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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
 
 
x 
UNITED STATES OF AMERICA 
SUPERSEDING INDICTMENT 
S1 20 Cr. 330 (AJN) 
GHISLAINE MAXWELL, 
Defendant. 
x 
COUNT ONE 
(Conspiracy to Entice Minors to Travel to Engage in 
Illegal Sax 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 
groomed and abused by MAXWELL and 
that certain victims were in fact 
as 14 years old when they were 
Epstein, both of whom knew 
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 
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Epstein's residences in different states, which MAXWELL knew and 
intended would result in their grooming for and subjection to 
sexual abuse. Moreover, in an effort to conceal her crimes, 
MAXWELL repeatedly lied when questioned about her conduct, 
including in relation to some of the minor victims described 
herein, when providing testimony under oath in 2016. 
FACTUAL BACKGROUND 
3. 
During the time periods charged in this 
Indictment, GHISLAINE MAXWELL, the defendant, had a personal and 
professional relationship with Jeffrey Epstein and was among his 
closest associates. In particular, between in or about 1994 and 
in or about 1997, MAXWELL was in an intimate relationship with 
Epstein and also was paid by Epstein to manage his various 
properties. Over the course of their relationship, MAXWELL and 
Epstein were photographed together on multiple occasions, 
including in the below image: 
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4. 
Beginning in at least 1994, GHISLAINE MAXWELL, 
the defendant, enticed and groomed multiple minor girls to 
engage in sex acts with Jeffrey Epstein, through a variety of 
means and methods, including but not limited to the following: 
a. 
MAXWELL first attempted to befriend some of 
Epstein's minor victims prior to their abuse, including by 
asking the victims about their lives, their schools, and their 
families. MAXWELL and Epstein would spend time building 
friendships with minor victims by, for example, taking minor 
victims to the movies or shopping. Some of these outings would 
involve MAXWELL and Epstein spending time together with a minor 
victim, while some would involve MAXWELL or Epstein spending 
time alone with a minor victim. 
b. 
Having developed a rapport with a victim, 
MAXWELL would try to normalize sexual abuse for a minor victim 
by, among other things, discussing sexual topics, undressing in 
front of the victim, being present when a minor victim was 
undressed, and/or being present for sex acts involving the minor 
victim and Epstein. 
c. 
MAXWELL'S presence during minor victims' 
interactions with Epstein, including interactions where the 
minor victim was undressed or that involved sex acts with 
Epstein, helped put the victims at ease because an adult woman 
was present. For example, in some instances, MAXWELL would 
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massage Epstein in front of a minor victim. In other instances, 
MAXWELL encouraged minor victims to provide massages to Epstein, 
including sexualized massages during which a minor victim would 
be fully or partially nude. Many of those massages resulted in 
Epstein sexually abusing the minor victims. 
d. 
In addition, Epstein offered to help some 
minor victims by paying for travel and/or educational 
opportunities, and MAXWELL encouraged certain victims to accept 
Epstein's assistance. As a result, victims were made to feel 
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. 
GHISLAINE MAXWELL, the defendant, facilitated 
Jeffrey Epstein's access to minor victims knowing that he had a 
sexual preference for underage girls and that he intended to 
engage in sexual activity with those victims. Epstein's 
resulting abuse of minor victims included, among other things, 
touching a victim's breast, touching a victim's genitals, 
placing a sex toy such as a vibrator on a victim's genitals, 
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directing a victim to touch Epstein while he masturbated, and 
directing a victim to touch Epstein's genitals. 
MAXWELL AND EPSTEIN'S VICTIMS 
6. 
Between approximately in or about 1994 and in or 
about 1997, 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 a multi-story private residence on the 
Upper East Side of Manhattan, New York owned by Epstein (the 
"New York Residence"), which is depicted in the following 
photograph: 
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b. 
