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2020.09.28_Exhibit_D

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 IN THE SUP.ERJOR COURT
  OFTHE VIRGIN ISLA DS        Case 1:20-cr-00330-AJN Document 1 Filed 06/29/20 Page 1 of 18

  FILED
 September 28, 2020

 TAMARA CHARLES
CLERK OF THE COURT
                UNITED STATES DISTRICT COURT
                SOUTHERN DISTRICT OF NEW YORK
                 -    -   -   -   -   -    -   -    -   -   -   -   -     X
                                                                                   SEALED
                     UNITED STATES OF AMERICA                                      INDICTMENT

                                                                                   20 Cr.

                     GHISLAINE MAXWELL ,

                                          Defendant.
                                                                                   20 Cr. 330
                                                                          X


                                                       COUNT ONE
                                  (Conspiracy to Entice Minors to Travel to Engage in
                                                   Illegal ~ex Acts)

                                      The Grand Jury charges:

                                                                        OVERVIEW

                                      1.           The charges set forth herein stem from the role

                of GHISLAINE MAXWELL, the defendant, in the sexual exploitation

                and abuse of multiple minor girls by Jeffrey Epstein.                           In

                particular, from at least in or about 1994, up to and including

                at least in or about 1997, MAXWELL assisted, facilitated, and

                contributed to Jeffrey Epstein's abuse of minor girls by, among

                other things, helping Epstein to recruit, groom, and ultimately

                abuse victims known to MAXWELL and Epstein to be under the age

                of 18.            The victims were as young 

[…]

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