DOJ-OGR-00002857.jpg

Case 1:20-cr-00330-PAE Document187 Filed 03/29/21 Page15 of 24 18. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did, knowingly transport an individual who had not attained the age of 18 years in interstate and foreign commerce, with intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2423(a). Overt Acts 19. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with EPSTEIN and Minor Victim-1l in New York and Florida. b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1l was enticed to travel from Florida to New York for purposes of sexually abusing her at the New York Residence, in violation of New York Penal Law, Section 130.55. em In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an 15 DOJ-OGR-00002857