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be N Ww ws Oo OY ~] oO WO a oO = be N Ww = Hs Oo a OY a ~] a oO a Ke) 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 737 Filed 07/22/22 Page 90of101 90 M6s2Max2 Turning to that conduct, the punishment here must reflect the seriousness of the offense, promote respect for the law, provide just punishment for the offense, and deter. First, as to the seriousness, the defendant's conduct was, as aptly described by the probation department, heinous and predatory. Ms. Maxwell worked with Epstein to select young victims who were vulnerable. Once selected, Ms. Maxwell played a pivotal role in facilitating the abuse of the underaged girls through a series of deceptive tactics. A sophisticated adult woman, she provided an initial venire of responsibility and even safety. She befriended and developed relationships of trust. She then manipulated the victims and normalized sexual abuse through her involvement, encouragement, and instruction. To give one example from trial, Jane testified that Ms. Maxwell cultivated a friendship with her, took her to movies and shopping. In an initial sexual interaction, while Jane was 14 years old, the defendant engaged in sexual conduct with Epstein while Jane was present. After that, the defendant instructed Jane, again, while she was only 14 years old, on how to massage Epstein, including instructions on how to touch his penis during massages. The abuse later escalated to Epstein using vibrators on Jane, penetrating her with his fingers. During some of the sexual abuse, the defendant would herself touch Jane's breasts. Carolyn, the victim of the sex trafficking charge, SOUTHERN DISTRICT REPORTERS, P.C.» (212) 805-0300 DOJ-OGR-00011609