An estate in Palm Beach, Florida owned by 
Epstein (the "Palm Beach Residence"), which is depicted in the 
following photograph: 
c. 
A ranch in Santa Fe, New Mexico owned by 
Epstein (the "New Mexico Residence"), which is depicted in the 
following photograph: 
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England. 
d. 
MAXWELL's personal residence in London, 
7. 
Among the victims induced or enticed by GHISLAINE 
MAXWELL, the defendant, were minor victims identified herein as 
Minor Victim-1, Minor Victim-2, and Minor Victim-3. In 
particular, and during time periods relevant to this Indictment, 
MAXWELL engaged in the following acts, among others, with 
respect to minor victims: 
a. 
MAXWELL met Minor Victim-1 when Minor 
Victim-1 was approximately 14 years old. MAXWELL subsequently 
interacted with Minor Victim-1 on multiple occasions at 
Epstein's residences, knowing that Minor Victim-1 was under the 
age of 18 at the time. During these interactions, which took 
place between approximately 1994 and 1997, MAXWELL groomed Minor 
Victim-1 to engage in sexual acts with Epstein through multiple 
means. First, MAXWELL and Epstein attempted to befriend Minor 
Victim-1, taking her to the movies and on shopping trips. 
MAXWELL also asked Minor Victim-1 about school, her classes, her 
family, and other aspects of her life. MAXWELL then sought to 
normalize inappropriate and abusive conduct by, among other 
things, undressing in front of Minor Victim-1 and being present 
when Minor Victim-1 undressed in front of Epstein. Within the 
first year after MAXWELL and Epstein met Minor Victim-1, Epstein 
began sexually abusing Minor Victim-1. MAXWELL was present for 
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and involved in some of this abuse. In particular, MAXWELL 
involved Minor Victim-1 in group sexualized massages of Epstein. 
During those group sexualized massages, MAXWELL and/or Minor 
Victim-1 would engage in sex acts with Epstein. Epstein and 
MAXWELL both encouraged Minor Victim-1 to travel to Epstein's 
residences in both New York and Florida. As a result, Minor 
Victim-1 was sexually abused by Epstein in both New York and 
Florida. Minor Victim-1 was enticed to travel across state 
lines for the purpose of sexual encounters with Epstein, and 
MAXWELL was aware that Epstein engaged in sexual activity with 
Minor Victim-1 after Minor-Victim-1 traveled to Epstein's 
properties, including in the context of a sexualized massage. 
b. 
MAXWELL interacted with Minor Victim-2 on at 
least one occasion in or about 1996 at Epstein's residence in 
New Mexico when Minor Victim-2 was under the age of 18. 
Victim-2 had flown into New Mexico from out of state at 
Epstein's invitation for the purpose of being groomed for and/or 
subjected to acts of sexual abuse. MAXWELL knew that Minor 
Victim-2 was under the age of 18 at the time. While in New 
Mexico, MAXWELL and Epstein took Minor Victim-2 to a movie and 
MAXWELL took Minor Victim-2 shopping. MAXWELL also discussed 
Minor Victim-2's school, classes, and family with Minor Victim-
2. In New Mexico, MAXWELL began her efforts to groom Minor 
Victim-2 for abuse by Epstein by, among other things, providing 
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Minor 
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an unsolicited massage to Minor Victim-2, during which Minor 
Victim-2 was topless. MAXWELL also encouraged Minor Victim-2 to 
massage Epstein. 
c. 
MAXWELL groomed and befriended Minor 
Victim-3 in London, England between approximately 1994 and 1995, 
including during a period of time in which MAXWELL knew that 
Minor Victim-3 was under the age of 18. Among other things, 
MAXWELL discussed Minor Victim-3's life and family with Minor 
Victim-3. MAXWELL introduced Minor Victim-3 to Epstein and 
arranged for multiple interactions between Minor Victim-3 and 
Epstein. During those interactions, MAXWELL encouraged Minor 
Victim-3 to massage Epstein, knowing that Epstein would engage 
in sex acts with Minor Victim-3 during those massages. Minor 
Victim-3 provided Epstein with the requested massages, and 
during those massages, Epstein sexually abused Minor Victim-3. 
