Ghislaine Maxwell plans to appeal her conviction for sex trafficking on the basis of challenging the memories of her victims.
The disgraced British socialite was found guilty by a jury of enticing young girls to massage rooms for Jeffrey Epstein to molest between 1994 and 2004.
Maxwell, now 61, was jailed without bail in July 2020 and sentenced to 20 years in prison in June 2022.
On Tuesday, she is set to present her reasons for appealing, citing "errors" by the trial court and the US government that brought the charges against her.
Maxwell's attorneys will argue that the government breached its promise not to prosecute her.
They are also expected to argue that she was charged with time-barred offences and that new allegations were developed from "faded, distorted, and motivated memories".
Maxwell's attorneys will also argue that her prison conditions prevented her from assisting in her own defence and that the court refused to correct the jury's misunderstanding of the charges.
Finally, Maxwell will claim that the US government breached a non-prosecution agreement by bringing charges against her.
Epstein, a financier and convicted sex offender, died in his jail cell in August 2019 while awaiting trial on sex trafficking charges. His death was ruled a suicide.
Maxwell's attorneys are set to state in their appeal: "The government prosecuted Ms Maxwell as a proxy for Jeffrey Epstein.
"It did so to satisfy public outrage over an unpopular non-prosecution agreement and the death of the person responsible for the crimes.
"In its zeal to pin the blame for its own incompetence and for Epstein's crimes on Ms Maxwell, the government breached its promise not to prosecute Ms Maxwell, charged her with time-barred offences, resurrected and recast decades-old allegations for conduct previously ascribed to Epstein and other named assistants, and joined forces with plaintiffs' attorneys, whose interests were financial, to develop new allegations out of faded, distorted, and motivated memories."
During her three-week trial in December 2021, jurors heard prosecutors describe Maxwell as "dangerous".
They were told details of how she helped entice vulnerable teenagers to Epstein's various properties for him to sexually abuse.
But her attorneys will argue she did not have a fair trial after it emerged one of the jurors, Scotty David, had failed to disclose he had been sexually abused.
Her lawyers will also argue the court had refused to correct the jury's "misunderstanding" of elements of the charges - meaning Maxwell was "convicted of crimes with which she was not charged".
