DOJ-OGR-00014828.pdf

--- Page 1 --- **Document Header:** * Case 1:20-cr-00330-PAE * Document 779 * Filed 08/22/22 * Page 81 of 101 **Page Content:** * the conviction. * The government has asked for an immense sentence. We recognize that any sentence in this case is going to be significant and is going to be immensely punishing. The probation department, based on the original guidelines in the presentence report, recommended a downward variance to 20 years. That recommendation is now higher than the guideline range that is applicable in this case. But we ask the Court to consider the justification that probation articulated in the presentence report in fashioning a sentence that takes into consideration that a sentence lower than the guideline range is appropriate in this case. * The government's sentence asks for the outer limits, and although we still believe that even the recommendation is too high, a sentence within the guideline range now may be more reasonable, but it still does not take into consideration some of the various factors that we have brought to the Court's attention in our submission. Simply stated, based upon the conduct of conviction, the government's request is out of proportion. Jeffrey Epstein would have faced the same sentence, and he is clearly far more culpable than Ghislaine Maxwell. * THE COURT: You mean he would have faced the same guidelines. * MS. STERNHEIM: Yes, that is correct, Judge. **Footer:** * SOUTHERN DISTRICT REPORTERS, P.C. * (212) 805-0300 * DOJ-OGR-00014828 **Note:** * The image appears to be a scanned document, with some text slightly blurry or cut off. However, all visible text has been extracted as requested.