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Case 1:20-cr-00330-PAE Document675 _ Filed 06/25/22 Page1of21
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA,
Case No. 20—CR—330 (AJN)
GHISLAINE MAXWELL,
Defendant.
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MEMORANDUM OF LAW IN SUPPORT OF CRIME VICTIMS SARAH RANSOME’S
AND ELIZABETH STEIN’S MOTION TO BE ALLOWED TO DELIVER
ORAL VICTIM IMPACT STATEMENTS AT MAXWELL’S SENTENCING
Sarah Ransome and Elizabeth Stein, through undersigned counsel, Robert Y. Lewis and
Margaret E. Mabie of the Marsh Law Firm PLLC, hereby submits this memorandum of law in
support of their motion to be allowed to deliver oral victim impact statements (“VIS”) at the
sentencing of Ghislaine Maxwell on June 28, 2022. (Dkt. 666).
INTRODUCTION
As the Court is aware, this case involves what is likely the most extensive known worldwide
sex trafficking operation in recent history. At the trial of the defendant, Ghislaine Maxwell, the
Government chose to prosecute a narrow sliver of the crimes that it believed Maxwell had
committed. A jury found Maxwell guilty of five sex trafficking counts — Nos. 1 and 3-6 of the
government’s second superseding indictment.
Now, at sentencing, the Court has the power and the freedom to consider the full scope of
the harm that Maxwell’s crimes caused. See 18 U.S.C. § 3661 (“no limitation shall be placed on the
DOJ-OGR- 00010692