{"efta_number": "EFTA01659462", "page_count": 24, "url": "https://epstein-data.com/EFTA01659462", "pdf_url": "https://epstein-data.com/pdf/EFTA01659462.pdf", "pages": [{"efta_number": "EFTA01659462", "page_number": 0, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 1 of 24 \nORIGINAL \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUNITED STATES OF AMERICA \nGHISLAINE MAXWELL, \nDefendant. \nSUPERSEDING INDICTMENT \nS2 20 Cr. 330 (AJN) \nCOUNT ONE \n(Conspiracy to Entice Minors to Travel to Engage in \nIllegal Sex Acts) \nThe Grand Jury charges: \nOVERVIEW \n1. \nThe charges set forth herein stem from the role \nof GHISLAINE MAXWELL, the defendant, in the sexual exploitation \nand abuse of multiple minor girls by Jeffrey Epstein. In \nparticular, from at least in or about 1994, up to and including \nat least in or about 2004, MAXWELL assisted, facilitated, and \ncontributed to Jeffrey Epstein's abuse of minor girls by, among \nother things, helping Epstein to recruit, groom, and ultimately \nabuse victims known to MAXWELL and Epstein to be under the age \nof 18. The victims were as young as 14 years old when they were \ngroomed and abused by MAXWELL and Epstein, both of whom knew \nthat certain victims were in fact under the age of 18. \n2. \nAs a part and in furtherance of their scheme to \nabuse minor victims, GHISLAINE MAXWELL, the defendant, and \nJeffrey Epstein enticed and caused minor victims to travel to \nEFTA01659462\n", "char_count": 1227}, {"efta_number": "EFTA01659462", "page_number": 1, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 2 of 24 \nEpstein's residences in different states, which MAXWELL knew and \nintended would result in their grooming for and subjection to \nsexual abuse. Moreover, in an effort to conceal her crimes, \nMAXWELL repeatedly lied when questioned about her conduct, \nincluding in relation to some of the minor victims described \nherein, when providing testimony under oath in 2016. \nFACTUAL BACKGROUND \n3. \nDuring the time periods charged in this \nIndictment, GHISLAINE MAXWELL, the defendant, had a personal and \nprofessional relationship with Jeffrey Epstein and was among his \nclosest associates. In particular, between in or about 1994 and \nin or about 1997, MAXWELL was in an intimate relationship with \nEpstein. Additionally, between in or about 1994 and in or about \n2004, MAXWELL was paid by Epstein to manage his various \nproperties. \n4. \nBeginning in at least 1994, GHISLAINE MAXWELL, \nthe defendant, enticed and groomed multiple minor girls to \nengage in sex acts with Jeffrey Epstein, through a variety of \nmeans and methods, including but not limited to the following: \na. \nMAXWELL first attempted to befriend some of \nEpstein's minor victims prior to their abuse, including by \nasking the victims about their lives, their schools, and their \nfamilies. MAXWELL and Epstein would spend time building \nfriendships with minor victims by, for example, taking minor \n2 \nEFTA01659463\n", "char_count": 1439}, {"efta_number": "EFTA01659462", "page_number": 2, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 3 of 24 \nvictims to the movies or shopping. Some of these outings would \ninvolve MAXWELL and Epstein spending time together with a minor \nvictim, while some would involve MAXWELL or Epstein spending \ntime alone with a minor victim. \nb. \nHaving developed a rapport with a victim, \nMAXWELL would try to normalize sexual abuse for a minor victim \nby, among other things, discussing sexual topics, undressing in \nfront of the victim, being present when a minor victim was \nundressed, and/or being present for sex acts involving the minor \nvictim and Epstein. \nc. \nMAXWELL'S presence during minor victims' \ninteractions with Epstein, including interactions where the \nminor victim was undressed or that involved sex acts with \nEpstein, helped put the victims at ease because an adult woman \nwas present. For example, in some instances, MAXWELL would \nmassage Epstein in front of a minor victim. In other instances, \nMAXWELL encouraged minor victims to provide massages to Epstein, \nincluding sexualized massages during which a minor victim would \nbe fully or partially nude. Many of those massages resulted in \nEpstein sexually abusing the minor victims. \nd. \nIn addition, Epstein