DOJ-OGR-00021604.pdf

--- Page 1 --- **Document Header:** Case 22-1426, Document 78, 06/29/2023, 3536039, Page174 of 217 **SA-428** **Page Number:** 59 **Text:** M6SQmaxS1 crimes. She has not owned up to the truth. She has lied repeatedly. She has been dishonest with the Court, and she has made misrepresentations when it suits her. Your Honor, we recognize that the Court has calculated the guidelines to be 188 to 235 months. That is far below the sentence that the government believes is appropriate in this case. We recognize that there are a small number of cases where the Court imposes an above-guideline sentence. This is that case, your Honor. In the almost 20 years since the 2003 manual was enacted, our Sentencing Commission, our Congress, and our country have all recognized just how serious sex crimes against children are. Our country now recognizes how woefully inadequate the 2003 guidelines were, and the Supreme Court has expressly held that sentencing courts can vary upwards for exactly that reason. Again, this is that case. This is exactly that case. This is the time to impose an above-guideline sentence. A guideline sentence in this case would create unwarranted sentencing disparities with individuals being sentenced today for sex-trafficking offenses. This case calls out for an above-guideline sentence because of the breathtaking scope of the defendant's conduct, the length of her crimes, the number of victims, the vulnerability of her victims, the sophistication of the defendant's predatory conduct and the degree to which she psychologically manipulated her victims. Her conduct was shockingly predatory, and it **Footer:** SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 **DOI-OGR-00021604**