Case 1:20-cr-00330-PAE Document672 Filed 06/24/22 Page1of68
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June 24, 2022
Submission Under Seal
Honorable Alison J. Nathan
Sitting By Designation
United States District Court
40 Foley Square
New York, NY 10007
Re: United States v. Ghislaine Maxwell
S2 20 Cr. 330 (AJN)
Dear Judge Nathan:
Ghislaine Maxwell submits this letter in response to the Court’s order (Dkt. 665). Ms.
Maxwell objects to characterization of Sarah Ransome, Maria Farmer, Teresa Helm, and Juliette
Bryant (collectively, the "Individuals") as "victims" of the counts of conviction and disputes that
the Individuals qualify as statutory victims within the definition of a "crime victim" contained in
the Crime Victims' Rights Act, 18 U.S.C.A. §3771 ("CVRA").
The issue that requires resolution in advance of sentencing is whether the Individuals, or
their representatives, have statutory crime victim status under the CVRA. Under the statute,
definition of “crime victim” takes as a given that there has been a “federal offense” committed.
See 18 U.S.C. § 3771(e)(2)(A). Ms. Maxwell asserts that the Individuals are not statutory crime
victims of the federal offenses of conviction, which require that (1) each was a minor at the time
to the alleged abuse, (11) the alleged abuse occurred during the period alleged in the indictment,
and (111) the Individuals were “directly and proximately harmed as a result of the commission of
[the] Federal offense.” /d.(emphasis added).
DOJ-OGR-00010592