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Case 1:20-cr-00330-PAE Document675 Filed 06/25/22 Page3of21 activity was demanded in return. And soon the sex overcame everything else. Sarah described the Epstein/Maxwell quid pro quo as the “Hotel California;” you can check-out any time you like, but you can never leave. Both VISs provide relevant background information regarding Maxwell’s character and conduct. Both statements further describe that for many years after finally extricating themselves physically from the Epstein/Maxwell trap, they suffered serious mental and physical illnesses. Elizabeth discusses numerous hospitalizations for mental breakdowns and being unable to hold down a job. After being a victim of Maxwell’s conspiracy crimes, Sarah attempted suicide twice, both times ending up in the hospital with serious physical injuries. Both Sarah and Elizabeth have submitted VISs to the probation office for inclusion in the Presentence Investigation Report. See Declaration of Robert Y. Lewis, dated June 23, 2022. For the reasons set forth below, the Court should allow Sarah and Elizabeth to read their victim impact statements at Maxwell’s sentencing hearing. ARGUMENT I. These Victims Have a Statutory Right to be Heard Under the Crime Victim’s Rights Act The Crime Victim's Rights Act (“CVRA”) defines the term “crime victim” as a “person directly and proximately harmed as a result of the commission of a Federal offense....” 18 U.S.C. § 3771(e). This definition was based on earlier restitution statutes which “all demonstrate a clarion congressional intent to provide restitution to as many victims and in as many cases as possible.” United States v. Martin, 128 F.3d 1188, 1190 (7th Cir. 1997) (quoted in United States v. Kamuvaka, 719 ESupp.2d 469, 475 (E.D. Pa. 2010)). In relying on these far-reaching statutes to craft the DOJ-OGR-00010694