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Case 1:20-cr-00330-PAE Document 681-1 Filed 06/26/22 Page 2 of 7 FACTUAL BACKGROUND At this point in the proceedings, it is clear the defendant Maxwell was involved in a far- reaching sex trafficking conspiracy. Defendant Maxwell was found guilty by a jury of a “decade- long unlawful agreement with the Defendant’s continuous coconspirator, Jeffrey Epstein. The overarching conspiracy—which, as the Government argued and proved at trial, employed a single ‘playbook’ to groom and sexually abuse underage girls—constitutes a single conspiracy offense with multiple victims.” DE 657 at 2-3. Now, defendant Maxwell is to be sentenced for her criminal involvement in this far-research conspiracy. Kate clearly has a right to be heard as part of that process. As this Court is aware, Kate was recognized in this case as a crime victim of a federally charged criminal conspiracy against Ghislaine Maxwell for acts that Maxwell committed against Kate when she was seventeen years old. While there was a limiting instruction during the trial, clarifying that the jury was not permitted to find Maxwell guilty of any crime charged committed against Kate, she provided powerful and credible testimony of her interactions with Maxwell, which viewed in any objective light clearly demonstrate she was the victim of Maxwell’s grooming that led to years of sexual abuse at the hands of Jeffrey Epstein. Kate courageously took the stand to share her experiences with the jury and was subject to the severe stress of a harsh cross- examination. Having endured such risk and emotional expense to ensure the jury had a full picture and was able to render a just verdict, Kate is deserving of the opportunity to return and speak at this important stage for the benefit of the Court and the catharsis she will likely experience from providing her valuable insight at this stage where she can speak without the anxiety of being attacked by opposing counsel. No doubt, Kate has important insight into Maxwell’s role in a sex- trafficking organization, the type that is helpful for any Court tasked with determining an appropriate sentence. DOJ-OGR-00010738