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Case 1:20-cr-00330-PAE Document672 Filed 06/24/22 Page1of68 LAW OFFICES OF BOBBI C. STERNHEIA\ 212-243-1100 * Main 225 Broadway, Suite 715 917-912-9698 ° Cell New York, NY 10007 888-587-4737 ° Fax besternhein@mac.com June 24, 2022 Submission Under Seal Honorable Alison J. Nathan Sitting By Designation United States District Court 40 Foley Square New York, NY 10007 Re: United States v. Ghislaine Maxwell S2 20 Cr. 330 (AJN) Dear Judge Nathan: Ghislaine Maxwell submits this letter in response to the Court’s order (Dkt. 665). Ms. Maxwell objects to characterization of Sarah Ransome, Maria Farmer, Teresa Helm, and Juliette Bryant (collectively, the "Individuals") as "victims" of the counts of conviction and disputes that the Individuals qualify as statutory victims within the definition of a "crime victim" contained in the Crime Victims' Rights Act, 18 U.S.C.A. §3771 ("CVRA"). The issue that requires resolution in advance of sentencing is whether the Individuals, or their representatives, have statutory crime victim status under the CVRA. Under the statute, definition of “crime victim” takes as a given that there has been a “federal offense” committed. See 18 U.S.C. § 3771(e)(2)(A). Ms. Maxwell asserts that the Individuals are not statutory crime victims of the federal offenses of conviction, which require that (1) each was a minor at the time to the alleged abuse, (11) the alleged abuse occurred during the period alleged in the indictment, and (iii) the Individuals were “directly and proximately harmed as a result of the commission of [the] Federal offense.” /d.(emphasis added). DOJ-OGR-00010592