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Case 1:20-cr-00330-PAE Document675 Filed 06/25/22 Page6of21 Against this backdrop, Sarah and Elizabeth are categorial “victims” who should be allowed. to speak at sentencing. Sexual abusers frequently use their actual or perceived power to manipulate and coerce victims during their abuse or trafficking. Jill Laurie Goodman & Dorchen A. Leidholdt, Lawyers Manual on Human Trafficking, NY State Jud. Comm. on Women in the Court 169-76 (2013). The scheme Sarah and Elizabeth both describe in their victim impact statements is the same scheme Maxwell is being sentenced for and it involves the same defendant and co-conspirators as the conspiratorial scheme proven at trial. Moreover, these victim statements reflect Sarah’s and Elizabeth's personal knowledge of Maxwell’s character and actions in furtherance of the scheme. Maxwell’s argument that Sarah and Elizabeth do not qualify as real victims because they were not minors at the time of the trafficking and therefore are not victims within the counts of conviction is of no moment. The allegations in the second superseding indictment easily encompasses these non—minor victims. For example, in paragraph 4(e) of the second superseding indictment, which is a sub-part of a count for which there was a conviction, alleges that “through this process, Maxwell and Epstein enticed victims to engage in sexual activity with Epstein.” Likewise, paragraph 9 of the second superseding indictment alleges that “among the victims induced or enticed by GHISLAINE MAXWELL, the defendant, were minor victims identified herein as Minor Victim—1, Minor Victim—2, Minor Victim—3 and Minor Victim—4.” A fair reading of the indictment is that although it emphasizes minor victims, the sex trafficking conspiracy—as alleged—encompassed non—minor victims like Sarah and Elizabeth. DOJ-OGR-00010697