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Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page5of 24 6. Additionally, beginning at least in or about 2001, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and recruited, and caused to be enticed and recruited, minor girls to visit Epstein’s Palm Beach Residence to engage in sex acts with Epstein, after which Epstein, MAXWELL, or another employee of Epstein’s would give the victims hundreds of dollars in cash. Epstein and MAXWELL encouraged one or more of those victims to travel with Epstein with the intention that the victim engage in sex acts with Epstein. Moreover, and in order to maintain and increase his supply of victims, Epstein, MAXWELL, and other Epstein employees also paid certain victims to recruit additional girls to be similarly abused by Epstein. In this way, Epstein and MAXWELL created a network of underage victims for him to sexually exploit. 7. Between at least in or about 2001 and in or about 2004, GHISLAINE MAXWELL, the defendant, and Epstein encouraged and enticed one or more minor victims to engage in paid sex acts with Epstein through a variety of means and methods, including but not limited to the following: a. Epstein’s employees, including, at times, MAXWELL, would call a victim to schedule an appointment for the victim to massage Epstein at his Palm Beach Residence. MAXWELL placed at least some of those calls while with Epstein in DOJ-OGR-00002847

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Filename DOJ-OGR-00002847.jpg
File Size 523.2 KB
OCR Confidence 95.0%
Has Readable Text Yes
Text Length 1,423 characters
Indexed 2026-02-03 16:27:47.447945