UNITED STATES DISTRICT COURT [EFTA00008874]

UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUNITED STATES OF AMERICA \nGHISLAINE MAXWELL, \nDefendant. \nx \nx \nSEALED \nINDICTMENT \n20 Cr. \nCOUNT ONE \n(Conspiracy to Entice Minors to Travel to Engage in \nIllegal Sex Acts) \nThe Grand Jury charges: \nOVERVIEW \n1. \nThe charges set forth herein stem from the role \nof GHISLAINE MAXWELL, the defendant, in the sexual exploitation \nand abuse of multiple minor girls by Jeffrey Epstein. In \nparticular, from at least in or about 1994, up to and including \nat least in or about 1997, MAXWELL assisted, facilitated, and \ncontributed to Jeffrey Epstein's abuse of minor girls by, among \nother things, helping Epstein to recruit, groom, and ultimately \nabuse victims known to MAXWELL and Epstein to be under the age \nof 18. The victims were as young as 14 years old when they were \ngroomed and abused by MAXWELL and Epstein, both of whom knew \nthat certain victims were in fact under the age of 18. \n2. \nAs a part and in furtherance of their scheme to \nabuse minor victims, GHISLAINE MAXWELL, the defendant, and \nJeffrey Epstein enticed and caused minor victims to travel to \nGM_GLSDN Y_00000346 \nEFTA00008874\n\n2 \nEpstein's residences in different states, which MAXWELL knew and \nintended would result in their grooming for and subjection to \nsexual abuse. Moreover, in an effort to conceal her crimes, \nMAXWELL repeatedly lied when questioned about her conduct, \nincluding in relation to some of the minor victims described \nherein, when providing testimony under oath in 2016. \nFACTUAL BACKGROUND \n3. \nDuring the time periods charged in this \nIndictment, GHISLAINE MAXWELL, the defendant, had a personal and \nprofessional relationship with Jeffrey Epstein and was among his \nclosest associates. In particular, between in or about 1994 and \nin or about 1997, MAXWELL was in an intimate relationship with \nEpstein and also was paid by Epstein to manage his various \nproperties. Over the course of their relationship, MAXWELL and \nEpstein were photographed together on multiple occasions, \nincluding in the below image: \nGM_GLSDNY_00000347 \nEFTA00008875\n\n4. \nBeginning in at least 1994, GHISLAINE MAXWELL, \nthe defendant, enticed and groomed multiple minor girls to \nengage in sex acts with Jeffrey Epstein, through a variety of \nmeans and methods, including but not limited to the following: \na. \nMAXWELL first attempted to befriend some of \nEpstein's minor victims prior to their abuse, including by \nasking the victims about their lives, their schools, and their \nfamilies. MAXWELL and Epstein would spend time building \nfriendships with minor victims by, for example, taking minor \nvictims to the movies or shopping. Some of these outings would \ninvolve MAXWELL and Epstein spending time together with a minor \nvictim, while some would involve MAXWELL or Epstein spending \ntime alone with a minor victim. \nb. \nHaving developed a rapport with a victim, \nMAXWELL would try to normalize sexual abuse for a minor victim \nby, among other things, discussing sexual topics, undressing in \nfront of the victim, being present when a minor victim was \nundressed, and/or being present for sex acts involving the minor \nvictim and Epstein. \nc. \nMAXWELL'S presence during minor victims' \ninteractions with Epstein, including interactions where the \nminor victim was undressed or that involved sex acts with \nEpstein, helped put the victims at ease because an adult woman \nwas present. For example, in some instances, MAXWELL would \n3 \nGM_GLSDNY_00000348 \nEFTA00008876\n\nmassage Epstein in front of a minor victim. In other instances, \nMAXWELL encouraged minor victims to provide massages to Epstein, \nincluding sexualized massages during which a minor victim would \nbe fully or partially nude. Many of those massages resulted in \nEpstein sexually abusing the minor victims. \nd. \nIn addition, Epstein offered to help some \nminor victims by paying for travel and/or educational \nopportunities, and MAXWELL encouraged certain victims to accept \nEpstein's assistance. As a result, victims were made