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Case 1:20-cr-00330-PAE Document675 Filed 06/25/22 Page19of 21 the dozens and dozens of other co—conspirators who were an essential part of the Maxwell/Epstein conspiracy to sexually abuse dozens and dozens of young women and girls. Sarah and Elizabeth are entitled to read aloud their victim impact statements at Maxwell’s criminal sentencing. Victim impact statements can help the Court understand the “effect of the offense on the victim and the victim’s family, and may include oral testimony|.|” See United States v, Wilson, 493 F. Supp. 2d 364, 393 (E.D.N.Y. 2006) quoting 18 U.S.C. § 3593(a). Courts have allowed sentencing determinations to consider “oral or written testimony from close family members regarding victims and the direct impact” of the harm. Kelly v, California, 555 U.S. 1020 (2008) quoting Blume, Ten Years of Payne: Victim Impact Evidence in Capital Cases, 88 Cornell L.Rev. 257, 271-272 (2003) (collecting cases). Courts have also considered poems, photographs, hand-crafted items, and even multimedia video presentations. /d. Sarah’s and Elizabeth’s request to provide oral testimony should not be denied. Allowing Maxwell’s victims to speak will cause no unfair prejudice to Maxwell. As explained above, this Court clearly possesses the authority under 18 U.S.C. § 3661 to obtain any information that may be relevant to sentencing. Maxwell will have an opportunity to respond through her counsel to any information the victims provide.® The Court can then sift through all the information to determine what is relevant in imposing Maxwell’s sentence. The Court should err on the side of ° Maxwell’s response cannot include cross—examining the victims. See Paul G. Cassell & Edna Erez, Victim Impact Statements and Ancillary Harm: The American Perspective, 15 CANADIAN CRIM. L. REV. 150, 169-70 (2011) (“Federal courts have consistently held that full confrontation rights do not extend to sentencing, a ruling that would implicitly block cross—examination of victims at federal sentencing hearings.”). 19 DOJ-OGR-00010710