DOJ-OGR-00020739.pdf

Case 22-1426, Document 57, 02/28/2023, 3475900, Page121 of 208 A-117 Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 4 of 24 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. Between approximately in or about 1994 and in or about 2004, 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 multi-story private residence on the Upper East Side of Manhattan, New York owned by Epstein (the "New York Residence"). b. An estate in Palm Beach, Florida owned by Epstein (the "Palm Beach Residence"). c. A ranch in Santa Fe, New Mexico owned by Epstein (the "New Mexico Residence"). d. MAXWELL's personal residence in London, England. 4 DOJ-OGR-00020739