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Case 21-770, Document 40-1, 04/12/2021, 3075763, Page4 of 25 front of a victim, being present when a minor victim was undressed, and/or being present for sex acts involving a minor victim and Epstein. (Ind. §] 4(b)). Maxwell’s presence as an adult woman normalized Epstein’s abusive behavior, and she took part in at least some acts of sexual abuse. (Ind. {[f| 4(c), (e)). To make victims feel indebted to Epstein, Maxwell encouraged victims to accept Epstein’s offers of financial assistance. (Ind. {| 4(d)). The victims were as young as 14 years old when they were groomed and abused by Maxwell and Epstein, both of whom knew that their victims were minors. (Ind. {| 1). 7. Together, Maxwell and Epstein conspired to entice and cause 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. (Ind. {] 2). To conceal her crimes, Maxwell lied under oath during a civil deposition, including when asked about her interactions with minor girls. (Ind. § 2). 8. The Indictment contains detailed speaking allegations which describe: the means and methods of Maxwell’s criminal conduct (Ind. {| 4); Maxwell’s interactions with three minor victims (Ind. {[] 7(a)-(c)); specific overt acts performed by Maxwell (Ind. 4] 11(a)-(d)); and specific false statements that form the basis of the perjury charges (Ind. 4 21, 23). 9. As the Government explained in oral and written proffers, the DOJ-OGR-00001321