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Case 1:20-cr-00330-PAE Document672 Filed 06/24/22 Page 6 of 68 LAW OFFICES OF BOBBI C. STERNHEIA\ government concerning Ms. Giuffre’s significant credibility problems See Exhibits H and I. Ms. Giuffre’s impact statement, while admissible under the CVRA, should be redacted and the letters challenging her credibility should be made part of the record in this case. The process for a sentencing court to receive and utilize victim impact information from statutory crime victims and other affected persons must be consistent with a defendant's due process rights: the right not to be sentenced based upon materially false information (see Townsend v. Burke, 334 U.S. 736, 741 (1948)) and the right to be sentenced based upon accurate information, as safeguarded by Federal Rule of Criminal Procedure 32. There are potential Sixth Amendment Booker concerns if the definition of statutory “crime victim” under the CVRA is interpreted so broadly that it is not based upon the offense established by the jury verdict. The Victim Impact Statements Should Be Redacted The Individuals are not “crime victims” of the charged federal offenses under the CVRA. Their victim impact statements are unduly prejudicial, contain allegations not previously before the Court which serve to inflame the emotions of the Court and public. Their airing during sentencing or any consideration by the Court in imposing sentence, would violate Ms. Maxwell’s due process rights. We object to the publication of the impact statement of the Individuals. However, should the Court permit the inclusion of these victim impact statements in connection with the sentencing proceeding, we request that portions be redacted, including but not limited to statements that would have been precluded under Rule 412, medical conditions claimed to have “The Billionaire’s Playboy Club.” See Giuffre v. Maxwell, 18-2868 (2d Cir.) Dkt. 278, Exhibit KK at 563-646. Ms. Giuffre lived with Eppinger for approximately 6 months when he ran a front business for international sex trafficking known as the modeling agency "Perfect 10". He was prosecuted in the Southern District of Florida and pleaded guilty to charges of alien smuggling for prostitution, interstate travel for prostitution, and money laundering. See United States v. Eppinger, 00 Cr. 131 (FAM)(SD-FL) DOJ-OGR-00010597