offered to help some \nminor victims by paying for travel and/or educational \nopportunities, and MAXWELL encouraged certain victims to accept \nEpstein's assistance. As a result, victims were made to feel \n3 \nEFTA01659464\n", "char_count": 1452}, {"efta_number": "EFTA01659462", "page_number": 3, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 4 of 24 \nindebted and believed that MAXWELL and Epstein were trying to \nhelp them. \ne. \nThrough this process, MAXWELL and Epstein \nenticed victims to engage in sexual activity with Epstein. In \nsome instances, MAXWELL was present for and participated in the \nsexual abuse of minor victims. Some such incidents occurred in \nthe context of massages, which developed into sexual encounters. \n5. \nBetween approximately in or about 1994 and in or \nabout 2004, GHISLAINE MAXWELL, the defendant, facilitated \nJeffrey Epstein's access to minor victims by, among other \nthings, inducing and enticing, and aiding and abetting the \ninducement and enticement of, multiple minor victims. Victims \nwere groomed and/or abused at multiple locations, including the \nfollowing: \na. \nA multi-story private residence on the Upper \nEast Side of Manhattan, New York owned by Epstein (the \"New York \nResidence\"). \nb. \nAn estate in Palm Beach, Florida owned by \nEpstein (the \"Palm Beach Residence\"). \nc. \nA ranch in Santa Fe, New Mexico owned by \nEpstein (the \"New Mexico Residence\"). \nd. \nMAXWELL's personal residence in London, \nEngland. \n4 \nEFTA01659465\n", "char_count": 1189}, {"efta_number": "EFTA01659462", "page_number": 4, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 5 of 24 \n6. \nAdditionally, beginning at least in or about \n2001, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein \nenticed and recruited, and caused to be enticed and recruited, \nminor girls to visit Epstein's Palm Beach Residence to engage in \nsex acts with Epstein, after which Epstein, MAXWELL, or another \nemployee of Epstein's would give the victims hundreds of dollars \nin cash. Epstein and MAXWELL encouraged one or more of those \nvictims to travel with Epstein with the intention that the \nvictim engage in sex acts with Epstein. Moreover, and in order \nto maintain and increase his supply of victims, Epstein, \nMAXWELL, and other Epstein employees also paid certain victims \nto recruit additional girls to be similarly abused by Epstein. \nIn this way, Epstein and MAXWELL created a network of underage \nvictims for him to sexually exploit. \n7. \nBetween at least in or about 2001 and in or about \n2004, GHISLAINE MAXWELL, the defendant, and Epstein encouraged \nand enticed one or more minor victims to engage in paid sex acts \nwith Epstein through a variety of means and methods, including \nbut not limited to the following: \na. \nEpstein's employees, including, at times, \nMAXWELL, would call a victim to schedule an appointment for the \nvictim to massage Epstein at his Palm Beach Residence. MAXWELL \nplaced at least some of those calls while with Epstein in \n5 \nEFTA01659466\n", "char_count": 1446}, {"efta_number": "EFTA01659462", "page_number": 5, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 6 of 24 \nManhattan, New York. Epstein would often travel from New York \nto Florida, where he would then have the scheduled appointments. \nb. \nWhen a victim initially arrived at the Palm \nBeach Residence, she would be greeted by an employee of \nEpstein's, including, at times, MAXWELL. The victim would then \nbe escorted to a room with a massage table. Once inside, the \nvictim would provide a nude or semi-nude massage for EPSTEIN, \nwho would himself typically be naked. During these encounters, \nEPSTEIN would escalate the nature and scope of the physical \ncontact to include sex acts such as groping and direct and \nindirect contact with the victim's genitals. EPSTEIN would also \ntypically masturbate during these encounters, ask the victim to \ntouch him while he masturbated, and touch the victim's genitals \nwith his hands or with sex toys. \nc. \nIn connection with each sexual encounter, \nEpstein or one of his employees or associates, including, at \ntimes, MAXWELL, paid the victim in cash. Each victim was \ntypically paid hundreds of dollars for each encounter. \n8. \nGHISLAINE MAXWELL, the