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Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 37 of55 crimes. For the reasons set forth below, the nature and seriousness of the offense weigh in favor of a Guidelines sentence, in light of the role the defendant played in the conspiracy and the irreparable harm the defendant caused to her victims. The Defendant’s Role in the Conspiracy Maxwell’s conduct was shockingly predatory. She was a calculating, sophisticated, and dangerous criminal who preyed on vulnerable young girls and groomed them for sexual abuse. Although there are many unsettling aspects of the defendant’s conduct, what stands out from the trial record is that she worked with Epstein to select victims who she knew were vulnerable to exploitation. As the trial record establishes, Maxwell met Jane shortly after her father passed away, and her family was struggling to make ends meet. Annie’s mother was struggling to raise her daughters alone. Carolyn was living alone with her mother, who was an addict. It is not a coincidence that all of Maxwell’s victims came from single-mother households. Not only did her conduct exhibit a callous disregard for other human beings, but her practice of targeting vulnerable victims reflects her view that struggling young girls could be treated like disposable objects. Once the victims were selected, Maxwell played an essential role in the conspiracy by grooming victims for abuse. Maxwell did this by forging trust with her victims so that they could be sexually exploited. As Dr. Rocchio explained, the psychological harms of sexual abuse are greater where, as here, the abuse arises from a relationship of trust with the abuser: Trust is central often in the treatment of someone who’s been sexually abused, because it’s often the part that is most confusing and also causes the most — the most harm. We know that the more they trusted the individual, then, of course, the more they feel betrayed, the more betrayal there’s been. And to the extent there’s been betrayal in the relationship, then the individuals are really struggling to a much, much greater degree, often trying to 35 DOJ-OGR-00010572