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be NO Ww ws Oo OY ~] oO Ke) a oO he be No (ee) = Hs Oo _ OY a ~] a oO a Ke} 20 21 22 23 24 25 Case 1:20-cr-00330-PAE Document 767 LCKCmax9 Charge by at least one of the conspirators in conspiracy. In other agreement went beyond that at least one the conspiracy. With respect indictment alleges as One, between Filed 08/10/22 furtherance of Page 222 of 257 3056 words, the government must show the mere talking stage. It mus conspirators in furtherance of that that the t show to the overt acts follows: the for Count One, the in or about 1994 and in or about 1997, when Jane was under the age of 17, Maxwell participated in multiple group sexual York and Florida. Two, in or about 1996, when Jane was under the age of encounters with Epstein and Jane in New 17, Jane was enticed to travel from Florida to New York for purposes of sexually abusing her at violation of New York Three, in or Penal Law, Section 130.55. the New York residence in about 1996, Maxwell provided Annie with an unsolicited massage in New Mexico during which Annie was topless. Four, between in or about 2001 and in or about 2002, when Carolyn was under the age of 17, Maxwell and invited Carolyn to travel Florida with Epstein. With respect indictment alleges as Between in or about follows: from Florida to a place outside of SOUTHERN DISTRICT REPORT ERS, (212) 805-0300 PG ew Epstein to the overt acts to Count Three, the 1994 and in or about 1997 when DOJ-OGR-00017243