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- {
- "document_metadata": {
- "page_number": "17",
- "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 17 of 55\n\ninvolvement in the offense is immense,\" and that she was essential to \"fostering a culture for the abuse to continue.\" (Id.). Moreover, the Probation Office observed that the defendant's conduct reflected a dark world view: \"it appears that the defendant viewed the victims as objects who could be manipulated for her and Epstein's own selfish purposes without any regard for their personal wellbeing, health, or safety.\" (Id.).\n\nAs the PSR reflects, the United States Probation Office has calculated an applicable sentencing range under the advisory United States Sentencing Guidelines of 292 to 365 months, based on a total offense level of 40. The Government does not object to the calculation set forth in the PSR, except that the Government respectfully submits that, as noted in the Government's objections to the PSR, the Guidelines calculation should include two additional groups relating to two victims: Virginia Roberts and the victim identified at trial as Melissa. (PSR at 45). Pursuant to the Court's discovery order, the Government notified the defense by letter on September 13, 2022 that the Government intended to prove at trial that the conspiracy involved six victims, including Virginia Roberts and Melissa. The Government did just that at trial. (See, e.g., Tr. 2874, 2882-84 (discussing evidence demonstrating the abuse of Virginia Roberts and Melissa in summation); PSR ¶¶ 55-58, 80). The PSR notes that Virginia Roberts and Melissa do not appear by name in the indictment, but Application Note 6 to U.S.S.G. § 2G1.3 expressly instructs that if the relevant conduct of an offense of conviction includes \"prohibited sexual conduct in respect to more than one minor, whether specifically cited in the count of conviction, each such minor shall be treated as if contained in a separate count of conviction.\" (emphasis added).\n\nAccordingly, the offense level should be increased by two levels, pursuant to U.S.S.G. § 2G1.3(d)(1). As a result, the applicable sentencing range is 360 to 660 months' imprisonment, based on an offense level of 42.\n\n15\nDOJ-OGR-00010552",
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- {
- "type": "printed",
- "content": "Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 17 of 55",
- "position": "header"
- },
- {
- "type": "printed",
- "content": "involvement in the offense is immense,\" and that she was essential to \"fostering a culture for the abuse to continue.\" (Id.). Moreover, the Probation Office observed that the defendant's conduct reflected a dark world view: \"it appears that the defendant viewed the victims as objects who could be manipulated for her and Epstein's own selfish purposes without any regard for their personal wellbeing, health, or safety.\" (Id.).",
- "position": "top"
- },
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- "type": "printed",
- "content": "As the PSR reflects, the United States Probation Office has calculated an applicable sentencing range under the advisory United States Sentencing Guidelines of 292 to 365 months, based on a total offense level of 40. The Government does not object to the calculation set forth in the PSR, except that the Government respectfully submits that, as noted in the Government's objections to the PSR, the Guidelines calculation should include two additional groups relating to two victims: Virginia Roberts and the victim identified at trial as Melissa. (PSR at 45). Pursuant to the Court's discovery order, the Government notified the defense by letter on September 13, 2022 that the Government intended to prove at trial that the conspiracy involved six victims, including Virginia Roberts and Melissa. The Government did just that at trial. (See, e.g., Tr. 2874, 2882-84 (discussing evidence demonstrating the abuse of Virginia Roberts and Melissa in summation); PSR ¶¶ 55-58, 80). The PSR notes that Virginia Roberts and Melissa do not appear by name in the indictment, but Application Note 6 to U.S.S.G. § 2G1.3 expressly instructs that if the relevant conduct of an offense of conviction includes \"prohibited sexual conduct in respect to more than one minor, whether specifically cited in the count of conviction, each such minor shall be treated as if contained in a separate count of conviction.\" (emphasis added).",
- "position": "middle"
- },
- {
- "type": "printed",
- "content": "Accordingly, the offense level should be increased by two levels, pursuant to U.S.S.G. § 2G1.3(d)(1). As a result, the applicable sentencing range is 360 to 660 months' imprisonment, based on an offense level of 42.",
- "position": "bottom"
- },
- {
- "type": "printed",
- "content": "15",
- "position": "footer"
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- {
- "type": "printed",
- "content": "DOJ-OGR-00010552",
- "position": "footer"
- }
- ],
- "entities": {
- "people": [
- "Virginia Roberts",
- "Melissa",
- "Epstein"
- ],
- "organizations": [
- "United States Probation Office"
- ],
- "locations": [],
- "dates": [
- "September 13, 2022",
- "06/22/22"
- ],
- "reference_numbers": [
- "1:20-cr-00330-PAE",
- "Document 670",
- "DOJ-OGR-00010552"
- ]
- },
- "additional_notes": "The document appears to be a court filing related to a criminal case, discussing sentencing guidelines and the defendant's conduct. The text is printed and there are no visible stamps or handwritten notes."
- }
|