EPSTEIN
page 3 / 16 . OCR, unverified
Florida.
Minor Victim-1 was enticed to travel across state
lines for the purpose of sexual encounters with Epstein, and
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's
properties, including in the context of a sexualized massage.
b.
MAXWELL interacted with Minor Victim-2 on at
least one occasion in or about 1996 at Epstein's residence in
New Mexico when Minor Victim-2 was under the age of 18.
Minor
Victim-2 had flown into New Mexico from out of state at
Epstein's invitation for the purpose of being groomed for and/or
subjected to acts of SBxual abuse.
MAXWELL knew that Minor
Victim-2 was under the age of 18 at the time.
While in New
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and
MAXWELL took Minor Victim-2 shopping.
MAXWELL also discussed
Minor Victim-2's school, classes, and family with Minor Victim-
2.
In New Mexico, MAXWELL began her efforts to groom Minor
Victim-2 for abuse by Epstein by, among other things, providing
Case 1:20-mj-00132-AJ Document 1 Filed 07/02/20 Page 10 of 19
. an unsolicited massage to Minor Victim-2, during which Minor
Victim-2 was topless.
MAXWELL also encouraged Minor Victim-2 to
massage Epstein.
c.
MAXWELL groomed and befriended Minor
Victim-3 in London, England between approximately 1994 and 1995,
including during a period of time in which MAXWELL knew that
Minor Victim-3 was under the age of 18.
Among other things,
MAXWELL discussed Minor Victim-3's life and family with Minor
Victim-3.
MAXWELL introduced Minor Victim-3 to Epstein and
arranged for multiple interactions between Minor Victim-3 and
Epstein.
During those interactions, MAXWELL encouraged Minor
Victim-3 to massage Epstein, knowing that Epstein would engage
in sex acts with Minor Victim-3 during those massages.
Minor
Victim-3 provided Epstein with the requested massages, and
during those massages, Epstein sexually abused Minor Victim-3.
MAXWELL was aware that Epstein engaged in sexual activity with
Minor Victim-3 on multiple occasions, including at times when
Minor Victim-3 was under the age of 18, including in the context
of a sexualized massage.
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT
8.
In or around 2016, .in the context of a deposition
as part of civil litigation, GHISLAINE MAXWELL, the defendant,
repeatedly provided false and perjurious statements, under oath,
regarding, among other subjects, her role in facilitating the
Case 1:20-mj-00132-AJ Document 1 Filed 07/02/20 Page 11 of 19
abuse of minor victims by Jeffrey Epstein, including some of the
specific events and acts of abuse detailed above.
STATUTORY ALLEGATIONS
9.
From at least in or about 1994, up to and
including in or about 1997, in the Southern District of New York
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey
Epstein, and others known and unknown, willfully and knowingly
did combine, conspire, confederate, and agree together and with
each other to commit an offense against the United States, to
wit, enticement, in violation of Title 18, United States Code,
Section 2422.
10.
It was a part and object of the conspiracy that
G~ISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did knowingly persuade, induce,
entice, and coerce one and more individuals to travel in
interstate and foreign commerce, to engage in sexual activity
for which a person can be charged with a criminal offense, in
violation of Title 18, United States Code, Section 2422.
Overt Acts
11.
In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
Case 1:20-mj-00132-AJ Document 1 Filed 07/02/20 Page 12 of 19
'
a.
Between in or about 1994 and in or about
1997, when Minor Victim-1 was under the age of 18, MAXWELL
participated in multiple group sexual encounters with Epstein
and Minor Victim-1 in New York and Florida.
b.
In or about 1996, when Minor Victim-1 was
under the age of 18, Minor Victim-1 was enticed to travel from
Florida to New York for purposes of sexually abusing her at the
New York Residence, in violation of New York Penal Law, Section
130.55.
c.
In or about 1996, when Minor Victim-2 was
under the age of 18, MAXWELL provided Minor Victim-2 with an
unsolicited massage in New Mexico, during which Minor Victim-2
was topless.
d.
Between in or about 1994 and in or about
1995, when Minor Victim-3 was under the age of 18, MAXWELL
encouraged Minor Victim-3 to provide massages to Epstein in
London, England, knowing that Epstein intended to sexually abuse
Minor Victim-3 during those massages.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Enticement of a Minor to Travel to Engage in Illegal Sex Acts)
The Grand Jury further charges:
12.
The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if