DOJ-OGR-00019186.pdf

Case 1:20-mj-00132-AJ Document 1 Filed 07/02/20 Page 13 of 19 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 DOJ-OGR-00019186