in favor of a Guidelines sentence. The Government addresses each of these factors in turn below. However, certain aspects of the defendant’s submission bear addressing up front. First, the Court should reject the defendant’s request for a reduced sentence in light of conditions at the Metropolitan Detention Center. The defendant’s claims are inaccurate—and in fact, the defendant has enjoyed remarkable privileges as a high-profile inmate that vastly exceed the benefits accorded to the average inmate. It is unsurprising that a woman who had led a life of incredible luxury should complain about her life as a prisoner, but that fact does not come close to meriting leniency at sentencing, much less the extraordinary degree of leniency the defendant seeks. If anything stands out from the defendant’s sentencing submission, it is her complete failure to address her offense conduct and her utter lack of remorse. Instead of showing even a hint of acceptance of responsibility, the defendant makes a desperate attempt to cast blame wherever else she can. On that score, the defendant’s attempt to cast aspersions on the Government for prosecuting her, and her claim that she is being held responsible for Epstein’s crimes, are both absurd and offensive. Maxwell was an adult who made her own choices. She made the choice to sexually exploit numerous underage girls. She made the choice to conspire with Epstein for years, working as partners in crime and causing devastating harm to vulnerable victims. She should be held accountable for her disturbing role in an extensive child exploitation scheme. DOJ-OGR-00010539