U.S. Department of Justice United States Attorney Southern District of New York Prosecution Memorandum Privileged and Confidential - Attorney Work Product Do Not Disseminate Outside of the SDNY USAO (or other DOS COMPONENT, as needed) USAO #: United States v. Maxwell, S2 20 Cr. 330 (AJN) 3/14/2021 I. Overview This memorandum seeks authorization to charge GHISLAINE MAXWELL with additional criminal offenses based on her participation in the recruitment, grooming, and abuse of minor girls with Jeffrey Epstein in a superseding indictment. Our Office previously obtained a six-count Indictment charging Maxwell with one count of conspiracy to transport a minor for illegal sexual activity, in violation of 18 U.S.C. § 371; one count of transporting a minor, in violation of 18 U.S.C. § 2423(a); one count of conspiracy to entice a minor to travel to engage in illegal sexual activity, in violation of 18 U.S.C. § 371: one count of enticing a minor to travel, in violation of 18 U.S.C. § 2422; and two counts of perjury. in violation of 18 U.S.C. § 1623. The evidence supporting those charges and the legal issues surrounding those charges were discussed at length in previous prosecution memos dated April 10, 2020 and April 28. 2020. As detailed in those memos, the current charges focus on the victimization of , all of whom were sexually abused by Epstein, with assistance from Maxwell, between 1994 and 1997. The perjury charges arise from false statements Maxwell made during a civil deposition in 2016. which statements are directly contradicted by the evidence we have gathered regarding- Since obtaining the original Indictment charging Maxwell, our investigation has continued, including through the interviews of multiple Epstein victims who previously either declined to be interviewed or had not previously been identified. The charges we propose expanding and adding in a superseding indictment against Maxwell are based on the experiences of one victim i