{
  "document_metadata": {
    "page_number": "40",
    "document_number": "670",
    "date": "06/22/22",
    "document_type": "court document",
    "has_handwriting": false,
    "has_stamps": false
  },
  "full_text": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 40 of 55\n\nidentified a total of thirty-two minor victims, including Carolyn and Virginia.5 Of those thirty-two individuals, thirteen appear in the message pads, again including Carolyn and Virginia.\n\nThe Government notes that, from interviewing many of these victims during the course of its investigation, the Government has learned that, in the later phases of the conspiracy, victims primarily scheduled appointments with—and interfaced with—Epstein's personal assistants, who were in their early twenties.6 Although the Government does not seek to include these minors as victims for purposes of the Guidelines calculation, the scope of the pyramid scheme that the defendant helped devise with Epstein bears emphasis when evaluating the harms that the defendant's criminal conduct ultimately caused.\n\nVictim Impact\n\nIt is difficult to capture in words the harm that Maxwell caused to her victims. They were children who experienced what can only be described as a recurring nightmare: again and again, they found themselves alone with Maxwell and Epstein in terrifying mansions where they were sexually abused and physically violated. They were trapped in an exploitative relationship with Maxwell and Epstein that, for many victims, lasted for years.\n\nOften, in cases involving sexual exploitation, the Court is left to consider the harms the victims have suffered during the offense conduct and to predict the likely effects on their lives going forward. What is remarkable in this case is that the Court need make no such predictions\n\n5 The letter was marked with Jencks Act control number 3505-022. With the exception of Carolyn and Virginia, none of the other thirty individuals named in this document have been publicly identified on the record in this case. Those victims retain significant privacy interests.\n\n6 Of course, there can be no comparison between the defendant—a woman in her forties in the 2000s—and the young women (often in their very early twenties) who worked as personal assistants, and whose roles and life circumstances dramatically differed from those of the defendant.\n\n38\nDOJ-OGR-00010575",
  "text_blocks": [
    {
      "type": "printed",
      "content": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 40 of 55",
      "position": "header"
    },
    {
      "type": "printed",
      "content": "identified a total of thirty-two minor victims, including Carolyn and Virginia.5 Of those thirty-two individuals, thirteen appear in the message pads, again including Carolyn and Virginia.",
      "position": "top"
    },
    {
      "type": "printed",
      "content": "The Government notes that, from interviewing many of these victims during the course of its investigation, the Government has learned that, in the later phases of the conspiracy, victims primarily scheduled appointments with—and interfaced with—Epstein's personal assistants, who were in their early twenties.6 Although the Government does not seek to include these minors as victims for purposes of the Guidelines calculation, the scope of the pyramid scheme that the defendant helped devise with Epstein bears emphasis when evaluating the harms that the defendant's criminal conduct ultimately caused.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Victim Impact",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "It is difficult to capture in words the harm that Maxwell caused to her victims. They were children who experienced what can only be described as a recurring nightmare: again and again, they found themselves alone with Maxwell and Epstein in terrifying mansions where they were sexually abused and physically violated. They were trapped in an exploitative relationship with Maxwell and Epstein that, for many victims, lasted for years.",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "Often, in cases involving sexual exploitation, the Court is left to consider the harms the victims have suffered during the offense conduct and to predict the likely effects on their lives going forward. What is remarkable in this case is that the Court need make no such predictions",
      "position": "middle"
    },
    {
      "type": "printed",
      "content": "5 The letter was marked with Jencks Act control number 3505-022. With the exception of Carolyn and Virginia, none of the other thirty individuals named in this document have been publicly identified on the record in this case. Those victims retain significant privacy interests.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "6 Of course, there can be no comparison between the defendant—a woman in her forties in the 2000s—and the young women (often in their very early twenties) who worked as personal assistants, and whose roles and life circumstances dramatically differed from those of the defendant.",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "38",
      "position": "footer"
    },
    {
      "type": "printed",
      "content": "DOJ-OGR-00010575",
      "position": "footer"
    }
  ],
  "entities": {
    "people": [
      "Carolyn",
      "Virginia",
      "Epstein",
      "Maxwell"
    ],
    "organizations": [
      "Government",
      "Court"
    ],
    "locations": [],
    "dates": [
      "06/22/22"
    ],
    "reference_numbers": [
      "1:20-cr-00330-PAE",
      "670",
      "3505-022",
      "DOJ-OGR-00010575"
    ]
  },
  "additional_notes": "The document appears to be a court filing related to the case against Ghislaine Maxwell, discussing the impact of her crimes on the victims and the scope of the conspiracy involving Jeffrey Epstein."
}