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Case 22-1426, Document “Tatza | 3475900, Page128 of 208 | A124 | Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 11 of 24 offered to assist Minor Victim-4 with obtaining a passport for purposes of such travel, but Minor Victim-4 declined the invitation. On multiple occasions between approximately 2001 and 2004, Epstein’s employees, Minor Victim-4 gifts, including lingerie, including at times MAXWELL, from an address in sent Manhattan, New York to Minor Victim-4'’s residence in Florida. Epstein and MAXWELL each also encouraged Minor Victim-4 to recruit other young females to provide sexualized massages to Epstein. In response, Minor Victim-4 brought multiple females, including girls under the age of 18, massages for Epstein at the Palm Beach Residence. occasions, both Minor Victim-4 and the girl she brought were paid hundreds of dollars in cash. to provide sexualized On such MAXWELL’S EFFORTS TO CONCEAL HER CONDUCT 10. In or around 2016, as part of civil litigation, repeatedly provided false and perjurious statements, regarding, among other subjects, abuse of minor victims by Jeffrey Epstein, specific events and acts of abuse detailed above. 11. including in or about 2004, and elsewhere, in the context of a deposition GHISLAINE MAXWELL, STATUTORY ALLEGATIONS From at least in or about 1994, GHISLAINE MAXW ELL, 1 the defendant, up to and Jeffrey the defendant, under oath, her role in facilitating the including some of the in the Southern District of New York DOJ-OGR- 00020746