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10 11 12 13 14 15 16 17 18 19 20 21 22 23 Case 1:20-cr-00330-PAE Document563_ Filed 12/18/21 Page 53 of 167 With respect to the overt acts for Count Three, the Indictment reads-alleges as follows: (1) Between in or about 1994 and in or about 1997, when Jane was under the age of 178, Maxwell 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 178, 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 Annieswas-under the-age-of18,Maxwell provided Annie with an unsolicited massage in New Mexico, during which Annie was topless; 44) Betweenin-er about 1994 and in-or about 1995 when Kate-was- Pages ie cece besel sees eees Cate oo seers clo aes te Ste ae eee Gee eee ese ie ete ead eel gue boa Se ae ee (ok) Between in or about 2001 and in or about 2002, when Carolyn was under the age of 178, 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-alleges 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; ineludinge-attimes 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 52 DOJ-OGR-00008591