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Case 1:20-cr-00330-PAE Document 410-1 Filed 11/04/21 CHARGE Summary of Indictment The Indictment contains six counts, or “charges,” against the defendant. Each count constitutes a separate offense or crime. You must consider each count of the Indictment separately, and you must return a separate verdict on each count. I am briefly going to summarize each count, and then will give you the law in greater detail. Count One of the Indictment charges Ghislaine Maxwell, the defendant, with conspiring—that is, agreeing—with others to entice an individual to travel in interstate and foreign commerce to engage in sexual activity for which a person can be charged with a criminal offense: Count One relates to multiple victims and the time period 1994 to 2004. Count Two of the Indictment charges +he-defeadantMs. Maxwell with enticing ex jindisiduellJane Doe-1 pseudonym] to travel in interstate end-foreice-commerce to engage in sexual activity with Jeffrey Epstein for which a person can be charged with a criminal offense. Count Two relates to [Jane Doe-1 _pseudonym Miner Vietimt and the time period 1994 to 1997. —| Count Three of the Indictment charges ++e-defendentMs. Maxwell with conspiring with others to transport a minor in interstate and foreign commerce, with intent that the minor engage in sexual activity for which a person can be charged with a criminal offense. Count Three relates to multiple minor victims and the time period 1994 to 2004. Count Four of the Indictment charges the defendants. Maxwell with transporting <- jsinox[ Jane Doe-1_pscudonym] in interstate end-fereice-commerce, with the intent that she sainor|Jane Doe-1_pseudonym| engage in sexual activity with Jeffrey Epstein for which a person 1 The defense has informed the Government that they continue to object to the use of pseudonyms. The parties have agreed to use neutral identifiers here to avoid the need for redactions. 15 Page 15 of 93 al Commented [CE12]: These references will need to be changed once we agree upon an appropriate pseudonym. Commented [CE13]: For a discussion of the reasons for DOJ-OGR-00006081