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Case 1:20-cr-00330-PAE Document675 Filed 06/25/22 Page 2of21 information concerning the background, character, and conduct of a person convicted of an offense which a court of the United States may receive and consider for the purpose of imposing an appropriate sentence.”). Two of Maxwell’s victims, Sarah Ransome and Elizabeth Stein, seek to assist the Court in exercising this authority by providing oral VISs at sentencing. The Court should allow these victims to present their statements detailing the impact of Maxwell’s crimes on them to advance the cause of justice. FACTUAL BACKGROUND As the extensive evidence at trial has revealed, Maxwell was involved in a far-reaching long— running sex trafficking conspiracy. As the Court recently explained, Maxwell was found guilty after a lengthy jury trial of a “decade-long unlawful agreement with the Defendant’s continuous coconspirator, Jeffrey Epstein. The overarching conspiracy—which, as the Government argued and proved at trial, employed a single ‘playbook’ to groom and sexually abuse underage girls—constitutes a single conspiracy offense with multiple victims.” (Dkt. 657 at 2-3). Now, Maxwell is to be sentenced for her criminal involvement in this expansive conspiracy. The victims clearly have a right to be heard as part of this process. Both moving victims, Sarah and Elizabeth, came to New York as young women seeking to matriculate at the Fashion Institute of Technology and then work in the fashion industry. Both became targets of Epstein and Maxwell who preyed on their vulnerabilities including their desire to advance in the competitive fashion industry, their relative youth, and naiveté. Epstein and Maxwell promised them that they would use their connections in the fashion industry to advance the victims’ educations and careers. But there was a cruel catch. For every favor or promise of a favor, sexual DOJ-OGR-00010693