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760 KB
Extraction Summary
4
People
3
Organizations
2
Locations
2
Events
2
Relationships
4
Quotes
Document Information
Type:
Court filing (sentencing memorandum/government submission)
File Size:
760 KB
Summary
This document is a page from a government sentencing memorandum filed on June 22, 2022, in the case against Ghislaine Maxwell. It argues for a significant financial penalty, highlighting that the defendant's wealth—derived largely from $23 million transferred by Jeffrey Epstein and the sale of a Manhattan townhouse—facilitated the abuse of victims and was concealed from Pretrial Services. The text asserts that her dishonesty regarding her assets is an aggravating factor warranting an above-Guidelines fine.
People (4)
| Name | Role | Context |
|---|---|---|
| The Defendant | Accused/Convicted Party |
Refers to Ghislaine Maxwell (implied by case number and context); described as wealthy, dishonest about finances, and...
|
| Jeffrey Epstein | Co-conspirator/Financier |
Described as having a 'repulsive desire for sexual contact with teenage girls' and the source of the defendant's wealth.
|
| Kate | Witness/Victim |
Testified at trial regarding the defendant's statements about the New York townhouse.
|
| Royalty, presidents, and celebrities | Associates |
Groups the defendant rubbed shoulders with to present a facade of respectability.
|
Organizations (3)
| Name | Type | Context |
|---|---|---|
| Probation Office |
Received submissions from the defense regarding the defendant's ability to pay a fine.
|
|
| Pretrial Services |
Agency to which the defendant lied about her assets.
|
|
| The Court |
Found that the defendant attempted to conceal assets.
|
Timeline (2 events)
2022-06-22
Filing of Document 670 in Case 1:20-cr-00330-PAE
Southern District of New York (implied)
Government
Court
Locations (2)
| Location | Context |
|---|---|
|
Property claimed by the defendant to be her only asset in statements to Pretrial Services.
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|
|
Property sold to fund the defendant; obtained by Epstein for the defendant.
|
Relationships (2)
Epstein transferred $23 million to her; she procured victims for him; he bought her a townhouse.
Defendant spoke to Kate about the origin of the NY townhouse.
Key Quotes (4)
"Money is a key theme underlying the criminal conduct in this case."Source
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Quote #1
"That same wealth motivated the defendant to make sure that Epstein’s repulsive desire for sexual contact with teenage girls was always met."Source
DOJ-OGR-00010588.jpg
Quote #2
"Epstein transferred a total of approximately $23 million to the defendant."Source
DOJ-OGR-00010588.jpg
Quote #3
"The defendant’s dishonesty surrounding her finances is an aggravating factor weighing in favor of an above-Guidelines fine in this case."Source
DOJ-OGR-00010588.jpg
Quote #4
Full Extracted Text
Complete text extracted from the document (2,248 characters)
Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 53 of 55
Money is a key theme underlying the criminal conduct in this case. The defendant’s access
to wealth enabled her to present herself as a supposedly respectable member of society, who rubbed
shoulders with royalty, presidents, and celebrities. That same wealth dazzled the girls from
struggling families who became the defendant and Epstein’s victims. That same wealth enabled
the defendant and Epstein to hire a parade of staff to transport victims and maintain the fabulous
properties where those victims were abused. That same wealth motivated the defendant to make
sure that Epstein’s repulsive desire for sexual contact with teenage girls was always met. That
wealth was the defendant’s reward. The defendant has lived a life of extraordinary privilege, and
she profited from her relationship with Epstein. It is only right that she should suffer some small
financial penalty for the incalculable harm she has caused.
to wealth enabled her to present herself as a supposedly respectable member of society, who rubbed
shoulders with royalty, presidents, and celebrities. That same wealth dazzled the girls from
struggling families who became the defendant and Epstein’s victims. That same wealth enabled
the defendant and Epstein to hire a parade of staff to transport victims and maintain the fabulous
properties where those victims were abused. That same wealth motivated the defendant to make
sure that Epstein’s repulsive desire for sexual contact with teenage girls was always met. That
wealth was the defendant’s reward. The defendant has lived a life of extraordinary privilege, and
she profited from her relationship with Epstein. It is only right that she should suffer some small
financial penalty for the incalculable harm she has caused.
The defense’s submissions to the Probation Office suggest that the defendant is attempting
to make the outrageous claim that she cannot afford a fine. (Dkt. 106). This Court has already
found that the defendant has attempted to conceal the full extent of her assets in connection with
this case. After getting caught in her lie to Pretrial Services that her only asset was her London
townhouse, the defendant provided a very different picture when seeking bail in December 2020.
The breakdown of the defendant’s finances provided then demonstrated that the defendant is a
remarkably wealthy woman. (See Dkt. No. 97, Ex. O). That wealth appears to have primarily
come from Epstein. The primary source of funds reflected in that financial breakdown was the
sale of the defendant’s Manhattan townhouse. Kate testified at trial that the defendant told Kate
that Epstein obtained the New York townhouse for the defendant. (Tr. 1194). Additionally, the
evidence at trial demonstrated that Epstein transferred a total of approximately $23 million to the
defendant. (PSR ¶ 23). The defendant’s dishonesty surrounding her finances is an aggravating
factor weighing in favor of an above-Guidelines fine in this case. The defendant’s assets range in
to make the outrageous claim that she cannot afford a fine. (Dkt. 106). This Court has already
found that the defendant has attempted to conceal the full extent of her assets in connection with
this case. After getting caught in her lie to Pretrial Services that her only asset was her London
townhouse, the defendant provided a very different picture when seeking bail in December 2020.
The breakdown of the defendant’s finances provided then demonstrated that the defendant is a
remarkably wealthy woman. (See Dkt. No. 97, Ex. O). That wealth appears to have primarily
come from Epstein. The primary source of funds reflected in that financial breakdown was the
sale of the defendant’s Manhattan townhouse. Kate testified at trial that the defendant told Kate
that Epstein obtained the New York townhouse for the defendant. (Tr. 1194). Additionally, the
evidence at trial demonstrated that Epstein transferred a total of approximately $23 million to the
defendant. (PSR ¶ 23). The defendant’s dishonesty surrounding her finances is an aggravating
factor weighing in favor of an above-Guidelines fine in this case. The defendant’s assets range in
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DOJ-OGR-00010588
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