DOJ-OGR-00001469.jpg

Case 1:20-cr-00330-AJN Document1 Filed 06/29/20 Page 3of18 4. Beginning in at least 1994, GHISLAINE MAXWELL, the defendant, enticed and groomed multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of means and methods, including but not limited to the following: a. MAXWELL first attempted to befriend some of -Epstein’s minor victims prior to their abuse, including by asking the victims about their lives, their schools, and their families. MAXWELL and Epstein would spend time building friendships with minor victims by, for example, taking minor victims to the movies or shopping. Some of these outings would involve MAXWELL and Epstein spending time together with a minor victim, while some would involve MAXWELL or Epstein spending time alone with a minor victim. com Having developed a rapport with a victim, MAXWELL would try to normalize sexual abuse for a minor victim by, among other things, discussing sexual topics, undressing in front of the victim, being present when a minor victim was undressed, and/or being present for sex acts involving the minor victim and Epstein. Ge MAXWELL’S presence during minor victims’ interactions with Epstein, including interactions where the minor victim was undressed or that involved sex acts with - Epstein, helped put the victims at — because an adult woman was present. For example, in some instances, MAXWELL would DOJ-OGR-00001469