DOJ-OGR-00020748.pdf

Case 22-1426, Document 57, 02/28/2023, 3475900, Page130 of 208 A-126 Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 13 of 24 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. e. Between in or about 2001 and in or about 2002, when Minor Victim-4 was under the age of 18, MAXWELL and Epstein invited Minor Victim-4 to travel from Florida to a place outside of Florida with Epstein. (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: 14. The allegations contained in paragraphs 1 through 9 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, knowingly did 13 DOJ-OGR-00020748