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DOJ-OGR-00002843

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Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page1of24 ORIGINAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK   —- eee eee ----+--+-+---+ x UNITED STATES OF AMERICA SUPERSEDING INDICTMENT ~ V. 7 S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. ~- +--+ eee ee LK COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW 1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the dafandank » 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 2004, 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 as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18. 2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to DOJ-OGR-00002843 

Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page 2 of 24 Epstein’s residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse. Moreover, in an effort to conceal her crimes, MAXWELL repeatedly lied when questioned about her conduct, including in relation to some of the minor victims described   herein, when providing testimony under oath in 2016. FACTUAL BACKGROUND 3. During the time periods charged in this   Indictment, GHISLAINE MAXWELL, the defendant, had a personal and professional relationship with Jeffrey Epstein and was among his closest associates. In particular, between in or about 1994 and in or about 1997, MAXWELL was in an intimate relationship with

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