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Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 3 of 4
14. Please describe with particularity what Ms. Maxwell allegedly did as part of the
“unsolicited massage” of Minor Victim-2 and identify the criminal statute(s) the
conduct allegedly violates (§ 7b, 11c, 17c).
15. Please identify the dates when, and locations where, Ms. Maxwell allegedly met
and/or interacted with Minor Victim-3 (§] 7c).
16. Please identify the dates when, and locations where, Ms. Maxwell allegedly
introduced Minor Victim-3 to Epstein and the dates and locations of their subsequent
“multiple interactions” (§] 7c).
17. Please identify the dates when, and locations where, Ms. Maxwell allegedly
“groomed” Minor Victim-3 to engage in sex acts with Epstein (4 7c).
18. Please identify the dates when, and locations where, Jeffrey Epstein allegedly
sexually abused Minor Victim-3 (§ 7c).
19. Please describe with particularity the “sex acts” that Minor Victim-3 allegedly
engaged in with Epstein during massages and identify the criminal statute(s) the
conduct allegedly violates and the other participants in those massages (4 7c).
20. Please identify the dates when Minor Victim-3 allegedly traveled in interstate or
foreign commerce to engage in illegal sexual activity with Epstein (§] 7c).
21. Please specify when the conspiracies charged in Count One and Count Three began
and ended. (f/f 9, 15).
22. Please identify the “others” who allegedly participated in the conspiracies charged in
Count One and Count Three with Epstein and Ms. Maxwell. ({f[ 9-10, 15-16).
23. Please identify any individuals who were enticed to travel, or were transported, in
interstate or foreign commerce to engage in illegal sexual activity with Epstein during
the time period of the charged conspiracies (1994-1997), apart from Minor Victims-1-
3 ({ 10, 16).
24. Please identify the dates when, and the locations where, Ms. Maxwell participated in
“group sexualized encounters” with Jeffrey Epstein and Minor Victim-1 (§{] 11a,
17a).
25. Please describe with particularity the conduct that the government believes constitutes
a “group sexualized encounter” and identify the criminal statute(s) the conduct
violates and the participants in those encounters (J 11a, 17a).
26. Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New
York in 1996 (Fj 11b, 17b).
DOJ-OGR-00002719
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Dates
Document Details
| Filename | DOJ-OGR-00002719.jpg |
| File Size | 736.5 KB |
| OCR Confidence | 92.9% |
| Has Readable Text | Yes |
| Text Length | 2,385 characters |
| Indexed | 2026-02-03 16:26:28.691152 |