I. Overview U.S. Department of Justice United States Attorney Southern District of New York Prosecution Memorandum Privileged and Confidential -- Attorney nark Product Do Not Disseminate Outside of the SDNY USAO United Stales v. Maxwell, 20 Cr. ( ) April 10, 2020 This memorandum seeks authorization to charge GHISLA1NE MAXWELL with one count of conspiracy to violate 18 U.S.C. § 2423(a), which prohibits the transportation of a minor for illegal sexual activity, and one count of conspiracy to violate 18 U.S.C. § 2422, which prohibits the enticement of a minor to travel to engage in illegal sexual activity. These charges arise from Maxwell's role in facilitating Jeffrey E tein's sexual abuse of minors. In particular, the proposed charges focus on the victimization o who was abused by E stein for several years. beginning when she was fourteen years o an ving in . Several months after Maxwell and Epstein met they began to encourage er to travel with them, and brought her to Epstein's mansion in ew York, where she was also abused. As discussed in greater detail below. Maxwell had a significant role in grooming for abuse and facilitating Epstein's access to Victim Interviews and Corroborating Evidence and moved to was born wit...when she was a In S e turn 14 years o at summer. reca s t at, one day, she was sitting at a picnic to le with friends when Ghislaine Maxwell wa ed by with her EFTA_00022689 EFTA02731168