EFTA00152328.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x SEALED UNITED STATES OF AMERICA INDICTMENT 20 Cr. GHISLAINE MAXWELL, Defendant. 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 EFTA00152328  es, which MAXWELL knew and Epstein's residences in different stat for and subjection to intended would result in their grooming crimes, sexual abuse. Moreover, in an effort to conceal her ed about her conduct, MAXWELL repeatedly lied when question mino r victims described including in relation to some of the r oath in 2016. herein, when providing testimony unde FACTUAL BACKGROUND 3. During the time periods charged in this ndant, had a personal and Indictment, GHISLAINE MAXWELL, the defe Epst ein and was among his professional relationship with Jeffrey and closest associates. In particular, between in or about 1994 intimate relationship with in or about 1997, MAXWELL was in an to manage his various Epstein and also was paid by Epstein , MAXWELL and properties. Over the course of their relationship multiple occasions, Epstein were photographed together on including in the below image: 2 EFTA00152329  GHISLAINE MAXWELL, 4. Beginning in at least 1994, ls to groomed multiple minor gir the defendant, enticed and variety of Jeffrey Epstein, through a engage in sex acts with following: ing but not limited to the means and methods, includ befriend some of a. MAXWELL first attempted to ing by or to their abuse, includ Epstein's minor victims pri their ir lives, their schools, and asking the victims about the lding tein would spend time bui families. MAXWELL and Eps minor tims by, for example, taking friendships with minor vic pping. Some of these outings would victims to the movies or sho h a minor n spending time together wit involve MAXWELL and Epstei nding olve MAXWELL or Epstein spe victim, while some would inv victim. time alone with a minor with a victim, b. Having developed a rapport or victim ize sexual abuse for a min MAXWELL would try to normal ressing in cussing sexual topics, und by, among other things, dis was present when a minor victim front of the victim, being the minor sent for sex acts involving undressed, and/or being pre victim and Epstein. minor victims' c. MAXWELL'S presence during re the including interactions whe interactions with Epstein, s with or that involved sex act minor victim was undressed adult woman tims at ease because an Epstein, helped put the vic ces, MAXWELL would was present. For example, in some instan 3 EFTA00152330  im. In other instances, massage Epstein in front of a minor vict provide massages to Epstein, MAXWELL encouraged minor victims to h a minor victim would including sexualized massages during whic be fully or partially nude. Many of those massages resulted in ims. Epstein sexually abusing the minor vict d. In addition, Epstein offered to help some or educational minor victims by paying for travel and/ ain victims to accept opportunities, and MAXWELL encouraged cert Epstein's assistance. As a result, victims were made to feel Epstein were trying to indebted and believed that MAXWELL and help them. ein e. Through this process, MAXWELL and Epst vity with Epstein. In enticed victims to engage in sexual acti for and participated in the some instances, MAXWELL was present sexual abuse of minor victims. Some such incidents occurred in d into sexual encounters. the context of massages, which develope ted 5. GHISLAINE MAXWELL, the defendant, facilita ims knowing that he had a Jeffrey Epstein's access to minor vict and that he intended to sexual preference for underage girls victims. Epstein's engage in sexual activity with those uded, among other things, resulting abuse of minor victims incl a victim's genitals, touching a victim's breast, touching on a victim's genitals, placing a sex toy such as a vibrator 4 EFTA00152331  bated, and ch Epstein while he mastur directing a victim to tou Epstein's genitals. directing a victim to touch TIMS MAXWELL AND EPSTEIN'S VIC or about 1994 and in or 6. Between approximately in L, the defendant, facilitated about 1997, GHISLAINE MAXWEL er to minor victims by, among oth Jeffrey Epstein's access tting the icing, and