EFTA00099530.pdf

A() l06A (08118) Application for a Warrant by Telephone or Other Reliable Electronic Means UNITED STATES DISTRICT COURT for the District of New Hampshire In the Matter of the Search of (Briefly describe the property to be searched or identify the person by name and address) Case No. The Premises Known and Described as 338 East Washington Road, Bradford, New Hampshire 03221 APPLICATION FOR A WARRANT BY TELEPHONE OR OTHER RELIABLE ELECTRONIC MEANS I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the property to be searched and give its location): Please see attached Affidavit and Attachment A. located in the District of New Hampshire , there is now concealed (identify the person or describe the property to be seized): Please see attached Affidavit and Attachment A. The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): O evidence of a crime; O contraband, fruits of crime, or other items illegally possessed; O property designed for use, intended for use, or used in committing a crime; ea person to be arrested or a person who is unlawfully restrained. The search is related to a violation of: Code Section Offense Description 18 U.S.C. 371 conspiracy to entice minors and transport minors 18 U.S.C. 2422, 2423(a) enticement of a minor, and transportation of a minor 18 U.S.C. 1623 perjury The application is based on these facts: Please see attached Affidavit. e Continued on the attached sheet. e Delayed notice of 30 days (give exact ending date ifmore than 30 days: ) is requested under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. Applicant's signature Special Agent, FBI Printed name and title Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephonic means (specify reliable electronic means). Date: 07/02/2020 Judge's signature City and state: Concord, NH Hon. Andrea K. Johnstone, U.S. Magistrate Judge Printed name and title Print r Save As... Attach Reset EFTA00099530 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK In the Matter of the Application of the United TO BE FILED UNDER SEAL States Of America for a Search and Seizure Warrant for the Premises Known and Described Agent Affidavit in Support of as 338 East Washington Road, Bradford, New Application for Search Warrant Hampshire 03221 SOUTHERN DISTRICT OF NEW YORK) ss.: being duly sworn, deposes and says: I. Introduction A. Affiant 1. I have been a Special Agent with the Federal Bureau of Investigation ("FBP") since 2017. During that time, I have participated in numerous investigations and prosecutions of crimes against children, including the sexual abuse of minors. I have also participated in the execution of multiple search warrants. 2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject Premises") for the purpose of locating GHISLAINE MAXWELL, who is a person to be arrested pursuant to an arrest warrant issued by a United States Magistrate Judge sitting in the Southern District of New York. This affidavit is based upon my personal knowledge; my review of documents and other evidence; and my conversations with other law enforcement personnel. Because this affidavit is being submitted for the limited purpose of establishing probable cause, it does not include all the facts that I have learned during the course of my investigation. Where the contents of documents and the actions, statements, and conversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated. 1 2017.08.02 EFTA00099531  B. The Subject Premises 3. The Subject Premises are particularly described as a 156-acre property located at 338 East Washington Road, Bradford, New Hampshire 03221 and containing three separate structures: a main residence, a guesthouse, and a garage. As detailed further herein, GHISLAINE MAXWELL, a Target Subject of this investigation, is believed to be currently present within the Subject Premises. An aerial photograph depicting all three of the structures of the Subject Premises is included below: Two photographs of the front of the main residence of the Subject Premises from two different angles are included below: 2 2017.08.02 EFTA00099532 A photograph of the guesthouse of the Subject Premises is included below: 3 2017.08.02 EFTA00099533  C. The Target Subject and the Subject Offenses 4. The Target Subject of this investigation is GHISLAINE MAXWELL. 5. On June 29, 2020, a grand jury in the Southern District of New York returned an indictment charging GHISLAINE MAXWELL with violations of 18 U.S.C. § 371 (conspiracy to entice minors to travel to engage in illegal sex acts); 18 U.S.C. § 2422 (enticement of a minor to travel to engage in illegal sex acts); 18 U.S.C. § 371 (conspiracy to transport minors with intent to engage in criminal sexual activity); 18 U.S.C. § 2423(a) (transportation of a minor with intent to engage in criminal sexual activity); and 18 U.S.C. § 1623 (perjury) (collectively, the "Subject Offenses"). The Indictment charging MAXWELL is attached as Exhibit A hereto (the "Indictment"). 