defendant, facilitated \nJeffrey Epstein's access to minor victims knowing that he had a \nsexual preference for underage girls and that he intended to \nengage in sexual activity with those victims. Epstein's \nresulting abuse of minor victims included, among other things, \ntouching a victim's breast, touching a victim's genitals, \n6 \nEFTA01659467\n", "char_count": 1500}, {"efta_number": "EFTA01659462", "page_number": 6, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 7 of 24 \nplacing a sex toy such as a vibrator on a victim's genitals, \ndirecting a victim to touch Epstein while he masturbated, and \ndirecting a victim to touch Epstein's genitals. \nMAXWELL AND EPSTEIN'S VICTIMS \n9. \nAmong the victims induced or enticed by GHISLAINE \nMAXWELL, the defendant, were minor victims identified herein as \nMinor Victim-1, Minor Victim-2, Minor Victim-3, and Minor \nVictim-4. In particular, and during time periods relevant to \nthis Indictment, MAXWELL engaged in the following acts, among \nothers, with respect to minor victims: \na. \nMAXWELL met Minor Victim-1 when Minor \nVictim-1 was approximately 14 years old. MAXWELL subsequently \ninteracted with Minor Victim-1 on multiple occasions at \nEpstein's residences, knowing that Minor Victim-1 was under the \nage of 18 at the time. During these interactions, which took \nplace between approximately 1994 and 1997, MAXWELL groomed Minor \nVictim-1 to engage in sexual acts with Epstein through multiple \nmeans. First, MAXWELL and Epstein attempted to befriend Minor \nVictim-1, taking her to the movies and on shopping trips. \nMAXWELL also asked Minor Victim-1 about school, her classes, her \nfamily, and other aspects of her life. MAXWELL then sought to \nnormalize inappropriate and abusive conduct by, among other \nthings, undressing in front of Minor Victim-1 and being present \nwhen Minor Victim-1 undressed in front of Epstein. Within the \n7 \nEFTA01659468\n", "char_count": 1491}, {"efta_number": "EFTA01659462", "page_number": 7, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 8 of 24 \nfirst year after MAXWELL and Epstein met Minor Victim-1, Epstein \nbegan sexually abusing Minor Victim-1. MAXWELL was present for \nand involved in some of this abuse. In particular, MAXWELL \ninvolved Minor Victim-1 in group sexualized massages of Epstein. \nDuring those group sexualized massages, MAXWELL and/or Minor \nVictim-1 would engage in sex acts with Epstein. Epstein and \nMAXWELL both encouraged Minor Victim-1 to travel to Epstein's \nresidences in both New York and Florida. As a result, Minor \nVictim-1 was sexually abused by Epstein in both New York and \nFlorida. Minor Victim-1 was enticed to travel across state \nlines for the purpose of sexual encounters with Epstein, and \nMAXWELL was aware that Epstein engaged in sexual activity with \nMinor Victim-1 after Minor-Victim-1 traveled to Epstein's \nproperties, including in the context of a sexualized massage. \nb. \nMAXWELL interacted with Minor Victim-2 on at \nleast one occasion in or about 1996 at Epstein's residence in \nNew Mexico when Minor Victim-2 was under the age of 18. Minor \nVictim-2 had flown into New Mexico from out of state at \nEpstein's invitation for the purpose of being groomed for and/or \nsubjected to acts of sexual abuse. MAXWELL knew that Minor \nVictim-2 was under the age of 18 at the time. While in New \nMexico, MAXWELL and Epstein took Minor Victim-2 to a movie and \nMAXWELL took Minor Victim-2 shopping. MAXWELL also discussed \nMinor Victim-2's school, classes, and family with Minor Victim-\n8 \nEFTA01659469\n", "char_count": 1563}, {"efta_number": "EFTA01659462", "page_number": 8, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 9 of 24 \n2. In New Mexico, MAXWELL began her efforts to groom Minor \nVictim-2 for abuse by Epstein by, among other things, providing \nan unsolicited massage to Minor Victim-2, during which Minor \nVictim-2 was topless. MAXWELL also encouraged Minor Victim-2 to \nmassage Epstein. \nc. \nMAXWELL groomed and befriended Minor \nVictim-3 in London, England between approximately 1994 and 1995, \nincluding during a period of time in which MAXWELL knew that \nMinor Victim-3 was under the age of 18. Among other things, \nMAXWELL discussed Minor Victim-3's life and family with Minor \nVictim-3. MAXWELL introduced Minor Victim-3 to Epstein and \narranged for multiple interactions between Minor Victim-3 and \nEpstein. During those interactions, MAXWELL encouraged Minor \nVictim-3 to massage Epstein, knowing that Epstein would engage \nin sex acts with Minor Victim-3 during those massages. Minor \nVictim-3 provided Epstein with the requested massages, and \nduring those massages, Epstein sexually abused Minor Victim-3. \nMAXWELL was aware that Epstein engaged in sexual activity with \nMinor Victim-3 on multiple occasions, including at times when \nMinor Victim-3 was under the age of 18, including in the context \nof a sexualized massage. \nd. \nMinor Victim-4 was recruited to provide \nEpstein with sexualized massages for which Minor Victim-4 was \npaid by Epstein and/or one of his associates, including, at \n9 \nEFTA01659470\n", "char_count": 1468}, {"efta_number": "EFTA01659462", "page_number": 9, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 10 of 24 \ntimes, MAXWELL, at the Palm Beach Residence beginning in or \naround 2001. MAXWELL met Minor Victim-4 at Epstein's Palm Beach \nResidence when Minor Victim-4 was approximately 14 years old. \nMAXWELL subsequently interacted with Minor Victim-4 on multiple \noccasions at Epstein's Palm Beach Residence, knowing that Minor \nVictim-4 was under the age of 18 at the time. During these \ninteractions, which took place between approximately 2001 and \n2004, MAXWELL groomed Minor Victim-4 to engage in sexual acts \nwith Epstein through multiple means. For example, MAXWELL asked \nMinor Victim-4 about her family and other aspects of her life. \nMAXWELL also sought to normalize inappropriate and abusive \nconduct by, among other things, discussing sexual topics in \nfront of Minor Victim-4 and being present when Minor Victim-4 \nwas nude in the massage room of the Palm Beach Residence. On \nmultiple occasions between approximately 2001 and 2004, Minor \nVictim-4 provided nude massages to Epstein at the Palm Beach \nResidence, during which Epstein engaged in multiple sex acts \nwith Minor Victim-4. Epstein's employees, including at times \nMAXWELL, called Minor Victim-4, including from New York, to \nschedule appointments for Minor Victim-4 to massage Epstein. \nAfter each massage, Epstein or one of his employees, including \nat times MAXWELL, paid Minor Victim-4 hundreds of dollars in \ncash. At some point during this period, both Epstein and \nMAXWELL invited Minor Victim-4 to travel with Epstein and \n10 \nEFTA01659471\n", "char_count": 1578}, {"efta_number": "EFTA01659462", "page_number": 10, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 11 of 24 \noffered to assist Minor Victim-4 with obtaining a passport for \npurposes of such travel, but Minor Victim-4 declined the \ninvitation. On multiple occasions between approximately 2001 \nand 2004, Epstein's employees, including at times MAXWELL, sent \nMinor Victim-4 gifts, including lingerie, from an address in \nManhattan, New York to Minor Victim-4's residence in Florida. \nEpstein and MAXWELL each also encouraged Minor Victim-4 to \nrecruit other young females to provide sexualized massages to \nEpstein. In response, Minor Victim-4 brought multiple females, \nincluding girls under the age of 18, to provide sexualized \nmassages for Epstein at the Palm Beach Residence. On such \noccasions, both Minor Victim-4 and the girl she brought were \npaid hundreds of dollars in cash. \nMAXWELL'S EFFORTS TO CONCEAL HER CONDUCT \n10. In or around 2016, in the context of a deposition \nas part of civil litigation, GHISLAINE MAXWELL, the defendant, \nrepeatedly provided false and perjurious statements, under oath, \nregarding, among other subjects, her role in facilitating the \nabuse of minor victims by Jeffrey Epstein, including some of the \nspecific events and acts of ,ib.:se d,=t=ilnl above. \nSTATUTORY ALLEGATIONS \n11. From at _east. in or about 1994, up to and \nincluding in or about 2004, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey \n11 \nEFTA01659472\n", "char_count": 1465}, {"efta_number": "EFTA01659462", "page_number": 11, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 12 of 24 \nEpstein, and others known and unknown, willfully and knowingly \ndid combine, conspire, confederate, and agree together and