aiding and abe things, inducing and ent s. Victims of, multiple minor victim inducement and enticement luding the at multiple locations, inc were groomed and/or abused following: residence on the a. A a multi-story private n (the , New York owned by Epstei Upper East Side of Manhattan lowing ch is depicted in the fol "New York Residence"), whi photograph: EFTA00152332  rida owned by b. An estate in Palm Beach, Flo ed in the Residence"), which is depict Epstein (the "Palm Beach following photograph: ico owned by c. A ranch in Santa Fe, New Mex in the idence"), which is depicted Epstein (the "New Mexico Res following photograph: 6 EFTA00152333  in London, d. MAXWELL's personal residence England. d or enticed by GHISLAINE 7. Among the victims induce e minor victims identi fied herein as MAXWELL, the defendant, wer -2, and Minor Victim-3. In Minor Victim-1, Minor Victim Indictment, e periods relevant to this particular, and during tim with lowing acts, among others, MAXWELL engaged in the fol respect to minor victims: when Minor a. MAXWELL met Minor Victim-1 14 years old. MAXWELL subsequently Victim-1 was approximately -1 on multiple occasions at interacted with Minor Victim under the g that Minor Victim-1 was Epstein's residences, knowin which took age of 18 at the time. During these interactions, omed Minor y 1994 and 1997, MAXWELL gro place between approximatel multiple acts with Epstein through Victim-1 to engage in sexual attempted to befriend Minor means. First, MAXWELL and Epstein ps. movies and on shopping tri Victim-1, taking her to the sse s, her tim-1 about school, her cla MAXWELL also asked Minor Vic of her life. MAXWELL then sought to family, and other aspects other abusive conduct by, among normalize inappropriate and ng present nt of Minor Victim-1 and bei things, undressing in fro Within the sed in front of Epstein. when Minor Victim-1 undres -1, Epstein and Epstein met Minor Victim first year after MAXWELL or Victim-1. MAXWELL was present for began sexually abusing Min EFTA00152334  s abuse. In particular, MAXWELL and involved in some of thi group sexualized mas sages of Epstein. involved Minor Victim-1 in d massag es, MAXWELL and/or Minor During those group sexualize acts with Epstei n. Epstein and Victim-1 would engage in sex n's or Victim-1 to travel to Epstei MAXWELL both encouraged Min k and Florida. As a result, Minor residences in both New Yor and by Epstein in both New York Victim-1 was sexually abused to travel across state Florida. Minor Victim-1 was enticed n, and ual encounters with Epstei lines for the purpose of sex ty with tei n engaged in sexual activi MAXWELL was aware that Eps n's Victim-1 traveled to Epstei Minor Victim-1 after Minor- sage. context of a sexualized mas properties, including in the Victim-2 on at b. MAXWELL interacted with Minor nce in ut 1996 at Epstein's reside least one occasion in or abo Minor -2 was under the age of 18. New Mexico when Minor Victim Mex ico from out of state at Victim-2 had flown into New and/or purpose of being groomed for Epstein's invitation for the abuse. MAXWELL knew that Minor subjected to acts of sexual of 18 at the time. While in New Victim-2 was under the age and too k Minor Victim-2 to a movie Mexico, MAXWELL and Epstein shopping. MAXWELL also discussed MAXWELL took Minor Victim-2 Victim - sses, and family with Minor Minor Victim-2's school, cla an her efforts to groom Minor 2. In New Mexico, MAXWELL beg ing n by, among other things, provid Victim-2 for abuse by Epstei 8 EFTA00152335  ch Minor Minor Victim-2, during whi an unsolicited massage to or Victim-2 to Victim-2 was topless. MAXWELL also encouraged Min massage Epstein. nded Minor c. MAXWELL groomed and befrie 4 and 1995, d between approximately 199 Victim-3 in London, Englan w that of time in which MAXWELL kne including during a period age of 18. Among other things, Minor Victim-3 was under the or tim-3' s life and family with Min MAXWELL discussed Minor Vic tim-3 to Epstein and Victim-3. MAXWELL introduced Minor Vic -3 and ctions between Minor Victim arranged for multiple intera MAXWELL encouraged Minor Epstein. During those interactions, engage n, knowing