6. Also on June 29, 2020, United States Magistrate Judge Lisa Margaret Smith signed a warrant for GHISLAINE MAXWELL's arrest, which is attached as Exhibit B hereto (the "Arrest 4 2017.08.02 EFTA00099534 Warrant"). Accordingly, I respectfully submit that there is probable cause to believe that MAXWELL is a "person to be arrested" within the meaning of Federal Rule of Criminal Procedure 4' (c)(4). 7. For the reasons detailed below, I respectfully submit that there is probable cause to believe that GHISLAINE MAXWELL will be found within the Subject Premises. II. Probable Cause A. Probable Cause Regarding the Target Subject's Commission of the Subject Offenses 8. As set forth in paragraph 5 above, a grand jury sitting in the Southern District of New York has returned an indictment charging the Target Subject with the Subject Offenses. B. Probable Cause Justifying Search of the Subject Premises 9. As detailed herein, and notwithstanding the efforts of GHISLAINE MAXWELL described below to evade detection since the arrest in July 2019 of her co-conspirator, Jeffrey Epstein, I and other agents have been able to identify a cellphone used by MAXWELL that, as specified below, is presently located in or around the Subject Premises. In particular, as detailed herein, a cell-site simulator placed the cellphone used by MAXWELL at the Subject Premises at approximately 7:36 AM on July 2, 2020, and cell site data similarly confirms that the cellphone used by MAXWELL has been in the vicinity of the Subject Premises on a regular basis for at least the last 30 days. 10. Based on my participation in the investigation, I know that since the arrest of GHISLAINE MAXWELL's co-conspirator, Jeffrey Epstein, in July 2019, MAXWELL has intentionally sought to evade detection. For example, since that time, MAXWELL has avoided public appearances, has moved at least twice, has stopped using a cellphone associated with her at the time of Epstein's arrest and started using a new cellphone registered simply in the name "G 5 2017.08.02 EFTA00099535 Max," (described herein as the "Target Cellphone"), has ordered packages from her Amazon account to be delivered to her under the name of another person, and has intentionally stayed out of public view. I further know that, since approximately July 2019, MAXWELL has been aware that she is the subject of an ongoing criminal investigation into her relationship with Epstein and her role in facilitating his abuse of minor girls. 11. Based on my review of Customs and Border Patrol records, I know that GHISLAINE MAXWELL is a United States citizen and that she most recently entered the United States in or about June of 2019. There is no record of MAXWELL leaving the United States since her arrival in June of 2019. 12. Based on my review of records, and as noted above, I have learned that the cellphone with phone number (the "Target Cellphone") is subscribed in the name of "M," which appears to be a shortened version of GHISLAINE MAXWELL's name. The Target Cellphone is presently active. 13. On or about June 30, 2020, United States Magistrate Judge Katharine H. Parker, signed a warrant for cellphone location information for the Target Cellphone (the "Cell Site Warrant"), which is attached as Exhibit C, after finding probable cause to believe that GHISLAINE MAXWELL is presently using the Target Cellphone. Pursuant to the Cell Site Warrant, the FBI has received GPS location data for the Target Cellphone since approximately 10:15 PM on June 30, 2020 and has also received historical cell site data for the Target Cellphone for the period June I, 2020 to June 30, 2020. As detailed further below, data obtained pursuant to the Cell Site Warrant confirms that MAXWELL is presently in the general location of the Subject Premises and has remained in that area consistently for at least the past 30 days. 6 2017.08.02 EFTA00099536  14. On July I, 2020, United States Magistrate Judge Andrea K. Johnstone signed a warrant for the use of a cell-site simulator for the Target Cellphone (the "Cell-Site Simulator Warrant"), which is attached as Exhibit D, after also finding probable cause to believe that MAXWELL is presently using the Target Cellphone. A copy of the application in support of that Cell-Site Simulator Warrant, which sets forth in greater detail the probable cause to believe MAXWELL is using the Target Cellphone, is attached as Exhibit E. 15. Pursuant to the Cell-Site Simulator Warrant, the Target Cellphone was found to be at the Subject Premises on July 2, 2020 at approximately 7:36 AM. 16. I know from my review of records and my conversations with other law enforcement agents that the GPS location and cell site data collected pursuant to the Cell Site Warrant revealed the following: a. GPS location data, also known as precision location information, provides relatively precise location information about a cellphone, which a provider can typically collect either via GPS tracking technology built into the phone or by triangulating the device's signal as received by the provider's nearby