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Case 1:20-cr-00330-PAE Document670 _ Filed 06/22/22 Page 45of55 for exactly what it is: a desperate attempt to shift the blame for her own crimes and distract from the gravity of her offense conduct. In short, the defendant has lied repeatedly about her crimes, exhibited an utter failure to accept responsibility, and demonstrated repeated disrespect for the law and the Court. The defendant’s history and characteristics weigh in favor of a Guidelines sentence. 3. The Need to Promote Respect for the Law and to Afford Adequate Deterrence The importance of promoting respect for the law and affording adequate deterrence further supports imposing a sentence within the Guidelines range. Given the magnitude, breadth, and sophistication of the conduct in this case, those interests are best served by a significant term of imprisonment. The defendant’s pattern of exploitative conduct, and her lies to evade responsibility for her crimes, should be met with punishment that holds her accountable for the full measure of her criminal conduct and the abuse and horror for which she is responsible. A Guidelines sentence would also deter those who would facilitate sexual abusers in positions of power. As the Government has emphasized throughout this case, Jeffrey Epstein could not have committed these crimes without the defendant. The defendant, an adult woman, was able to provide a cover of respectability to Epstein that lulled the victims and their families into a false sense of security. This case sends the important message that those who would conspire with sexual predators will be held responsible for their significant role in these crimes. Accordingly, a Guidelines sentence is necessary to afford deterrence. The lenient sentence the defendant seeks would send the message that there is one system of laws for the rich and powerful, and another set for everyone else. It would also send the message to victims that, even if they have the courage to report their abusers and undergo the excruciating experience of testifying in court, there will be no meaningful accountability. As the Probation 43 DOJ-OGR-00010580