DOJ-OGR-00008507.jpg

10 11 12 13 14 15 16 17 18 19 20 21 ae 23 Case 1:20-cr-00330-PAE Document562- Filed 12/17/21 Page 51 of 82 participated in multiple group sexual encounters with Epstein and Jane in New York and Florida; (2) In or about 1996, when Jane was under the age of 18, Jane 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; (3) In or about 1996, when Annie was under the age of 18, Maxwell provided Annie with an unsolicited massage in New Mexico, during which Annie was topless; (4) Between in or about 1994 and in or about 1995, when Kate was under the age of 18, Maxwell encouraged Kate to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Kate during those massages; (5) Between in or about 2001 and in or about 2002, when Carolyn was under the age of 18, Maxwell and Epstein invited Carolyn to travel from Florida to a place outside of Florida with Epstein. With respect to the overt acts for Count Five, the Indictment reads as follows: (1) Between in or about 2001 and in or about 2004, Epstein and Maxwell recruited Carolyn to engage in sex acts with Epstein at the Palm Beach Residence, after which Epstein and, at times, Maxwell provided Carolyn with hundreds of dollars in cash for each encounter. Carolyn truthfully told both Epstein and Maxwell her age; (2) Between in or about 2001 and in or about 2004, Epstein and Maxwell both encouraged and enticed Carolyn to recruit other girls to engage in paid sex acts with Epstein, which she did; (3) Between in or about 2001 and in or about 2004, Epstein's employees, including at times Maxwell, sent Carolyn gifts, including lingerie, from an address in the Southern District of New York to Carolyn’s residence in Florida. For example, on one occasion in or about October of 2002, Epstein caused a package to be sent by Federal Express from an address in Manhattan to Carolyn in Florida; (4) On multiple occasions between in or about 2001 and in or about 2004, Epstein, Maxwell, or one of Epstein's other employees called Carolyn to schedule an appointment for Carolyn to massage Epstein. For example, in or 50 DOJ-OGR-00008507