cell towers. Cell site data, by contrast, reflects only the cell tower and sector thereof utilized in routing any communication to and from the cellphone, as well as the approximate range of the cellphone from the tower during the communication (sometimes referred to as "per-call measurement" ("PCM") or "round-trip time" ("RTT") data). Because cell towers are often a half-mile or more apart, even in urban areas, and can be ten or more miles apart in rural areas, cell site data is helpful but typically less precise than precision location information. b. Through the Cell Site Warrant, law enforcement was able to obtain cell site data for the Target Cellphone. While less precise than a cell-site simulator, consistent with the current location obtained pursuant to the Cell-Site Simulator Warrant as detailed in paragraph 15, 7 2017.08.02 EFTA00099537 above, I am aware that the cell site data for the Target Cellphone reveals that it has been located in and around Bradford, New Hampshire for at least the past 30 days. More specifically, I am aware that during that same period, the Target Cellphone has regularly connected with a cell tower that covers an area that includes the Subject Premises (the "Subject Premises Cell Tower".) c. Cell site data further indicates that The Target Cellphone has been within the vicinity of the Subject Premises Cell Tower as recently as within the last approximately 24 hours. 17. In addition to the cell-site simulator data, which has confirmed that the Target Cellphone was at the Subject Premises on the morning of July 2, 2020, and the Cell Site Data confirming that the Target Cellphone has been in the vicinity of the Subject Premises for at least the past 30 days, I know based on my review of property records and my conversations with other law enforcement agents the following: a. Although there are multiple residences, including the Subject Premises, within the vicinity of the Subject Premises Cell Tower, with the exception of the Subject Premises, all of the other residences in that area are owned in the names of individuals or in the names of identified family trusts. By contrast, the Subject Premises is the only property within the vicinity of the Subject Premises Cell Tower that is owned by an entity. In particular, the Subject Premises is owned by an entity called Granite Realty LLC, a name seemingly designed to obscure the true identity of its owner. b. On or about December 13, 2019, Granite Realty LLC purchased the Subject Premises for $1,070,000 in an all cash sale. 18. Based on the above, I respectfully submit that there is probable cause to believe that GHISLAINE MAXWELL is currently located within the Subject Premises. In particular, 8 2017.08.02 EFTA00099538 the fact that the cell-site simulator confirmed the Target Cellphone was located in the Subject Premises at approximately 7:36 AM this morning and that cell site data confirmed that the Target Cellphone has been located in the vicinity of the Subject Premises on a regular basis for the past 30 days, makes it likely that MAXWELL is currently in the Subject Premises with her phone. Moreover, although there are multiple residences located within the range of the Subject Premises Cell Tower, the Subject Premises is the only residence located within that area that is owned in the name of an anonymous entity, which is consistent with MAXWELL's extensive efforts, described above, to remain anonymous after the arrest of her co-conspirator, Jeffrey Epstein. III. Conclusion and Ancillary Provisions 19. Based on the foregoing, I respectfully submit that there is probable cause to believe that GHISLAINE MAXWELL is a person to be arrested for the Subject Offenses and that she is currently located at the Subject Premises. I therefore respectfully request the court to issue a warrant to search for the individual specified in Attachment A to this affidavit and to the Search and Seizure Warrant. Respectfully submitted, Is Special Agent Federal Bureau of Investigation The affiant appeared before me by telephonic conference on this date pursuant to Fed. R. Crim. P. 4.1 and affirmed under oath the content of this affidavit and application. Honorable Andrea K. Johnstone United States Magistrate Judge District of New Hampshire Dated: 9 2017.08.02 EFTA00099539  ATTACHMENT A I. Premises to be Searched—Subject Premises The Subject Premises are particularly described as a 156-acre property located at 338 East Washington Road, Bradford, New Hampshire 03221 and containing three separate structures: a main residence, a guesthouse, and a garage. As detailed further herein, GHISLAINE MAXWELL, a Target Subject of this investigation, is believed to be currently present inside the Subject Premises. An aerial photograph depicting all three of the structures of the Subject Premises is included below: 2017.08.02 EFTA00099540 Two photographs of the front of the main residence of the Subject Premises from two different angles are included below: 2017.08.02 EFTA00099541 A photograph of the guesthouse of the Subject Premises is included below: H. Person to Be Seized This warrant authorizes executing agents to search the Subject Premises for GHISLAINE MAXWELL, who is a person to be arrested for violations of 18 U.S.C. § 371 (conspiracy to entice minors to travel to engage in illegal sex acts); 18 U.S.C. § 2422 (enticement of a minor to travel to engage in illegal sex acts); 18 U.S.C. § 371 (conspiracy to transport minors with intent to engage in criminal sexual activity); 18 U.S.C. § 2423(a) (transportation of a minor with intent to engage in criminal sexual activity); and 18 U.S.C. § 1623 (perjury). 