EFTA00080532Set 9
18p3,185w
GHISLAINE MAXWELL,
Defendant.
20 Cr. 330
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1. The charges ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00080532.pdf
EFTA00082145Set 9
2020-07-0818p3,380w
GHISLAINE MAXWELL,
Defendant.
x
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 ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00082145.pdf
EFTA00089823Set 9
18p3,185w
GHISLAINE MAXWELL,
Defendant.
20 Cr. 330
X
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW
1. The charges ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00089823.pdf
EFTA00152328Set 9
18p3,389w
STATES OF AMERICA INDICTMENT
20 Cr.
GHISLAINE MAXWELL,
Defendant.
COUNT ONE
(Conspiracy to Entice Minors to Travel to Engage in
Illegal Sex Acts)
The Grand Jury charges:
OVERVIEW ... 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00152328.pdf
EFTA00079409Set 9
2007-07-2592p17,481w
statute which proscribes "pro
and "lewdness", regardless of whether an adu stitution"
lt or minor is involved, is of very limited
applicability here. That statute's definitio
n of"prostitution ... would show that
in what may possibly be characterized as sexu only a small minority of massages resulted
al activity with a woman under the age of
even where ... investigative efforts on the use of the
Internet to lure infants and minors, 3-14 years-old. Of those
115 cases, 71 involved the use of Internet chat
rooms
https://www.justice.gov/epstein/files/DataSet%209/EFTA00079409.pdf
EFTA00153059Set 9
2019-07-06102p25,840w
have been involved in the investigation of cases involving sex
trafficking, enticement of minors, and transportation of minors for illegal sex acts, and have
participated in the execution of search ... instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex
trafficking of minors) and 371 (conspiracy to commit sex trafficking) (the "Original Subject
Offenses.")
12. For the reasons ... criminal law, including violations of Title 18, United States Code, Sections 2422
(transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to commit
transportation of minors and enticement
https://www.justice.gov/epstein/files/DataSet%209/EFTA00153059.pdf
EFTA00076712Set 9
2019-07-06102p25,844w
have been involved in the investigation of cases involving sex
trafficking, enticement of minors, and transportation of minors for illegal sex acts, and have
participated in the execution of search ... instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex
trafficking of minors) and 371 (conspiracy to commit sex trafficking) (the "Original Subject
Offenses.")
12. For the reasons ... criminal law, including violations of Title 18, United States Code, Sections 2422
(transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to commit
transportation of minors and enticement
https://www.justice.gov/epstein/files/DataSet%209/EFTA00076712.pdf
EFTA01099943Set 9
2006-07-2632p10,791w
U.S.C. § 2255 in effect when the predicate acts
allegedly were committed allow only "minors" to file suit. Rule 56, Fed.R.Civ.P. (2010);
Local Oen. Rules ... U.S.C. § 2255 in effect when the predicate acts
allegedly were committed allow only "minors" to file suit. The pleadings and the
discovery materials on file show that there ... EXPLOITATION AND OTHER ABUSE OF CHILDREN
§ 2255. Civil remedy for personal injuries
(a) Any minor wbo is a victim of a violation of section 2241(c), 2242, 2243, 2251,
2251k
https://www.justice.gov/epstein/files/DataSet%209/EFTA01099943.pdf
EFTA01723963Set 10
100p18,558w
working at Bear Stearns you were already engaging
13 in sex with underage minors?
14 A Again, I believe you know the answers to
15 those questions ... working at Bear
16 Stearns you were already engaging in sex with
17 underage minor females?
18 A As your firm has been described by the
19 U.S. Attorney ... that
EFTA01723975
25
1 • Ghislaine Maxwell shares your sexual obsession
2 for underage minor females?
3 MR. ■: Argumentative, speculation,
4 harassing.
S A You know, Mr. the current
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01723963.pdf
EFTA00160044Set 9
2019-07-0232p6,383w
Code Section(s) Offense Description(s)
18 U.S.C. §§ 1591 and Sex trafficking of minors; sex trafficking conspiracy
371
The application is based on these facts:
See Attached Affidavit ... Title 18, United
2
2017.08.02
EFTA00160046
States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section
371 (sex trafficking conspiracy) (the "Subject Offenses ... including at least
in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern
District of New York and elsewhere. During that time and continuing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00160044.pdf
EFTA00257690Set 9
70p11,999w
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy ... Code Seetion(s) Offense Description(s)
18 U.S.C. §§ 1591 and Sex trafficking of minors; sex trafficking conspiracy
371
The application is based on these facts:
See Attached Affidavit ... ofTitle 18. United
2
2017 08.02
EFTA00257725
States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Codc, Section
371 (sex trafficking conspiracy) (the "Subject Offenses
https://www.justice.gov/epstein/files/DataSet%209/EFTA00257690.pdf
EFTA00164797Set 9
2019-07-0236p7,554w
Code Section(s) Offense Description(s)
18 U.S.C. §§ 1591 & 371 Sex trafficking of minors; sex trafficking conspiracy
The application is based on these facts:
See Attached Affidavit and its Attachment ... Title 18, United
2
2017.08.02
EFTA00164799
States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section
371 (sex trafficking conspiracy) (the "Subject Offenses ... including at least
in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern
District of New York and elsewhere. During that time and continuing
https://www.justice.gov/epstein/files/DataSet%209/EFTA00164797.pdf
EFTA01648851Set 10
2019-07-0236p7,580w
Code Section(s) Offense Description(s)
18 U.S.C. §§ 1591 & 371 Sex trafficking of minors; sex trafficking conspiracy
The application is based on these facts:
See Attached Affidavit and its Attachment ... Title 18, United
2
2017.08.02
EFTA01648853
States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section
371 (sex trafficking conspiracy) (the "Subject Offenses ... including at least
in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern
District of New York and elsewhere. During that time and continuing
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01648851.pdf
EFTA00725998Set 9
2010-03-1739p12,410w
Deposition of Jane Doe, September 24, 2009 and
continued March 11, 2010, at 527 (minor girl sexually abused at least 17 times by Epstein) (hereinafter
"Jane Doe Depo") (Deposition Attachment ... outlines some of the experiences of other Epstein victims. Whet,
a 14 year old minor at the time, was brought to Epstein's home, she was taken upstairs ... very tiny." Id. at 15.
4. The exact number of minor girls who Epstein assaulted is known only to Epstein.
However, Edwards had a good basis to believe
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725998.pdf
EFTA01657895Set 10
2007-01-1615p3,969w
become
concerned with the passing references to sexual contact
between Defendant and other minors made not only at
sentencing, but elsewhere in the record ... Court.
THE COURT: . . . There has been some reference to another
incident with a minor girl. What do you know about that,
if anything?
MS. VILLAFANA: Your Honor, there ... other minor
girls that have been
THE COURT: You mean in addition to the victim in this
case?
MS. VILLAFANA: Yes, your honor.
THE COURT: Go ahead.
MS. VILLAFANA
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01657895.pdf
EFTA00081947Set 9
2019-07-0833p10,720w
there is probable cause to believe that the person
committed . . an offense involving a minor victim under section . .. 1591," then "it shall he
presumed that no condition or combination ... with
"victims" of the crimes charged in the Indictment. Victims refer to the "minor" girls who arc
alleged to have been sexually trafficked by the Defendant. Under 18 U.S.C ... Beach, Florida, in connection with
allegations that he had committed similar sex offenses against minor girls. The investigation
ultimately also involved federal authorities, namely the U.S. Attorney's Office
https://www.justice.gov/epstein/files/DataSet%209/EFTA00081947.pdf