DOJ-OGR-00010711.jpg

Case 1:20-cr-00330-PAE Document675_ Filed 06/25/22 Page 20of21 receiving the most information possible in making its sentencing decision and allow all the victims of all Maxwell’s sex trafficking crimes to speak. IV. If the Court Does Not Believe that Sarah and Elizabeth Are Entitled to be Heard at Sentencing, They Should Be Given Additional Time to Brief and Argue the Issue For all the reasons just explained, Sarah and Elizabeth believe that they have established entitlement to deliver their victim impact statements at Maxwell’s sentencing. But if, for any reason, the Court has doubts about this issue, Sarah and Elizabeth respectfully request additional time to develop factual and legal arguments in support of their position. Sarah and Elizabeth have had just 48 hours to respond to the Court’s June 21* order setting out procedures for briefing this issue. Such a short time frame has deprived them of an opportunity to develop both factual and legal arguments supporting their position. The Court should give them additional time to develop their position. CONCLUSION For all these reasons, the Court should allow Sarah and Elizabeth to orally deliver their victim impact statements at Maxwell’s sentencing or, in the alternative, provide them with additional time to further brief this issue. Dated: June 23, 2022 New York, New York 20 DOJ-OGR-00010711