DOJ-OGR-00010540.jpg

Case 1:20-cr-00330-PAE Document670 Filed 06/22/22 Page5of55 The Government agrees that the defendant should be sentenced for her own conduct: she committed terrible crimes that caused irreparable harm to vulnerable children. Her own criminal actions demand that she serve every day of a Guidelines sentence in prison. I. Background A. The Investigation The U.S. Attorney’s Office for the Southern District of New York opened its investigation into Jeffrey Epstein and his co-conspirators in late November 2018. The investigation was prompted by investigative journalism, and not, as the defendant claims, by civil litigants who pressed for criminal charges. In light of the covert nature of the investigation, the Government interviewed a small group of witnesses and charged Epstein as soon as it was able to, obtaining an indictment against Epstein approximately six months later, on July 2, 2019, and arresting Epstein on July 6, 2019. (PSR ¥ 21). That initial phase of the investigation remained intentionally narrow in order to keep the circle of people aware of a federal investigation into Epstein small to avoid jeopardizing the investigation before Epstein could be apprehended. The Government’s investigation expanded upon charging Epstein, and several additional victims came forward after the charges were announced. After Epstein’s death in August 2019, the Government continued that same investigation, which included interviewing several victims. Among the victims the Government interviewed were individuals identified on the record in this case as “Jane” and “Kate” (both of whom agreed to be interviewed by the Government for the first time) as well as Annie Farmer. The Government obtained the original Indictment against the defendant—which related to the abuse of Jane, Kate, and Annie Farmer—in late June 2020. In March 2021, the Government obtained a superseding indictment charging the defendant—which added counts relating to the defendant’s abuse of an additional minor victim, Carolyn—based on DOJ-OGR-00010540