with \neach other to commit an offense against the United States, to \nwit, enticement, in violation of Title 18, United States Code, \nSection 2422. \n12. It was a part and object of the conspiracy that \nGHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others \nknown and unknown, would and did knowingly persuade, induce, \nentice, and coerce one and more individuals to travel in \ninterstate and foreign commerce, to engage in sexual activity \nfor which a person can be charged with a criminal offense, in \nviolation of Title 18, United States Code, Section 2422. \nOvert Acts \n13. In furtherance of the conspiracy and to effect \nthe illegal object thereof, the following overt acts, among \nothers, were committed in the Southern District of New York and \nelsewhere: \na. \nBetween in or about 1994 and in or about \n1997, when Minor Victim-1 was under the age of 18, MAXWELL \nparticipated in multiple group sexual encounters with Epstein \nand Minor Victim-1 in New York and Florida. \nb. \nIn or about 1996, when Minor Victim-1 was \nunder the age of 18, Minor Victim-1 was enticed to travel from \nFlorida to New York for purposes of sexually abusing her at the \n12 \nEFTA01659473\n", "char_count": 1366}, {"efta_number": "EFTA01659462", "page_number": 12, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 13 of 24 \nNew York Residence, in violation of New York Penal Law, Section \n130.55. \nc. \nIn or about 1996, when Minor Victim-2 was \nunder the age of 18, MAXWELL provided Minor Victim-2 with an \nunsolicited massage in New Mexico, during which Minor Victim-2 \nwas topless. \nd. \nBetween in or about 1994 and in or about \n1995, when Minor Victim-3 was under the age of 18, MAXWELL \nencouraged Minor Victim-3 to provide massages to Epstein in \nLondon, England, knowing that Epstein intended to sexually abuse \nMinor Victim-3 during those massages. \ne. \nBetween in or about 2001 and in or about \n2002, when Minor Victim-4 was under the age of 18, MAXWELL and \nEpstein invited Minor Victim-4 to travel from Florida to a place \noutside of Florida with Epstein. \n(Title 18, United States Code, Section 371.) \nCOUNT TWO \n(Enticement of a Minor to Travel to Engage in Illegal Sex Acts) \nThe Grand Jury further charges: \n14. The allegations contained in paragraphs 1 through \n9 of this Indictment are repeated and realleged as if fully set \nforth within. \n15. From at least in or about 1994, up to and \nincluding in or about 1997, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did \n13 \nEFTA01659474\n", "char_count": 1293}, {"efta_number": "EFTA01659462", "page_number": 13, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 14 of 24 \npersuade, induce, entice, and coerce an individual to travel in \ninterstate and foreign commerce to engage in sexual activity for \nwhich a person can be charged with a criminal offense, and \nattempted to do the same, and aided and abetted the same, to \nwit, MAXWELL persuaded, induced, enticed, and coerced Minor \nVictim-1 to travel from Florida to New York, New York on \nmultiple occasions with the intention that Minor Victim-1 would \nengage in one or more sex acts with Jeffrey Epstein, in \nviolation of New York Penal Law, Section 130.55. \n(Title 18, United States Code, Sections 2422 and 2.) \nCOUNT THREE \n(Conspiracy to Transport Minors with Intent to \nEngage in Criminal Sexual Activity) \nThe Grand Jury further charges: \n16. The allegations contained in paragraphs 1 through \n9 of this Indictment are repeated and realleged as if fully set \nforth within. \n17. From at least in or about 1994, up to and \nincluding in or about 2004, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey \nEpstein, and others known and unknown, willfully and knowingly \ndid combine, conspire, confederate, and agree together and with \neach other to commit an offense against the United States, to \nwit, transportation of minors, in violation of Title 18, United \nStates Code, Section 2423(a). \n14 \nEFTA01659475\n", "char_count": 1406}, {"efta_number": "EFTA01659462", "page_number": 14, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 15 of 24 \n18. It was a part and object of the conspiracy that \nGHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others \nknown and unknown, would and did, knowingly