that Epstein would Victim-3 to massage Epstei Minor tim-3 during those massages. in sex acts with Minor Vic and with the requested massages, Victim-3 provided Epstein Victim-3. tein sexually abused Minor during those massages, Eps ivity with tein engaged in sexual act MAXWELL was aware that Eps times when occasions, including at Minor Victim-3 on multiple the context the age of 18, including in Minor Victim-3 was under of a sexualized massage. L HER CONDUCT MAXWELL'S EFFORTS TO CONCEA context of a deposition 8. In or around 2016, in the defendant, n, GHISLAINE MAXWELL, the as part of civil litigatio under oath, and perjurious statements, repeatedly provided false ing the jec ts, her role in facilitat regarding, among other sub 9 EFTA00152336  ein, including some of the abuse of minor victims by Jeffrey Epst iled above. specific events and acts of abuse deta STATUTORY ALLEGATIONS 9. From at least in or about 1994, up to and hern District of New York including in or about 1997, in the Sout defendant, Jeffrey and elsewhere, GHISLAINE MAXWELL, the willfully and knowingly Epstein, and others known and unknown, and agree together and with did combine, conspire, confederate, nst the United States, to each other to commit an offense agai 18, United States Code, wit, enticement, in violation of Title Section 2422. piracy that 10. It was a part and object of the cons rey Epstein, and others GHISLAINE MAXWELL, the defendant, Jeff ingly persuade, induce, known and unknown, would and did know viduals to travel in entice, and coerce one and more indi engage in sexual activity interstate and foreign commerce, to a criminal offense, in for which a person can be charged with Code, Section 2422. violation of Title 18, United States Overt Acts to effect 11. In furtherance of the conspiracy and owing overt acts, among the illegal object thereof, the foll hern District of New York and others, were committed in the Sout elsewhere: 10 EFTA00152337  in or about a. Between in or about 1994 and L under the age of 18, MAXWEL 1997, when Minor Victim-1 was Epstein up sexual encounters with participated in multiple gro York and Florida. and Minor Victim-1 in New Victim-1 was b. In or about 1996, when Minor vel fro m Victim-1 was enticed to tra under the age of 18, Minor at the poses of sexually abusing her Florida to New York for pur , Section lation of New York Penal Law New York Residence, in vio 130.55. or Victim-2 was c. In or about 1996, when Min h an L provided Minor Victim-2 wit under the age of 18, MAXWEL tim-2 Mexico, during which Minor Vic unsolicited massage in New was topless. in or about d. Between in or about 1994 and L under the age of 18, MAXWEL 1995, when Minor Victim-3 was tein in to provide massages to Eps encouraged Minor Victim-3 ly abuse t Epstein intended to sexual London, England, knowing tha massages. Minor Victim-3 during those e, Section 371.) (Title 18, United States Cod COUNT TWO s) to Tra vel to Engage in Illegal Sex Act (Enticement of a Minor rges: The Grand Jury further cha in paragraphs 1 12. The allegations contained as if t are repeated and realleged through 8 of this Indictmen fully set forth within. 11 EFTA00152338  13. From at least in or about 1994, up to and hern District of New York including in or about 1997, in the Sout ndant, knowingly did and elsewhere, GHISLAINE MAXWELL, the defe an individual to travel in persuade, induce, entice, and coerce ge in sexual activity for interstate and foreign commerce to enga inal offense, and which a person can be charged with a crim abetted the same, to attempted to do the same, and aided and and coerced Minor wit, MAXWELL persuaded, induced, enticed, York, New York on Victim-1 to travel from Florida to New Minor Victim-1 would multiple occasions with the intention that rey Epstein, in engage in one or more sex acts with Jeff 130.55. violation of New York Penal Law, Section and 2.) (Title 18, United States Code, Sections 2422 COUNT THREE nt to (Conspiracy to Transport Minors with Inte Engage in Criminal Sexual Acti vity ) The Grand Jury further charges: 1 14. The allegations contained in paragraphs and realleged as if through 8 of this Indictment are repeated fully set forth within. 