3 2017.08.02 EFTA00099542 EXHIBIT A EFTA00099543 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x SEALED UNITED STATES OF AMERICA INDICTMENT 20 Cr. GHISLAINE MAXWELL, Defendant. 20 Cr. 330 X COUNT ONE (Conspiracy to Entice Minors to Travel to Engage in Illegal Sex Acts) The Grand Jury charges: OVERVIEW 1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to and including at least in or about 1997, MAXWELL assisted, facilitated, and contributed to Jeffrey Epstein's abuse of minor girls by, among other things, helping Epstein to recruit, groom, and ultimately abuse victims known to MAXWELL and Epstein to be under the age of 18. The victims were as young as 14 years old when they were groomed and abused by MAXWELL and Epstein, both of whom knew that certain victims were in fact under the age of 18. 2. As a part and in furtherance of their scheme to abuse minor victims, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein enticed and caused minor victims to travel to EFTA00099544 Epstein's residences in different states, which MAXWELL knew and intended would result in their grooming for and subjection to sexual abuse. Moreover, in an effort to conceal her crimes, MAXWELL repeatedly lied when questioned about her conduct, including in relation to some of the minor victims described herein, when providing testimony under oath in 2016. FACTUAL BACKGROUND 3. During the time periods charged in this Indictment, GHISLAINE MAXWELL, the defendant, had a personal and professional relationship with Jeffrey Epstein and was among his closest associates. In particular, between in or about 1994 and in or about 1997, MAXWELL was in an intimate relationship with Epstein and also was paid by Epstein to manage his various properties. Over the course of their relationship, MAXWELL and Epstein were photographed together on multiple occasions, including in the below image: 2 EFTA00099545  4. Beginning in at least 1994, GHISLAINE MAXWELL, the defendant, enticed and groomed multiple minor girls to engage in sex acts with Jeffrey Epstein, through a variety of means and methods, including but not limited to the following: a. MAXWELL first attempted to befriend some of Epstein's minor victims prior to their abuse, including by asking the victims about their lives, their schools, and their families. MAXWELL and Epstein would spend time building friendships with minor victims by, for example, taking minor victims to the movies or shopping. Some of these outings would involve MAXWELL and Epstein spending time together with a minor victim, while some would involve MAXWELL or Epstein spending time alone with a minor victim. b. Having developed a rapport with a victim, MAXWELL would try to normalize sexual abuse for a minor victim by, among other things, discussing sexual topics, undressing in front of the victim, being present when a minor victim was undressed, and/or being present for sex acts involving the minor victim and Epstein. c. MAXWELL'S presence during minor victims' interactions with Epstein, including interactions where the minor victim was undressed or that involved sex acts with Epstein, helped put the victims at ease because an adult woman was present. For example, in some instances, MAXWELL would 3 EFTA00099546 massage Epstein in front of a minor victim. In other instances, MAXWELL encouraged minor victims to provide massages to Epstein, including sexualized massages during which a minor victim would be fully or partially nude. Many of those massages resulted in Epstein sexually abusing the minor victims. d. In addition, Epstein offered to help some minor victims by paying for travel and/or educational opportunities, and MAXWELL encouraged certain victims to accept Epstein's assistance. As a result, victims were made to feel indebted and believed that MAXWELL and Epstein were trying to help them. e. Through this process, MAXWELL and Epstein enticed victims to engage in sexual activity with Epstein. In some instances, MAXWELL was present for and participated in the sexual abuse of minor victims. Some such incidents occurred in the context of massages, which developed into sexual encounters. 5. GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims knowing that he had a sexual preference for underage girls and that he intended to engage in sexual activity with those victims. Epstein's resulting abuse of minor victims included, among other things, touching a victim's breast, touching a victim's genitals, placing a sex toy such as a vibrator on a victim's genitals, 4 EFTA00099547 directing a victim to touch Epstein while he masturbated, and directing a victim to touch Epstein's genitals. MAXWELL AND EPSTEIN'S VICTIMS 6. Between approximately in or about 1994 and in or about 1997, GHISLAINE MAXWELL, the defendant, facilitated Jeffrey Epstein's access to minor victims by, among other things, inducing and enticing, and aiding and abetting the inducement and enticement of, multiple minor victims. Victims were groomed and/or abused at multiple locations, including the following: a. A a multi-story private residence on the Upper East Side of Manhattan, New York owned by Epstein (the "New York Residence"), which is depicted in the following photograph: EFTA00099548  b. An estate in Palm Beach, Florida owned by Epstein (the "Palm Beach Residence"), which is depicted in the following photograph: c. A ranch in Santa Fe, New Mexico owned by Epstein (the "New Mexico Residence"), which is depicted in the following photograph: EFTA00099549  d. MAXWELL's personal residence in London, England. 7. Among the victims induced or enticed by GHISLAINE MAXWELL, the defendant, were minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3. In particular, and during time periods relevant to this Indictment, MAXWELL engaged in the following acts, among others, with respect to minor victims: a. MAXWELL met Minor Victim-1 when Minor Victim-1 was approximately 14 years old. MAXWELL subsequently interacted with Minor Victim-1 on multiple occasions at Epstein's residences, knowing that Minor Victim-1 was under the age of 18 at the time. During these interactions, which took place between approximately 1994 and 1997, MAXWELL groomed Minor Victim-1 to engage in sexual acts with Epstein through multiple means. First, MAXWELL and Epstein attempted to befriend Minor Victim-1, taking her to the movies and on shopping trips. MAXWELL also asked Minor Victim-1 about school, her classes, her family, and other aspects of her life. MAXWELL then sought to normalize inappropriate and abusive conduct by, among other things, undressing in front of Minor Victim-1 and being present when Minor Victim-1 undressed ih front of Epstein. Within the first year after MAXWELL and Epstein met Minor Victim-1, Epstein began sexually abusing Minor Victim-1. MAXWELL was present for 7 EFTA00099550 and involved in some of this abuse. In particular, MAXWELL involved Minor Victim-1 in group sexualized massages of Epstein. During those group sexualized massages, MAXWELL and/or Minor Victim-1 would engage in sex acts with Epstein. Epstein and MAXWELL both encouraged Minor Victim-1 to travel to Epstein's residences in both New York and Florida. As a result, Minor Victim-1 was sexually abused by Epstein in both New York and Florida. Minor Victim-1 was enticed to travel across state lines for the purpose of sexual encounters with Epstein, and MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-1 after Minor-Victim-1 traveled to Epstein's properties, including in the context of a sexualized massage. b. MAXWELL interacted with Minor Victim-2 on at least one occasion in or about 1996 at Epstein's residence in New Mexico when Minor Victim-2 was under the age of 18. Minor Victim-2 had flown into New Mexico from out of state at Epstein's invitation for the purpose of being groomed for and/or subjected to acts of sexual abuse. MAXWELL knew that Minor Victim-2 was under the age of 18 at the time. While in New Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed Minor Victim-2's school, classes, and family with Minor Victim- 2. In New Mexico, MAXWELL began her efforts to groom Minor Victim-2 for abuse by Epstein by, among other things, providing 8 EFTA00099551 an unsolicited massage to Minor Victim-2, during which Minor Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to massage Epstein. c. MAXWELL groomed and befriended Minor Victim-3 in London, England between approximately 1994 and 1995, including during a period of time in which MAXWELL knew that Minor Victim-3 was under the age of 18. Among other things, MAXWELL discussed Minor Victim-3's life and family with Minor Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and arranged for multiple interactions between Minor Victim-3 and Epstein. During those interactions, MAXWELL encouraged Minor Victim-3 to massage Epstein, knowing that Epstein would engage in sex acts with Minor Victim-3 during those massages. Minor Victim-3 provided Epstein with the requested massages, and during those massages, Epstein sexually abused Minor Victim-3. MAXWELL was aware that Epstein engaged in sexual activity with Minor Victim-3 on multiple occasions, including at times when Minor Victim-3 was under the age of 18, including in the context of a sexualized massage. MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT 8. In or around 2016, in the context of a deposition as part of civil litigation, GHISLAINE MAXWELL, the defendant, repeatedly provided false and perjurious statements, under oath, regarding, among other subjects, her role in facilitating the 9 EFTA00099552 abuse of minor victims by Jeffrey Epstein, including some of the specific events and acts of abuse detailed above. STATUTORY ALLEGATIONS 9. