EFTA00020404

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.
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EFTA00020404