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Case 1:20-cr-00330-PAE Document 493 Filed 11/22/21 Page1of6
U.S. Department of Justice
United States Attorney
Southern District of New York
The Silvio J. Mollo Building
One Saint Andrew’s Plaza
New York, New York 10007
November 7, 2021
The Honorable Alison J. Nathan
United States District Court
Southern District of New York
United States Courthouse
40 Foley Square
New York, New York 10007
Re: United States v. Ghislaine Maxwell, 20 Cr. 330 (AJN)
Dear Judge Nathan:
The Government respectfully submits this letter in response to the Court’s order directing
the Government to state its position as to whether Minor Victim-3 “could be deemed a victim of
any of the crimes charged in the indictment for any legal purposes, including for purposes of
restitution under 18 U.S.C. § 3663(a)(2).” The answer is yes. Minor Victim-3 suffered unwanted
and traumatic sexual contact with Jeffrey Epstein when she was 17 years old. In addition to making
her a victim in the ordinary sense of that word, it makes her a victim of the charged Mann Act
conspiracies for at least the following provisions of federal law: the Crime Victim’s Rights Act
(“CVRA”), 18 U.S.C. § 3771; the Victim and Witness Protection Act (“VWPA”), 18 U.S.C. §
3663; and Federal Rule of Evidence 412.!
Both the CVRA and VWPA contain statutory definitions of the term “victim.” The CVRA
defines “victim” as “a person directly and proximately harmed as a result of the commission of a
Federal offense or an offense in the District of Columbia.” 18 U.S.C. § 3771(e)(2)(A). The VWPA
similarly defines “victim” to mean “a person directly and proximately harmed by the commission
' Given the expedited briefing deadline, the Government has not addressed every provision of
federal law that references victims, but would be happy to address any additional provisions the
Court deems relevant.
DOJ-OGR-00007431