15. From at least in or about 1994, up to and District of New York including in or about 1997, in the Southern ndant, Jeffrey and elsewhere, GHISLAINE MAXWELL, the defe willfully and knowingly Epstein, and others known and unknown, agree together and with did combine, conspire, confederate, and the United States, to each other to commit an offense against 12 EFTA00152339  United ors , in violation of Title 18, wit, transportation of min ). States Code, Section 2423(a the conspiracy that 16. It was a part and object of endant, Jeffrey Epstein, and others GHISLAINE MAXWELL, the def and did, knowingly tra nsport an known and unknown, would erstate and ained the age of 18 in int individual who had not att engage in ent that the individual foreign commerce, with int h a a person can be charged wit sexual activity for which tes Code, ion of Title 18, United Sta criminal offense, in violat Section 2423(a). Overt Acts racy and to effect 17. In furtherance of the conspi among the following overt acts, the illegal object thereof, k and the Sou thern District of New Yor others, were committed in elsewhere: and in or about a. Between in or about 1994 WELL was under the age of 18, MAX 1997, when Minor Victim-1 h EPSTEIN up sexual encounters wit participated in multiple gro York and Florida. and Minor Victim-1 in New or Victim-1 was b. In or about 1996, when Min vel from Vic tim-1 was enticed to tra under the age of 18, Minor g her at the purposes of sexually abusin Florida to New York for 13 EFTA00152340  Law, Section lation of New York Penal New York Residence, in vio 130.55. or Victim-2 was c. In or about 1996, when Min with an L provided Minor Victim-2 under the age of 18, MAXWEL Mexico, during which Minor Victim-2 unsolicited massage in New was topless. in or about d. Between in or about 1994 and WELL was under the age of 18, MAX 1995, when Minor Victim-3 n in to provide massages to Epstei encouraged Minor Victim-3 abuse t Eps tein intended to sexually London, England, knowing tha massages. Minor Victim-3 during those e, Section 371.) (Title 18, United States Cod COUNT FOUR with Intent to (Transportation of a Minor Activity) Engage in Criminal Sexual s: The Grand Jury further charge in paragraphs 1 18. The allegations contained ged as if t are repeated and realle through 8 of this Indictmen fully set forth within. 1994, up to and 19. From at least in or about of New York in the Southern District including in or about 1997, wingly did WELL, the defendant, kno and elsewhere, GHISLAINE MAX 18 in had not attained the age of transport an individual who t the merce, with the intent tha interstate and foreign com can be activity for which a person individual engage in sexual do so, and offense, and attempted to charged with a criminal 14 EFTA00152341  Minor to wit, MAXWELL arranged for aided and abetted the same, New York on from Florida to New York, Victim-1 to be transported -1 would intention that Minor Victim multiple occasions with the in acts with Jeffrey Epstein, engage in one or more sex Law, Section 130.55. violation of New York Penal e, Sections 2423(a) and 2.) (Title 18, United States Cod COUNT FIVE (Perjury) s: The Grand Jury further charge in paragraphs 1 20. The allegations contained as if t are repeated and realleged through 8 of this Indictmen fully set forth within. in the Southern 21. On or about April 22, 2016, , having INE MAXWELL, the defendant District of New York, GHISLA thfully in a deposition in taken an oath to testify tru States n pending before the United connection with a case the under thern District of New York District Court for the Sou al knowingly made false materi docket number 15 Civ. 7344, L gav e the following underlined declarations, to wit, MAXWEL false testimony: scheme to recruit Q. Did Jeffrey Epstein have a massages? If you know. underage girls for sexual king about. A. I don't know what you're tal 15 EFTA00152342  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 EFTA00152343 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 EFTA00152344  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 person 18 EFTA00152345