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Case 1:20-cr-00330-PAE Document 293 Filed 05/25/21 Page 13 of 32 at § 25a). Recruiting Others “Epstein ... encouraged [Accuser-4] to recruit other young females to provide sexualized massages[.]” (S2 Indictment 4 9d; see also id. at § 25b). Recruiting Others “Mr. Epstein asked [Accuser-4] if she had any friends that would be interested in performing these massages ... that she could bring to him[.]” (Ex. C at 26:12-16). Gifts to Accuser-4 “On multiple occasions between approximately 2001 and 2004, Epstein’s employees ... sent [Accuser-4] gifts, including lingerie, from an address in Manhattan, New York to [Accuser- 4’s] residence in Florida.” (S2 Indictment ¥ 9d; see also id. at § 25c). Gifts to Accuser-4 “Mr. Epstein provided [gifts] to [Accuser-4].... Epstein would provide her with lingerie.... He would also send her [gifts] via FedEx packages to her residence.” (Ex. C at 28:20-29:10) (describing subpoenaed FedEx records). Scheduling Massage Appointments “Epstein’s employees ... called [Accuser-4], including from New York, to schedule appointments for [Accuser-4] to massage Epstein.” (S2 Indictment 9d; see also id. at ¥ 25d). “For example, in or about April of 2004 and May of 2004 another employee of Epstein’s called [Accuser-4] to schedule such appointments.” (S2 Indictment § 25d). Scheduling Massage Appointments “TS ]Jometimes would be ... in New York and scheduled [Accuser-4] to come and work, but primary role was to schedule ... [Accuser-4] to come and perform the massages.” (Ex. C at 25:2-6). “(O]n or about April 23", 2004, placed a telephone call to a telephone used by [Accuser-4].” (Ex. C at 17:18-19:4; see also id. at 56:24-25 (subpoenaed cell phone records “indicate telephonic contact with ) The one critical difference between the allegations in the S2 Indictment and the allegations presented to the SDFL grand jury is this: Accuser-4 never implicated Ms. Maxwell in the Florida Investigation. Ms. Maxwell is not mentioned even once in the grand jury testimony concerning Accuser-4. Instead, the grand jury testimony reflects that Accuser-4 implicated Epstein hin se DOJ-OGR- 00004278