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Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page1of24 ORIGINAL UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - eee eee ~----+-+--+-+ x UNITED STATES OF AMERICA SUPERSEDING INDICTMENT -~ Vv. - S2 20 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. ~-- eee ee eee LLY COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW 1s The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendank in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 2004, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein’s abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18. 2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to DOJ-OGR-00002843