4.Sentencing Argument — Prosecution Request for Life Imprisonment

MS. HAJJAR: Thank you, your Honor.

Your Honor, the Government is asking the Court to impose a Guideline sentence of life imprisonment.

The offenses here, the offenses that Mr. Raniere has been convicted of, are among the most serious under the law. Sex trafficking, forced labor, child exploitation, the Guidelines demand a life sentence because these crimes cause immeasurable harm to victims. The court has heard from these victims today, at the defendant's trial, in voluminous victim-impact statements, and in court.

The victims have described so powerfully the impact of the defendant's crimes on them and their families. And in doing so they have relived the worse moments of their lives in order to convey to the Court and to the public how they were hurt in the most depraved ways. There is very little that I could add to that, your Honor. But what is clear is that these victims will be carrying this damage with them for the rest of their lives.

It is outrageous for defense counsel to suggest that the defendant committed these crimes because he didn't know how to leave women or because he didn't think he was hurting them. He did hurt them, and that was made absolutely clear at trial and it was made absolutely clear today. It doesn't matter if a child abuser doesn't think he's hurting a child; when he begins a sexual relationship when she's 15 years old, it doesn't matter.

The Government has submitted a lengthy sentencing memorandum addressing the 3553(a) factors, I'm not going to repeat those arguments today. I will just briefly address a few of the arguments that the counsel for the defendant made today.

Mr. Agnifilo's justification for pursuing Sarah Edmondson and DOS victims by sending them threatening letters and by attempting to institute criminal charges, that was the justification presented at trial and the jury rejected that justification. It is total nonsense and has no basis in the evidence.

Mr. Agnifilo asked this Court not to impose a sentence of 15 years because the defendant is 60 years old. But the defendant was 45 years old when he first started sexually abusing Camila. He was 49 years old when he ordered Daniela to be confined in a room without human contact for nearly two years. He was 54 years old when he attempted to use first-line slaves in DOS to, quote, "find him a virgin successor who would serve as a replacement for Camila." And he was 55 years old when he told Allison Mack that DOS slaves should be held down like a sort of sacrifice and branded with his initials.

The defendant's age has clearly not prevented him from committing crimes, far from it. If the defendant hadn't been arrested, he would be committing crimes today, tomorrow, and for the foreseeable future.

Even now after overwhelming evidence of his guilt was introduced at trial and after his conviction, the defendant has yet to express any understanding of or remorse for his crimes. His post-conviction comment has shown him to be completely unrepentant.

No sentence short of life in imprisonment is sufficient to protect the public from this defendant. No sentence short of life imprisonment is sufficient to provide just punishment for the defendant's crimes.

Thank you, your Honor.