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, enticement, in violation of Title 18, United States Code, Section 2422. 10. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did knowingly persuade, induce, entice, and coerce one and more individuals to travel in interstate and foreign commerce, to engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2422. Overt Acts 11. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: 10 EFTA00099553  a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with Epstein and Minor Victim-1 in New York and Florida. b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 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. c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. (Title 18, United States Code, Section 371.) COUNT TWO (Enticement of a Minor to Travel to Engage in Illegal Sex Acts) The Grand Jury further charges: 12. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. 11 EFTA00099554  13. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did persuade, induce, entice, and coerce 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, and attempted to do the same, and aided and abetted the same, to wit, MAXWELL persuaded, induced, enticed, and coerced Minor Victim-1 to travel from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. (Title 18, United States Code, Sections 2422 and 2.) COUNT THREE (Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity) The Grand Jury further charges: 14. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. 15. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to 12 EFTA00099555 wit, transportation of minors, in violation of Title 18, United States Code, Section 2423(a). 16. It was a part and object of the conspiracy that GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, would and did, knowingly transport an individual who had not attained the age of 18 in interstate and foreign commerce, with intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2423(a). Overt Acts 17. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. Between in or about 1994 and in or about 1997, when Minor Victim-1 was under the age of 18, MAXWELL participated in multiple group sexual encounters with EPSTEIN and Minor Victim-1 in New York and Florida. b. In or about 1996, when Minor Victim-1 was under the age of 18, Minor Victim-1 was enticed to travel from Florida to New York for purposes of sexually abusing her at the 13 EFTA00099556 New York Residence, in violation of New York Penal Law, Section 130.55. c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, MAXWELL encouraged Minor Victim-3 to provide massages to Epstein in London, England, knowing that Epstein intended to sexually abuse Minor Victim-3 during those massages. (Title 18, United States Code, Section 371.) COUNT FOUR (Transportation of a Minor with Intent to Engage in Criminal Sexual Activity) The Grand Jury further charges: 18. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. 19. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did transport an individual who had not attained the age of 18 in interstate and foreign commerce, with the intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do so, and 14 EFTA00099557 aided and abetted the same, to wit, MAXWELL arranged for Minor Victim-1 to be transported from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. (Title 18, United States Code, Sections 2423(a) and 2.) COUNT FIVE (Perjury) The Grand Jury further charges: 20. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. 21. On or about April 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: Q. Did Jeffrey Epstein have a scheme to recruit underage girls for sexual massages? If you know. A. I don't know what you're talking about. 15 EFTA00099558  Q. List all the people under the age of 18 that you interacted with at any of Jeffrey's properties? A. I'm not aware of anybody that I interacted with, other than obviously [the plaintiff) who was 17 at this point. (Title 18, United States Code, Section 1623.) COUNT SIX (Perjury) The Grand Jury further charges: 22. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. 