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Case 21-58, Document 58-1, 04/12/2021, 3075763, Page3 of 25 her bail application (Ex. E, I), which motions Judge Nathan denied in written orders dated December 28, 2020 and March 22, 2021 (Ex. H, L). Maxwell filed notices of appeal from these two orders (though not the original detention order). 5. Maxwell’s trial is scheduled to begin on July 12, 2021. STATEMENT OF FACTS A. The Offense Conduct and Evidence 6. The Indictment charges Maxwell with facilitating the sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997? (Ind. § 1). During that period, Maxwell played a key role in Epstein’s sexual abuse of minor girls by helping to identify, entice, and groom minor victims to engage in sex acts with Epstein. (Ind. 4] 1). Maxwell befriended victims by asking them about their lives, taking them to the movies or on shopping trips, and encouraging them to interact with Epstein. (Ind. {] 4(a)). Maxwell groomed victims for sexual abuse for by, among other things, discussing sexual topics, undressing in After Judge Nathan’s bail decisions were issued, Superseding Indictment S2 20 Cr. 330 (AJN) (the “Superseding Indictment”) was filed, charging Maxwell in eight counts. In addition to the original six charges, the Superseding Indictment also charges Maxwell with sex trafficking conspiracy, in violation of 18 U.S.C. § 371, and sex trafficking of a minor, in violation of 18 U.S.C. § 1591. Among other things, the Superseding Indictment expanded the scope of the conspiracies charged in Counts One and Three from 1994 through 2004 and specifically identified a fourth victim of those conspiracies. The additional charges strengthen the evidence against Maxwell and further support Judge Nathan’s detention orders. 3 DOJ-OGR- 00020237