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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
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UNITED STATES OF AMERICA SUPERSEDING INDICTMENT
-— VW, S82 20 Cr. 330 (AJN)
GHISLAINE MAXWELL,
Defendant.
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COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1s The charges set forth herein stem from the role
of GHISLAINE MAXWELL, the defendank, 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