From: USANYS)" <
To: at al YS)" c (USANYS)"
Subject: RE: Maxwell / Transition
Date: Tue, 29 Dec 2020 21:30:09 +0000
United States v. Ghislaine Maxwell. 20 Cr. 330 (AIN): In July 2020, Maxwell was charged in a six-count indictment with
facilitating the sexual abuse of three minor victims by Jeffrey Epstein between approximately 1994 and 1997. The charges
resulted from a multi-year investigation by the USAO-SDNY and the FBI into Jeffrey Epstein and his co-conspirators,
including Maxwell. Maxwell played a critical role in the scheme by helping to identify, entice, and groom minor girls to
engage in sex acts with Epstein. Her presence as an adult woman normalized Epstein's abusive behavior, and she even
took part in at least some acts of sexual abuse. Maxwell and Epstein enticed and caused minor victims to travel to
Epstein's residences in different states, which Maxwell knew and intended would result in their grooming for and
subjection to sexual abuse, resulting in charges related to the enticement and transportation of minors to participate in
illegal sex acts, and conspiracy to do the same, in violation of 18 U.S.C. § 2422, 2423, and 371. Then, in an effort to cover
up her crimes, the defendant lied under oath during a civil deposition, including when asked about her interactions with
minor girls, resulting in two perjury charges, in violation of 18 U.S.C. § 1623. Maxwell has been detained since her arrest,
and the Court has denied two separate bail motions, most recently as of December 28, 2020. Trial is scheduled for July
2021, and pretrial motions are due in January 2021. The most recent press release is located here:
https://www.justice.gov/usao-sdnybalghislaine-maxwell-charged-manhattan-federal-court-conspiring-jeffrey-epstein-
sexually .
From: (USANYS)
Sent: Tuesday, December 29, 2020 11:56 AM
To:(USANYS); (USANYS)
Subject: RE: Maxwell / Transition
Ideally tomorrow? The description of the case / status need be no more than a paragraph or so.
From: Donaleski, Rebekah (USANYS)
Sent: Tuesday, December 29, 2020 11:53 AM
To: (USANYS) (USANYS) c =>
Subject: RE: Maxwell /Transition
Sure, when do you need this by?
From: (USANYS)
Sent: Tuesday, December 29, 2020 11:44 AM
To: (USANYS) USANYS)
Subject: Maxwell / Transition
Hope you are enjoying the holidaysl All USAOs have been asked to send a writeup of our two most significant publicly
filed criminal cases (and one civil case) to the transition. We're going to include Maxwell as one of the two. Would you
guys mind putting together a writeup? We have been asked to include the following information:
Case name
Docket number
Brief description of the charges/claims
Current case status
Link to most recent press release (if applicable)
Counsel to the Acting U.S. Attorney
United States Attorney's Office
Southern District ofNew York
EFTA00031580