transport an \nindividual who had not attained the age of 18 years in \ninterstate and foreign commerce, with intent that the individual \nengage in sexual activity for which a person can be charged with \na criminal offense, in violation of Title 18, United States \nCode, Section 2423(a). \nOvert Acts \n19. In furtherance of the conspiracy and to effect \nthe illegal object thereof, the following overt acts, among \nothers, were committed in the Southern District of New York and \nelsewhere: \na. \nBetween in or about 1994 and in or about \n1997, when Minor Victim-i was under the age of 18, MAXWELL \nparticipated in multiple group sexual encounters with EPSTEIN \nand Minor Victim-1 in New York and Florida. \nb. \nIn or about 1996, when Minor Victim-1 was \nunder the age of 18, Minor Victim-1 was enticed to travel from \nFlorida to New York for purposes of sexually abusing her at the \nNew York Residence, in violation of New York Penal Law, Section \n130.55. \nc. \nIn or about 1996, when Minor Victim-2 was \nunder the age of 18, MAXWELL provided Minor Victim-2 with an \n15 \nEFTA01659476\n", "char_count": 1305}, {"efta_number": "EFTA01659462", "page_number": 15, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 16 of 24 \nunsolicited massage in New Mexico, during which Minor Victim-2 \nwas topless. \nd. \nBetween in or about 1994 and in or about \n1995, when Minor Victim-3 was under the age of 18, MAXWELL \nencouraged Minor Victim-3 to provide massages to Epstein in \nLondon, England, knowing that Epstein intended to sexually abuse \nMinor Victim-3 during those massages. \ne. \nBetween in or about 2001 and in or about \n2002, when Minor Victim-4 was under the age of 18, MAXWELL and \nEpstein invited Minor Victim-4 to travel from Florida to a place \noutside of Florida with Epstein. \n(Title 18, United States Code, Section 371.) \nCOUNT FOUR \n(Transportation of a Minor with Intent to \nEngage in Criminal Sexual Activity) \nThe Grand Jury further charges: \n20. The allegations contained in paragraphs 1 through \n9 of this Indictment are repeated and realleged as if fully set \nforth within. \n21. From at least in or about 1994, up to and \nincluding in or about 1997, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did \ntransport an individual who had not attained the age of 18 years \nin interstate and foreign commerce, with the intent that the \nindividual engage in sexual activity for which a person can be \ncharged with a criminal offense, and attempted to do so, and \n16 \nEFTA01659477\n", "char_count": 1380}, {"efta_number": "EFTA01659462", "page_number": 16, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 17 of 24 \naided and abetted the same, to wit, MAXWELL arranged for Minor \nVictim-1 to be transported from Florida to New York, New York on \nmultiple occasions with the intention that Minor Victim-1 would \nengage in one or more sex acts with Jeffrey Epstein, in \nviolation of New York Penal Law, Section 130.55. \n(Title 18, United States Code, Sections 2423(a) and 2.) \nCOUNT FIVE \n(Sex Trafficking Conspiracy) \nThe Grand Jury further charges: \n22. The allegations contained in paragraphs 1 through \n9 of this Indictment are repeated and realleged as if fully set \nforth within. \n23. From at least in or about 2001, up to and \nincluding in or about 2004, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey \nEpstein, and others known and unknown, willfully and knowingly \ndid combine, conspire, confederate, and agree together and with \neach other to commit an offense against the United States, to \nwit, sex trafficking of minors, in violation of Title 18, United \nStates Code, Section 1591(a) and (b). \n24. It was a part and object of the conspiracy that \nGHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others \nknown and unknown, would and did, in and affecting interstate \nand foreign commerce, recruit, entice, harbor, transport, \nprovide, and obtain, by any means a person, and to benefit, \n17 \nEFTA01659478\n", "char_count": 1419}, {"efta_number": "EFTA01659462", "page_number": 17, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 18 of 24 \nfinancially and by receiving anything of value, from \nparticipation in a venture which has engaged in any such act, \nknowing that the person had not attained the