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Case 21-58, Document 92, 05/27/2021, 3109708, Page4 of 24 sexual abuse of multiple minor victims by Jeffrey Epstein between approximately 1994 and 1997.2 (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, who were as young as 14 years old, to engage in sex acts with Epstein. (d.). 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. (Jd.). 9. 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. {| 11(a)-(d)); and specific false statements that form the basis of the perjury charges (Ind. {fj 21, 23). 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 identified a fourth victim of those conspiracies. 4 DOJ-OGR- 00020362