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Case 18-2868, Document 275, 08/09/2019, 2628223, Page5d of 18 Ms. Maxwell personally was involved in a “sexual abuse and sex trafficking scheme” created by Epstein: Ms. Maxwell “approached” plaintiff in 1999 when plaintiff was “fifteen years old” to recruit her into the scheme. Ms. Maxwell was “one of the main women” Epstein used to “procure under- aged girls for sexual activities.” Ms. Maxwell was a “primary co-conspirator” with Epstein in his scheme. She “persuaded” plaintiff to go to Epstein’s mansion “in a fashion very similar to the manner in which Epstein and his other co-conspirators coerced dozens of other children.” At the mansion, when plaintiff began giving Epstein a massage, he and Ms. Maxwell “turned it into a sexual encounter.” Epstein “with the assistance of’ Ms. Maxwell “converted [plaintiff] into ...a “sex slave.’” Jd. Plaintiff was a “sex slave” from “about 1999 through 2002.” Ms. Maxwell also was a “co-conspirator in Epstein’s sexual abuse.” Ms. Maxwell “appreciated the immunity” she acquired under Epstein’s plea agreement, because the immunity protected her from prosecution “for the crimes she committed in Florida.” Ms. Maxwell “participat[ed] in the sexual abuse of [plaintiff] and others.” Ms. Maxwell “took numerous sexually explicit pictures of underage girls involved in sexual activities, including [plaintiff].” Jd. She shared the photos with Epstein. As part of her “role in Epstein’s sexual abuse ring,” Ms. Maxwell “connect[ed]” Epstein with “powerful individuals” so that Epstein could traffick plaintiff to these persons. Plaintiff was “forced to have sexual relations” with Prince Andrew in “TMs. Maxwell’s] apartment” in London. Ms. Maxwell “facilitated” plaintiffs sex with Prince Andrew “by acting as a ‘madame’ for Epstein.” Ms. Maxwell “assist[ed] in internationally trafficking” plaintiff and “numerous other young girls for sexual purposes.” Plaintiff was “forced” to watch Epstein, Ms. Maxwell and others “engage in illegal sexual acts with dozens of underage girls.” 4