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Case 22-1426, Document “Tactzo | 3475900, Page133 of 208 | A-129 | Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 16 of 24 unsolicited massage in New Mexico, during which Minor Victim-2 was topless. ai Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. e. Between in or about 2001 and in or about 2002, when Minor Victim-4 was under the age of 18, MAXWELL and Epstein invited Minor Victim-4 to travel from Florida to a place outside of Florida with Epstein. (Title 18, United States Code, Section 371.) COUNT FOUR (Transportation of a Minor with Intent to Engage in Criminal Sexual Activity) The Grand Jury further charges: 20. The allegations contained in paragraphs 1 through 9 of this Indictment are repeated and realleged as if fully set forth within. 21. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did transport an individual who had not attained the age of 18 years in interstate and foreign commerce, with the intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do so, and 16 DOJ-OGR-00020751