Case 1:20-cr-00330-PAE Document 667 Filed 06/21/22 Pagelof2 LAW OFFICES OF BOBBI C. STERNHEIA\ 212-243-1100 * Main 225 Broadway, Suite 715 917-912-9698 ° Cell New York, NY 10007 888-587-4737 ° Fax [email protected] June 17, 2022 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: Counsel for Ms. Maxwell write to inform the Court that we do not request sealing or redaction of the letter submitted by Robert Y. Lewis, Esq., counsel to Sarah Ransome and Elizabeth Stein. However, Mr. Lewis’s letter raises an issue that we believe the Court must resolve prior to the sentencing hearing; namely, who may submit victim impact statements to the Court or address the Court at sentencing under the Crime Victims’ Rights Act (“CVRA”). Under the CVRA, a “crime victim” has, among other things, “the right to be reasonably heard at any public proceeding in the district court involving release, plea, sentencing, or any parole proceeding.” 18 U.S.C. § 3771(a)(4). The CVRA defines a “crime 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) (emphasis added). The concept of “direct and proximate harm,” as used in the CVRA, is not limitless and only covers victims of the conduct underlying the offenses of conviction. See United States v. Daly, No. 3:11-cr-121 (AWT), 2012 WL 315409, at *5-*6 (D. Conn. Feb. 1, 2012) (“[T]he determination as to whether person has the rights of a ‘crime victim’ for purposes the CVRA is made with reference to the conduct underlying the charged offense.) (emphasis added). The conduct underlying the offenses charged against Ms. Maxwell ended “in or about 2004.” To our understanding, Ms. Ransome alleges that she was a victim of Epstein and Ms. Maxwell from approximately October 2006 to April 2007,