age of 18 years and \nwould be caused to engage in a commercial sex act, in violation \nof Title 18, United States Code, Sections 1591(a) and (b) (2). \nOvert Acts \n25. In furtherance of the conspiracy and to effect \nthe illegal object thereof, the following overt acts, among \nothers, were committed in the Southern District of New York and \nelsewhere: \na. \nBetween in or about 2001 and in or about \n2004, Epstein and MAXWELL recruited Minor Victim-4 to engage in \nsex acts with EPSTEIN at the Palm Beach Residence, after which \nEpstein and, at times, MAXWELL provided Minor Victim-4 with \nhundreds of dollars in cash for each encounter. Minor Victim-4 \ntruthfully told both Epstein and MAXWELL her age. \nb. \nBetween in or about 2001 and in or about \n2004, Epstein and MAXWELL both encouraged and enticed Minor \nVictim-4 to recruit other girls to engage in paid sex acts with \nEpstein, which she did. \nc. \nBetween in or about 2001 and in or about \n2004, Epstein's employees, including at times MAXWELL, sent \nMinor Victim-4 gifts, including lingerie, from an address in the \nSouthern District of New York to Minor Victim-4's residence in \n18 \nEFTA01659479\n", "char_count": 1382}, {"efta_number": "EFTA01659462", "page_number": 18, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 19 of 24 \nFlorida. For example, on one occasion in or about October of \n2002, Epstein caused a package to be sent by Federal Express \nfrom an address in Manhattan to Minor Victim-4 in Florida. \nd. \nOn multiple occasions between in or about \n2001 and in or about 2004, Epstein, MAXWELL, or one of Epstein's \nother employees called Minor Victim-4 to schedule an appointment \nfor Minor Victim-4 to massage Epstein. For example, in or about \nApril of 2004 and May of 2004 another employee of Epstein's \ncalled Minor Victim-4 to schedule such appointments. \n(Title 18, United States Code, Section 371.) \nCOUNT SIX \n(Sex Trafficking of a Minor) \nThe Grand Jury further charges: \n26. The allegations contained in paragraphs 1 through \n9 of this Indictment are repeated and realleged as if fully set \nforth within. \n27. From at least in or about 2001, up to and \nincluding in or about 2004, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, willfully and \nknowingly, in and affecting interstate and foreign commerce, did \nrecruit, entice, harbor, transport, provide, and obtain by any \nmeans a person, knowing that the person had not attained the age \nof 18 years and would be caused to engage in a commercial sex \nact, and did aid and abet the same, to wit, MAXWELL recruited, \nenticed, harbored, transported, provided, and obtained \n19 \nEFTA01659480\n", "char_count": 1437}, {"efta_number": "EFTA01659462", "page_number": 19, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 20 of 24 \nindividuals who were less than 16 years old, including but not \nlimited to Minor Victim-4, as described above, and who were then \ncaused to engage in at least one commercial sex act with Jeffrey \nEpstein, and aided and abetted the same. \n(Title 18, United States Code, Section 1591(a), \n(b)(2), and 2.) \nCOUNT SEVEN \n(Perjury) \nThe Grand Jury further charges: \n28. The allegations contained in paragraphs 1 through \n9 of this Indictment are repeated and realleged as if fully set \nforth within. \n29. On or about April 22, 2016, in the Southern \nDistrict of New York, GHISLAINE MAXWELL, the defendant, having \ntaken an oath to testify truthfully in a deposition in \nconnection with a case then pending before the United States \nDistrict Court for the Southern District of New York under \ndocket number 15 Civ. 7433, knowingly made false material \ndeclarations, to wit, MAXWELL gave the following underlined \nfalse testimony: \nQ• \nDid Jeffrey Epstein have a scheme to recruit \nunderage girls for sexual massages? If you know. \nA. \nI don't know what you're talking about. \nQ. \nList all the people under the age of 18 that you \ninteracted with at any of Jeffrey's properties? \n20 \nEFTA01659481\n", "char_count": 1256}, {"efta_number": "EFTA01659462", "page_number": 20, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 21 of 24 \nA. \nI'm not aware of anybody that I interacted with, \nother than obviously [the plaintiff] who was 17 \nat this point. \n(Title 18, United