Case 1:20-cr-00330-PAE Document 675 Filed 06/25/22 Page 1 of 21 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA, -v- GHISLAINE MAXWELL, Defendant. ) ) ) ) ) ) ) ) ) ) ) Case No. 20-CR-330 (AJN) MEMORANDUM OF LAW IN SUPPORT OF CRIME VICTIMS AND MOTION TO BE ALLOWED TO DELIVER ORAL VICTIM IMPACT STATEMENTS AT MAXWELL'S SENTENCING and through undersigned counsel, Robert Y. 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 1 EFTA02838542