to feel \nindebted and believed that MAXWELL and Epstein were trying to \nhelp them. \ne. \nThrough this process, MAXWELL and Epstein \nenticed victims to engage in sexual activity with Epstein. In \nsome instances, MAXWELL was present for and participated in the \nsexual abuse of minor victims. Some such incidents occurred in \nthe context of massages, which developed into sexual encounters. \n5. \nGHISLAINE MAXWELL, the defendant, facilitated \nJeffrey Epstein's access to minor victims knowing that he had a \nsexual preference for underage girls and that he intended to \nengage in sexual activity with those victims. Epstein's \nresulting abuse of minor victims included, among other things, \ntouching a victim's breast, touching a victim's genitals, \nplacing a sex toy such as a vibrator on a victim's genitals, \n4 \nGM_GLSDNY_00000349 \nEFTA00008877\n\ndirecting a victim to touch Epstein while he masturbated, and \ndirecting a victim to touch Epstein's genitals. \nMAXWELL AND EPSTEIN'S VICTIMS \n6. \nBetween approximately in or about 1994 and in or \nabout 1997, GHISLAINE MAXWELL, the defendant, facilitated \nJeffrey Epstein's access to minor victims by, among other \nthings, inducing and enticing, and aiding and abetting the \ninducement and enticement of, multiple minor victims. Victims \nwere groomed and/or abused at multiple locations, including the \nfollowing: \na. \nA a multi-story private residence on the \nUpper East Side of Manhattan, New York owned by Epstein (the \n"New York Residence"), which is depicted in the following \nphotograph: \nGM_GLSDNY_00000350 \nEFTA00008878\n\n6 \nb. \nAn estate in Palm Beach, Florida owned by \nEpstein (the "Palm Beach Residence"), which is depicted in the \nfollowing photograph: \nc. \nA ranch in Santa Fe, New Mexico owned by \nEpstein (the "New Mexico Residence"), which is depicted in the \nfollowing photograph: \nGNI_GLSDNYJMNB51 \nEFTA00008879\n\nd. \nMAXWELL's personal residence in London, \nEngland. \n7. \nAmong the victims induced or enticed by GHISLAINE \nMAXWELL, the defendant, were minor victims identified herein as \nMinor Victim-1, Minor Victim-2, and Minor Victim-3. In \nparticular, and during time periods relevant to this Indictment, \nMAXWELL engaged in the following acts, among others, with \nrespect to minor victims: \na. \nMAXWELL met Minor Victim-1 when Minor \nVictim-1 was approximately 14 years old. MAXWELL subsequently \ninteracted with Minor Victim-1 on multiple occasions at \nEpstein's residences, knowing that Minor Victim-1 was under the \nage of 18 at the time. During these interactions, which took \nplace between approximately 1994 and 1997, MAXWELL groomed Minor \nVictim-1 to engage in sexual acts with Epstein through multiple \nmeans. First, MAXWELL and Epstein attempted to befriend Minor \nVictim-1, taking her to the movies and on shopping trips. \nMAXWELL also asked Minor Victim-1 about school, her classes, her \nfamily, and other aspects of her life. MAXWELL then sought to \nnormalize inappropriate and abusive conduct by, among other \nthings, undressing in front of Minor Victim-1 and being present \nwhen Minor Victim-1 undressed in front of Epstein. Within the \nfirst year after MAXWELL and Epstein met Minor Victim-1, Epstein \nbegan sexually abusing Minor Victim-1. MAXWELL was present for \n7 \nGM_GLSDNY_00000352 \nEFTA00008880\n\nand involved in some of this abuse. In particular, MAXWELL \ninvolved Minor Victim-1 in group sexualized massages of Epstein. \nDuring those group sexualized massages, MAXWELL and/or Minor \nVictim-1 would engage in sex acts with Epstein. Epstein and \nMAXWELL both encouraged Minor Victim-1 to travel to Epstein's \nresidences in both New York and Florida. As a result, Minor \nVictim-1 was sexually abused by Epstein in both New York and \nFlorida. Minor Victim-1 was enticed to travel across state \nlines for the purpose of sexual encounters with Epstein, and \nMAXWELL was aware that Epstein engaged in sexual activity with \nMinor Victim-1 after Minor-Victim-1 traveled to Epstein's \nproperties, including in the context of a sexualized massage. \nb. \nMAXWELL interacted with Minor