States Code, Section 1623.) \nCOUNT EIGHT \n(Perjury) \nThe Grand Jury further charges: \n30. The allegations contained in paragraphs 1 through \n9 of this Indictment are repeated and realleged as if fully set \nforth within. \n31. On or about July 22, 2016, in the Southern \nDistrict of New York, GHISLAINE MAXWELL, the defendant, having \ntaken an oath to testify truthfully in a deposition in \nconnection with a case then pending before the United States \nDistrict Court for the Southern District of New York under \ndocket number 15 Civ. 7433, knowingly made false material \ndeclarations, to wit, MAXWELL gave the following underlined \nfalse testimony: \nQ: \nWere you aware of the presence of sex toys or \ndevices used in sexual activities in Mr. \nEpstein's Palm Beach house? \nA: \nNo, not that I recall. . . \nQ. \nDo you know whether Mr. Epstein possessed sex \ntoys or devices used in sexual activities? \nOther than yourself and the blond and brunette \n21 \nEFTA01659482\n", "char_count": 1166}, {"efta_number": "EFTA01659462", "page_number": 21, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 22 of 24 \nthat you have identified as having been involved \nin three-way sexual activities, with whom did Mr. \nEpstein have sexual activities? \nA. \nI wasn't aware that he was having sexual \nactivities with anyone when I was with him other \nthan myself. \nQ. \nI want to be sure that I'm clear. Is it your \ntestimony that in the 1990s and 2000s, you were \nnot aware that Mr. Epstein was having sexual \nactivities with anyone other than yourself and \nthe blond and brunette on those few occasions \nwhen they were involved with you? \nA. \nThat is my testimony, that is correct. \n• \ne \n• \nQ. \nIs it your testimony that you've never given \nanybody a massage? \nA. \nI have not given anyone a massage. \nQ. \nYou never gave Mr. Epstein a massage, is that \nyour testimony? \nA. \nThat is my testimony. \nQ• \nYou never gave [Minor Victim-2] a massage is your \ntestimony? \nA. \nI never gave [Minor Victim-2] a massage. \n(Title 18, United States Code, Section 1623.) \nFORFEITURE ALLEGATIONS \n32. As a result of committing the offense alleged in \nCount Six of this Indictment, GHISLAINE MAXWELL, the defendant, \nshall forfeit to the United States, pursuant to Title 18, United \nStates Code, Section 1594(c)(1), any property, real and \npersonal, that was used or intended to be used to commit or to \n22 \nEFTA01659483\n", "char_count": 1350}, {"efta_number": "EFTA01659462", "page_number": 22, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 23 of 24 \nfacilitate the commission of the offense alleged in Count Six, \nand any property, real or personal, constituting or derived from \nany proceeds obtained, directly or indirectly, as a result of \nthe offense alleged in Count Six, or any property traceable to \nsuch property. \nSubstitute Asset Provision \n33. If any of the above-described forfeitable \nproperty, as a result of any act or omission of the defendant: \n(a) cannot be located upon the exercise of due diligence; \n(b) has been transferred or sold to, or deposited with, a \nthird person; \n(c) has been placed beyond the jurisdiction of the Court; \n(d) has been substantially diminished in value; or \n(e) has been commingled with other property which cannot \nbe subdivided without difficulty; \nit is the intent of the United States, pursuant to 21 U.S.C. \n853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any \nother property of the defendant up to the value of the above \nforfeitable property. \n(Title 18, United States Code, Section 1594; Title 21, \nUnited States Code, Section 853; and \nTitle 28, United States Code, Section 2461.) \nFOREPERSON \nAUD\nY STRAUSS \nUnited States Attorney \n23 \nEFTA01659484\n", "char_count": 1229}, {"efta_number": "EFTA01659462", "page_number": 23, "text_content": "Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 24 of 24 \nForm No. USA-33s-274 (Ed. 9-25-58) \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUNITED STATES OF AMERICA \nv . \nGHISLAINE MAXWELL, \nDefendant. \nSUPERSEDING INDICTMENT \nS2 20 Cr. 330 (AJN) \n(18 U.S.C. §S 371, 1591, 1623, 2422, \n2423(a), and 2) \nAUDREY STRAUSS \nUnited States Attorney \n7  L \ni t  {- 71 \noreperson \n24 \nEFTA01659485\n", "char_count": 412}]}