DOJ-OGR-00021604.pdf

Case 22-1426, Document 78, 06/29/2023, 3536039, Page174 of 217 SA-428 M6SQmaxS1 59 1 crimes. She has not owned up to the truth. She has lied 2 repeatedly. She has been dishonest with the Court, and she has 3 made misrepresentations when it suits her. Your Honor, we 4 recognize that the Court has calculated the guidelines to be 5 188 to 235 months. That is far below the sentence that the 6 government believes is appropriate in this case. We recognize 7 that there are a small number of cases where the Court imposes 8 an above-guideline sentence. This is that case, your Honor. 9 In the almost 20 years since the 2003 manual was enacted, our Sentencing Commission, our Congress, and our 10 country have all recognized just how serious sex crimes against 11 children are. Our country now recognizes how woefully 12 inadequate the 2003 guidelines were, and the Supreme Court has 13 expressly held that sentencing courts can vary upwards for 14 exactly that reason. Again, this is that case. This is 15 exactly that case. This is the time to impose an 16 above-guideline sentence. A guideline sentence in this case 17 would create unwarranted sentencing disparities with 18 individuals being sentenced today for sex-trafficking offenses. 19 This case calls out for an above-guideline sentence because of 20 the breathtaking scope of the defendant's conduct, the length 21 of her crimes, the number of victims, the vulnerability of her 22 victims, the sophistication of the defendant's predatory 23 conduct and the degree to which she psychologically manipulated 24 her victims. Her conduct was shockingly predatory, and it 25 her victims. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00021604