Victim-2 on at \nleast one occasion in or about 1996 at Epstein's residence in \nNew Mexico when Minor Victim-2 was under the age of 18. Minor \nVictim-2 had flown into New Mexico from out of state at \nEpstein's invitation for the purpose of being groomed for and/or \nsubjected to acts of sexual abuse. MAXWELL knew that Minor \nVictim-2 was under the age of 18 at the time. While in New \nMexico, MAXWELL and Epstein took Minor Victim-2 to a movie and \nMAXWELL took Minor Victim-2 shopping. MAXWELL also discussed \nMinor Victim-2's school, classes, and family with Minor Victim-\n2. In New Mexico, MAXWELL began her efforts to groom Minor \nVictim-2 for abuse by Epstein by, among other things, providing \n8 \nGM_GLSDNY_00000353 \nEFTA00008881\n\nan unsolicited massage to Minor Victim-2, during which Minor \nVictim-2 was topless. MAXWELL also encouraged Minor Victim-2 to \nmassage Epstein. \nc. \nMAXWELL groomed and befriended Minor \nVictim-3 in London, England between approximately 1994 and 1995, \nincluding during a period of time in which MAXWELL knew that \nMinor Victim-3 was under the age of 18. Among other things, \nMAXWELL discussed Minor Victim-3's life and family with Minor \nVictim-3. MAXWELL introduced Minor Victim-3 to Epstein and \narranged for multiple interactions between Minor Victim-3 and \nEpstein. During those interactions, MAXWELL encouraged Minor \nVictim-3 to massage Epstein, knowing that Epstein would engage \nin sex acts with Minor Victim-3 during those massages. Minor \nVictim-3 provided Epstein with the requested massages, and \nduring those massages, Epstein sexually abused Minor Victim-3. \nMAXWELL was aware that Epstein engaged in sexual activity with \nMinor Victim-3 on multiple occasions, including at times when \nMinor Victim-3 was under the age of 18, including in the context \nof a sexualized massage. \nMAXWELL'S EFFORTS TO CONCEAL HER CONDUCT \n8. \nIn or around 2016, in the context of a deposition \nas part of civil litigation, GHISLAINE MAXWELL, the defendant, \nrepeatedly provided false and perjurious statements, under oath, \nregarding, among other subjects, her role in facilitating the \n9 \nGM_GJ_SDNY_00000354 \nEFTA00008882\n\nabuse of minor victims by Jeffrey Epstein, including some of the \nspecific events and acts of abuse detailed above. \nSTATUTORY ALLEGATIONS \n9. \nFrom at least in or about 1994, up to and \nincluding in or about 1997, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey \nEpstein, and others known and unknown, willfully and knowingly \ndid combine, conspire, confederate, and agree together and with \neach other to commit an offense against the United States, to \nwit, enticement, in violation of Title 18, United States Code, \nSection 2422. \n10. It was a part and object of the conspiracy that \nGHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others \nknown and unknown, would and did knowingly persuade, induce, \nentice, and coerce one and more individuals to travel in \ninterstate and foreign commerce, to engage in sexual activity \nfor which a person can be charged with a criminal offense, in \nviolation of Title 18, United States Code, Section 2422. \nOvert Acts \n11. In furtherance of the conspiracy and to effect \nthe illegal object thereof, the following overt acts, among \nothers, were committed in the Southern District of New York and \nelsewhere: \n10 \nGM_GLSDN Y_00000355 \nEFTA00008883\n\na. \nBetween in or about 1994 and in or about \n1997, when Minor Victim-1 was under the age of 18, MAXWELL \nparticipated in multiple group sexual encounters with Epstein \nand Minor Victim-1 in New York and Florida. \nb. \nIn or about 1996, when Minor Victim-1 was \nunder the age of 18, Minor Victim-1 was enticed to travel from \nFlorida to New York for purposes of sexually abusing her at the \nNew York Residence, in violation of New York Penal Law, Section \n130.55. \nc. \nIn or about 1996, when Minor Victim-2 was \nunder the age of 18, MAXWELL provided Minor Victim-2 with an \nunsolicited massage in New Mexico, during which Minor Victim-2 \n• \nwas topless. \nd. \nBetween in or about 1994 and in or about \n1995, when Minor