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Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 38 of 55 understand what happened, how it happened and why, and what its effect is certainly. (Tr. 742-43). Maxwell’s victims trusted her: she was a seemingly respectable woman who showed. interest in them and promised to help them. She was key to the entire operation of the scheme, and Epstein could not have committed these crimes without her. Maxwell befriended her victims, won their trust, slowly broke down their boundaries, and normalized sexual abuse. For example, Jane testified that the defendant showed her how Epstein liked to be massaged and how he liked his penis touched. The defendant did this when Jane was only 14 years old. The defendant was an adult, in her thirties, helping to normalize abusive sexual conduct with a young teenager. The defendant’s demeanor was “casual, like it was — like it was very normal, like it was not a big deal.” (Tr. 309). When Jane was in her twenties, she described Maxwell this way to her boyfriend, who remembered years later how Jane told him that Epstein had abused her, and the defendant had made her feel comfortable. (Tr. 644). The degree to which the defendant manipulated her victims is an aggravating factor in this case. But her abusive conduct did not end with the grooming and manipulation of the victims. She also participated in the sexual abuse of her victims. Not only was Maxwell the person who was most frequently in the room when Epstein abused Jane (Tr. 289), but multiple victims testified that the defendant groped their breasts. (Tr. 310 (Jane), 2224 (Annie), 1536 (Carolyn)). In particular, Annie described a terrifying encounter in which she found herself alone with Maxwell at Epstein’s ranch in New Mexico, and Maxwell told her to remove her clothing so she could give Annie a “massage” during which she rubbed Annie’s breasts. (Tr. 2224; PSR 4 52). That so- called massage was the defendant sexually abusing a teenage girl. The conspiracy in this case was extensive and sophisticated by any metric: it involved multiple victims, at multiple properties in different states, over a span of many years. In order to 36 DOJ-OGR-00010573