EPSTEIN
page 4 / 16 . OCR, unverified
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
Case 1:20-mj-00132-AJ Document 1 Filed 07/02/20 Page 13 of 19
13.
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, knowingly did
persuade, induce, entice, and coerce an individual to travel in
interstate and foreign commerce to engage in sexual activity for
which a person can be charged with a criminal offense, and
attempted to do the same, and aided and abetted the same, to
wit, MAXWELL persuaded, induced, enticed, and coerced Minor
Victim-1 to travel from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2422 and 2.)
COUNT THREE
(Conspiracy to Transport Minors with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
.
The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
15.
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
Case 1:20-mj-00132-AJ Document 1 Filed 07/02/20 Page 14 of 19
wit, transportation of minors, in violation of Title 18, United
States Code, Section 2423(a).
16.
It was a part and object of the conspiracy that
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others
known and unknown, would and did, knowingly transport an
individual who had not attained the age of 18 in interstate and
foreign commerce, with intent that the individual engage in
sexual activity for which a person can be charged with a
criminal offense, in violation of Title 18, United States Code,
Section 2423(a).
Overt Acts
17.
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:
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
Case 1:20-mj-00132-AJ Document 1 Filed 07/02/20 Page 15 of 19
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 FOUR
(Transportation of a Minor with Intent to
Engage in Criminal Sexual Activity)
The Grand Jury further charges:
18.
The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
19.
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, knowingly did
transport an individual who had not attained the age of 18 in
interstate and foreign commerce, with the intent that the
individual engage in sexual activity for which a person can be
charged with a criminal offense, and attempted to do so, and
Case 1:20-mj-00132-AJ Document 1 Filed 07/02/20 Page 16 of 19
"
aided and abetted the same, to wit, MAXWELL arranged for Minor
Victim-1 to be transported from Florida to New York, New York on
multiple occasions with the intention that Minor Victim-1 would
engage in one or more sex acts with Jeffrey Epstein, in
violation of New York Penal Law, Section 130.55.
(Title 18, United States Code, Sections 2423(a) and 2.)
COUNT FIVE
(Perjury}
The Grand Jury further charges:
20.
The allegations contained in paragraphs 1
through 8 of this Indictment are repeated and realleged as if
fully set forth within.
21.
On or about April 22, 2016, in the Southern
District of New York, GHISLAINE MAXWELL, the defendant, having
taken an oath to testify truthfully in a deposition in
connection with a case then pending before the United States
District Court for the Southern District of New York under