Victim-3 was under the age of 18, MAXWELL \nencouraged Minor Victim-3 to provide massages to Epstein in \nLondon, England, knowing that Epstein intended to sexually abuse \nMinor Victim-3 during those massages. \n(Title 18, United States Code, Section 371.) \nCOUNT TWO \n(Enticement of a Minor to Travel to Engage in Illegal Sex Acts) \nThe Grand Jury further charges: \n12. The allegations contained in paragraphs 1 \nthrough 8 of this Indictment are repeated and realleged as if \nfully set forth within. \n11 \nGM_GJ_SDNY_00000356 \nEFTA00008884\n\n13. From at least in or about 1994, up to and \nincluding in or about 1997, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did \npersuade, induce, entice, and coerce an individual to travel in \ninterstate and foreign commerce to engage in sexual activity for \nwhich a person can be charged with a criminal offense, and \nattempted to do the same, and aided and abetted the same, to \nwit, MAXWELL persuaded, induced, enticed, and coerced Minor \nVictim-1 to travel from Florida to New York, New York on \nmultiple occasions with the intention that Minor Victim-1 would \nengage in one or more sex acts with Jeffrey Epstein, in \nviolation of New York Penal Law, Section 130.55. \n(Title 18, United States Code, Sections 2422 and 2.) \nCOUNT THREE \n(Conspiracy to Transport Minors with Intent to \nEngage in Criminal Sexual Activity) \nThe Grand Jury further charges: \n14. The allegations contained in paragraphs 1 \nthrough 8 of this Indictment are repeated and realleged as if \nfully set forth within. \n15. From at least in or about 1994, up to and \nincluding in or about 1997, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey \nEpstein, and others known and unknown, willfully and knowingly \ndid combine, conspire, confederate, and agree together and with \neach other to commit an offense against the United States, to \n12 \nGM_GJ_SDNY_00000357 \nEFTA00008885\n\nwit, transportation of minors, in violation of Title 18, United \nStates Code, Section 2423(a). \n16. It was a part and object of the conspiracy that \nGHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others \nknown and unknown, would and did, knowingly transport an \nindividual who had not attained the age of 18 in interstate and \nforeign commerce, with intent that the individual engage in \nsexual activity for which a person can be charged with a \ncriminal offense, in violation of Title 18, United States Code, \nSection 2423(a). \nOvert Acts \n17. In furtherance of the conspiracy and to effect \nthe illegal object thereof, the following overt acts, among \nothers, were committed in the Southern District of New York and \nelsewhere: \na. \nBetween in or about 1994 and in or about \n1997, when Minor Victim-1 was under the age of 18, MAXWELL \nparticipated in multiple group sexual encounters with EPSTEIN \nand Minor Victim-1 in New York and Florida. \nb. \nIn or about 1996, when Minor Victim-1 was \nunder the age of 18, Minor Victim-1 was enticed to travel from \nFlorida to New York for purposes of sexually abusing her at the \n13 \nGM_GLSDNY_00000358 \nEFTA00008886\n\nNew York Residence, in violation of New York Penal Law, Section \n130.55. \nc. \nIn or about 1996, when Minor Victim-2 was \nunder the age of 18, MAXWELL provided Minor Victim-2 with an \nunsolicited massage in New Mexico, during which Minor Victim-2 \nwas topless. \nd. \nBetween in or about 1994 and in or about \n1995, when Minor Victim-3 was under the age of 18, MAXWELL \nencouraged Minor Victim-3 to provide massages to Epstein in \nLondon, England, knowing that Epstein intended to sexually abuse \nMinor Victim-3 during those massages. \n(Title 18, United States Code, Section 371.) \nCOUNT FOUR \n(Transportation of a Minor with Intent to \nEngage in Criminal Sexual Activity) \nThe Grand Jury further charges: \n18. The allegations contained in paragraphs 1 \nthrough 8 of this Indictment are repeated and realleged as if \nfully set forth within. \n19. From at least in or about 1994, up to and \nincluding in or about 1997, in the Southern District of New York \nand elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did \ntransport an individual who had not attained the age of 18 in \ninterstate and foreign commerce, with the intent that the \nindividual engage in sexual activity for which a person can be \ncharged with a criminal offense, and attempted to do so, and \n14 \nGM_GLSDN Y_00000359 \nEFTA00008887\n\naided and abetted the same, to wit, MAXWELL arranged for Minor \nvictim-1 to be transported from Florida to New York, New York on \nmultiple occasions with the intention that Minor Victim-1 would \nengage in one or more sex acts with Jeffrey Epstein, in \nviolation of New York Penal Law, Section 130.55. \n(Title 18, United States Code, Sections 2423(a) and 2.) \nCOUNT FIVE \n(Perjury) \nThe Grand Jury further charges: \n20. The allegations contained in paragraphs 1 \nthrough 8 of this Indictment are repeated and realleged as if \nfully set forth within. \n21. On or about April 22, 2016, in the Southern \nDistrict of New York, GHISLAINE MAXWELL, the defendant, having \ntaken an oath to testify truthfully in a deposition in \nconnection with a case then pending before the United States \nDistrict Court for the Southern District of New York under \ndocket number 15 Civ. 7344, knowingly made false material \ndeclarations, to wit, MAXWELL gave the following underlined \nfalse testimony: \nQ. \nDid Jeffrey Epstein have a scheme to recruit \nunderage girls for sexual massages? If you know. \nA. \nI don't know what you're talking about. \n• \n• \n• \n15 \nGM_GLSDN Y_00000360 \nEFTA00008888\n\nQ• \nList all the people under the age of 18 that you \ninteracted with at any of Jeffrey's properties? \nA. \nI'm not aware of anybody that I interacted with, \nother than obviously [the plaintiff] who was 17 \nat this point. \n(Title 18, United States Code, Section 1623.) \nCOUNT SIX \n(Perjury) \nThe Grand Jury further charges: \n22. The allegations contained in paragraphs 1 \nthrough 8 of this Indictment are repeated and realleged as if \nfully set forth within. \n23. On or about July 22, 2016, in the Southern \nDistrict of New York, GHISLAINE MAXWELL, the defendant, having \ntaken an oath to testify truthfully in a deposition in \nconnection with a case then pending before the United States \nDistrict Court for the Southern District of New York under \ndocket number 15 Civ. 7344, knowingly made false material \ndeclarations, to wit, MAXWELL gave the following underlined \nfalse testimony: \nQ: \nWere you aware of the presence of sex toys or \ndevices used in sexual activities in Mr. \nEpstein's Palm Beach house? \nA: \nNo, not that I recall. . . \nQ• \nDo you know whether Mr. Epstein possessed sex \ntoys or devices used in sexual activities? \nA. \nNo. \n16 \nONLGLSDNY2WENBM \nEFTA00008889\n\nQ. \nOther than yourself and the blond and brunette \nthat you have identified as having been involved \nin three-way sexual activities, with whom did Mr. \nEpstein have sexual activities? \nA. \nI wasn't aware that he was having sexual \nactivities with anyone when I was with him other \nthan myself. \nQ• \nI want to be sure that I'm clear. Is it your \ntestimony that in the 1990s and 2000s, you were \nnot aware that Mr. Epstein was having sexual \nactivities with anyone other than yourself and \nthe blond and brunette on those few occasions \nwhen they were involved with you? \nA. \nThat is my testimony, that is correct. \n• • • \nQ. \nIs it your testimony that you've never given \nanybody a massage? \nA. \nI have not given anyone a massage. \nQ. \nYou never gave Mr. Epstein a massage, is that \nyour testimony? \nA. \nThat is my testimony. \nQ• \nYou never gave [Minor Victim-2] a massage is your \ntestimony? \nA. \nI never gave [Minor Victim-2] a massage. \n(Title 18, United States Code, Section 1623.) \nFOREPERSON \n17 \nAUDREY S RAUSS \nActing nited States Attorney \nGM_GLSDNY_00000362 \nEFTA00008890\n\nForm No. USA-33s-274 (Ed. 9-25-58) \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUNITED STATES OF AMERICA \nv. \nGHISLAINE MAXWELL, \nDefendant. \nINDICTMENT \n(18 U.S.C. §§ 371, 1623, 2422, 2423(e), \nand 2) \nAUDREY STRAUSS \nActing United States Attorney \nForeperson \n18 \nGM_GLSDNY_00000363 \nEFTA00008891