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Case 1:20-cr-00330-PAE Document675_ Filed 06/25/22 Page11of21 Elizabeth respectfully submit that hearing their unique “information concerning the background, character, and conduct” of Maxwell will assist the Court in imposing a fair and just sentence. A good illustration of these principles comes from the Seventh Circuit’s decision in United States v. Salutric, 775 F.3d 948, 951-52 (7th Cir. 2015). In that case, the Seventh Circuit observed that “[i]n arriving at an appropriate sentence, a sentencing judge necessarily must consider not only the offense of conviction but the defendant's broader criminal record and history.” /d. at 951. This point follows from the rationale that “[u]ncharged criminal acts (and the injuries inflicted upon the victims of those acts) have a bearing on whether the offense of conviction was an aberration or part of a larger pattern of criminal behavior, the likelihood of the defendant re-offending, and the need for specific deterrence.” /d., See also United States v. Laraneta, 700 F.3d 983, 987 (7th Cir. 2012). The Seventh Circuit explained that the federal “Criminal Code makes clear that ‘[n]o limitation shall be placed on the 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’.” 775 at 952 (quoting 18 U.S.C. § 3661). This Court should follow the same approach and hear from all victims of Maxwell’s long— running and. wide-ranging sex trafficking conspiracy. See also United States v. Goss, 325 F. Supp. 3d 932, 936 (E.D. Wis. 2018) (affirming the court’s consideration of information at sentencing that was not, strictly speaking, a “victim” impact statement because the “court can consider information from a variety of sources” when imposing sentence). Matters of social welfare directly impact decisions regarding the appropriateness of a criminal sentence. Krebs v. New York State Div. of Parole, No. 9:08- CV-255NAMDEP, 2009 WL 2567779, at *2 (N.D.N.Y. Aug. 17, 2009) (allowing consideration of 11 DOJ-OGR-00010702