23. On or about July 22, 2016, in the Southern District of New York, GHISLAINE MAXWELL, the defendant, having taken an oath to testify truthfully in a deposition in connection with a case then pending before the United States District Court for the Southern District of New York under docket number 15 Civ. 7344, knowingly made false material declarations, to wit, MAXWELL gave the following underlined false testimony: Q: Were you aware of the presence of sex toys or devices used in sexual activities in Mr. Epstein's Palm Beach house? A: No, not that I recall. . . . Q. Do you know whether Mr. Epstein possessed sex toys or devices used in sexual activities? A. No. 16 EFTA00099559 Q. Other than yourself and the blond and brunette that you have identified as having been involved in three-way sexual activities, with whom did Mr. Epstein have sexual activities? A. I wasn't aware that he was having sexual activities with anyone when I was with him other than myself. Q• I want to be sure that I'm clear. Is it your testimony that in the 1990s and 2000s, you were not aware that Mr. Epstein was having sexual activities with anyone other than yourself and the blond and brunette on those few occasions when they were involved with you? A. That is my testimony, that is correct. Q. Is it your testimony that you've never given anybody a massage? A. I have not given anyone a massage. Q• You never gave Mr. Epstein a massage, is that your testimony? A. That is my testimony. Q. You never gave [Minor Victim-2] a massage is your testimony? A. I never gave (Minor Victim-2] a massage. (Title 18, United States Code, Section 1623.) AUDREY S RAUSS Acting nited States Attorney 17 EFTA00099560  Form No. USA-33s-274 (Ed. 9-25-58) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v. GHISLAINE MAXWELL, Defendant. INDICTMENT (18 U.S.C. §§ 371, 1623, 2422, 2423(a), and 2) AUDREY STRAUSS Acting United States Attorney 18 EFTA00099561 EXHIBIT B EFTA00099562 Mod AO 442 (09113) Arrest Warrant AUSA Name & Telno: , 212-637-2225 UNITED STATES DISTRICT COURT for the Southern District of New York United States of America v. )) 20 CR 330 INL N " ) ) ) ) Ghislaine Maxwell ) Defendant ARREST WARRANT To: Any authorized law enforcement officer YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay (name ofperson to be arrested) Ghislaine Maxwell who is accused of an offense or violation based on the following document filed with the court: W Indictment O Superseding Indictment O Information O Superseding Information O Complaint O Probation Violation Petition O Supervised Release Violation Petition O Violation Notice O Order of the Court This offense is briefly described as follows: Title 18, United States Code, Section 371 (conspiracy to entice minors) Title 18, United States Code, Sections 2422 and 2 (enticement of a minor) Title 18, United States Code, Section 371 (conspiracy to transport minors) Title 18, United States Code, Sections 2423(a) and 2 (transportation of minor) Title 18, United States Code, Section 1623 (perjury) • Date: 06/29/2020 Issuing officer's signature City and state: White Plains, NY Hon. Lisa Margaret Smith, U.S. Magistrate Judge Printed name and title Return This warrant was received on (date) , and the person was arrested on (date) at (city and state) Date: Arresting officer's signature Printed name and title EFTA00099563 EXHIBIT C EFTA00099564  Original UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK In re: Second Warrant and Order For Prospective and Historical Location SECOND Information and Pen Register WARRANT AND ORDER Information for the Cell hone Assigned Call Number USAO Reference No. 2018R01618 Mag. Second Warrant and Order for Cellphone Location Information and Pen Register Information and for Sealing and Non-Disclosure TO: ("Service Provide?), and any subsequent provider of service to the Target Cellphone specified below ("Subsequent Service Provide?) Federal Bureau of Investigation ("Investigative Agency") Upon the Application and Agent Affidavit submitted by the Government in this matter: I. Findings The Court hereby finds: I. The Target Cellphone (the "Target Cellphone") that is the subject of this Order is assigned call number is subscribed to in the name of "M" (the "Subscribe?), and is currently serviced by the Service Provider. 2. Pursuant to 18 U.S.C. § 2703(c)(1)(A) and the applicable provisions of Rule 41 of the Federal Rules of Criminal Procedure, the Government's application sets forth probable cause to believe that the prospective and historical location information for the Target Cellphone will reveal the location of a person to be arrested for suspected violations of 18 U.S.C. §§ 371, 2422, 2423(a), and 1623 ("the Subject Offenses"). 3. Pursuant to 18 U.S.C. § 2703(d), the Government's application also sets forth specific and articulable facts showing that there are reasonable grounds to believe that the toll records for the Target Cellphone are relevant and material to an ongoing criminal investigation. 2019.07.24 EFTA00099565  4. Pursuant to 18 U.S.C. § 3123(b)(1), the Government has certified that the pen register information for the Target Cellphone is relevant to an ongoing investigation by the Investigating Agency of GHISLAINE MAXWELL and others unknown in connection with suspected violations of the Subject Offenses. 5. Pursuant to 18 U.S.C. § 2705(b), there is reason to believe that notification of the existence of this Warrant and Order will result in flight from prosecution, and/or intimidation of potential witnesses, or other