USA v. Maxwell — Government Sentencing Memorandum

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK S1 20 Cr. 330 (AJN) UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. GOVERNMENT'S SENTENCING MEMORANDUM The Government respectfully submits this memorandum in connection with the sentencing of defendant Ghislaine Maxwell, who was convicted by a unanimous jury on December 29, 2021, of conspiracy to entice minors to travel to engage in illegal sex acts, conspiracy to transport minors with intent to engage in criminal sexual activity, transportation of a minor with intent to engage in criminal sexual activity, conspiracy to commit sex trafficking of minors, and sex trafficking of a minor. INTRODUCTION For over a decade, the defendant sexually exploited and abused dozens of young girls, some as young as 14 years old. She did so in partnership with Jeffrey Epstein, using a well-rehearsed and calculated playbook designed to lure vulnerable victims into Epstein's orbit and normalize sexual abuse. SENTENCING GUIDELINES CALCULATION The Government calculates the applicable Sentencing Guidelines range as follows: Base offense level for sex trafficking of minors: 34 Specific Offense Characteristics: +2 for use of a computer (§ 2G1.3(b)(3)) +2 for undue influence over a minor victim (§ 2G1.3(b)(2)(B)) +4 for offense involving 2 or more minors (§ 2G1.3(b)(4)) +5 for pattern of activity involving prohibited sexual conduct (§ 4B1.5(b)(1)) +2 for obstruction of justice (§ 3C1.1) Adjusted Offense Level: 49 (capped at 43) Criminal History Category: I Guidelines Range: Life imprisonment RECOMMENDED SENTENCE The Government recommends a sentence within the range of 360 to 660 months' imprisonment (30 to 55 years). This recommendation reflects the seriousness of the defendant's conduct, the devastating impact on her victims, the need for deterrence, and the need to protect the public. VICTIM IMPACT Multiple victims submitted impact statements detailing the lasting trauma of Maxwell's abuse. Victims described how Maxwell's grooming and manipulation permanently altered the trajectory of their lives, leading to depression, anxiety, substance abuse, difficulty maintaining relationships, and persistent feelings of shame and distrust. CONCLUSION For the foregoing reasons, the Government respectfully requests that this Court impose a sentence of between 30 and 55 years' imprisonment. Filed: June 22, 2022 Source: U.S. Department of Justice, SDNY Available at: https://www.justice.gov/usao-sdny/united-states-v-ghislaine-maxwell