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Case 1:20-cr-00330-PAE Document670 - Filed 06/22/22 Page53 of 55 Money is a key theme underlying the criminal conduct in this case. The defendant’s access to wealth enabled her to present herself as a supposedly respectable member of society, who rubbed shoulders with royalty, presidents, and celebrities. That same wealth dazzled the girls from struggling families who became the defendant and Epstein’s victims. That same wealth enabled the defendant and Epstein to hire a parade of staff to transport victims and maintain the fabulous properties where those victims were abused. That same wealth motivated the defendant to make sure that Epstein’s repulsive desire for sexual contact with teenage girls was always met. That wealth was the defendant’s reward. The defendant has lived a life of extraordinary privilege, and she profited from her relationship with Epstein. It is only right that she should suffer some small financial penalty for the incalculable harm she has caused. The defense’s submissions to the Probation Office suggest that the defendant is attempting to make the outrageous claim that she cannot afford a fine. (Dkt. 106). This Court has already found that the defendant has attempted to conceal the full extent of her assets in connection with this case. After getting caught in her lie to Pretrial Services that her only asset was her London townhouse, the defendant provided a very different picture when seeking bail in December 2020. The breakdown of the defendant’s finances provided then demonstrated that the defendant is a remarkably wealthy woman. (See Dkt. No. 97, Ex. O). That wealth appears to have primarily come from Epstein. The primary source of funds reflected in that financial breakdown was the sale of the defendant’s Manhattan townhouse. Kate testified at trial that the defendant told Kate that Epstein obtained the New York townhouse for the defendant. (Tr. 1194). Additionally, the evidence at trial demonstrated that Epstein transferred a total of approximately $23 million to the defendant. (PSR § 23). The defendant’s dishonesty surrounding her finances is an aggravating factor weighing in favor of an above-Guidelines fine in this case. The defendant’s assets range in 51 DOJ-OGR-00010588