MAXWELL was aware that Epstein engaged in sexual activity with 
Minor Victim-3 on multiple occasions, including at times when 
Minor Victim-3 was under the age of 18, including in the context 
of a sexualized massage. 
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT 
8. 
In or around 2016, in the context of a deposition 
as part of civil litigation, GHISLAINE MAXWELL, the defendant, 
repeatedly provided false and perjurious statements, under oath, 
regarding, among other subjects, her role in facilitating the 
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abuse of minor victims by Jeffrey Epstein, including some of the 
specific events and acts of abuse detailed above. 
STATUTORY ALLEGATIONS 
9. 
From at least in or about 1994, up to and 
including in or about 1997, in the Southern District of New York 
and elsewhere, GHISLAIN£ 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 
wit, enticement, in violation of Title 18, United States Code, 
Section 2422. 
10. It was a part and object of the conspiracy that 
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others 
known and unknown, would and did knowingly persuade, induce, 
entice, and coerce one and more individuals to travel in 
interstate and foreign commerce, to engage in sexual activity 
for which a person can be charged with a criminal offense, in 
violation of Title 18, United States Code, Section 2422. 
Overt Acts 
11. In furtherance of the conspiracy and to effect 
the illegal object thereof, the following overt acts, among 
others, were committed in the Southern District of New York and 
elsewhere: 
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a. 
Between in or about 1994 and in or about 
1997, when Minor Victim-1 was under the age of 18, MAXWELL 
participated in multiple group sexual encounters with Epstein 
and Minor Victim-1 in New York and Florida. 
b. 
In or about 1996, when Minor Victim-1 was 
under the age of 18, Minor Victim-1 was enticed to travel from 
Florida to New York for purposes of sexually abusing her at the 
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. 
(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: 
12. The allegations contained in paragraphs 1 
through 8 of this Indictment are repeated and realleged as if 
fully set forth within. 
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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 
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wit, transportation of minors, in violation of Title 18, United 
States Code, Section 2423(a). 
16. It was a part and object of the conspiracy that 
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others 
known and unknown, would and did, knowingly transport an 
individual who had not attained the age of 18 in interstate and 
foreign commerce, with intent that the individual engage in 
sexual activity for which a person can be charged with a 
criminal offense, in violation of Title 18, United States Code, 
Section 2423(a). 
Overt Acts 
17. In furtherance of the conspiracy and to effect 
the illegal object thereof, the following overt acts, among 
others, were committed in the Southern District of New York and 
elsewhere: 
a. 
Between in or about 1994 and in or about 
1997, when Minor Victim-1 was under the age of 18, MAXWELL 
participated in multiple group sexual encounters with EPSTEIN 
and Minor Victim-1 in New York and Florida. 
b. 
In or about 1996, when Minor Victim-1 was 
under the age of 18, Minor Victim-1 was enticed to travel from 
Florida to New York for purposes of sexually abusing her at the 
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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. 
(Title 18, United States Code, Section 371.) 
COUNT FOUR 
(Transportation of a Minor with Intent to 
Engage in Criminal Sexual Activity) 
The Grand Jury further charges: 
18. The allegations contained in paragraphs 1 
through 8 of this Indictment are repeated and realleged as if 
fully set forth within. 
19. 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 
transport an individual who had not attained the age of 18 in 
interstate and foreign commerce, with the intent that the 
individual engage in sexual activity for which a person can be 
charged with a criminal offense, and attempted to do so, and 
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aided and abetted the same, to wit, MAXWELL arranged for Minor 
Victim-1 to be transported 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 2423(a) and 2.) 
COUNT FIVE 
(Perjury) 
The Grand Jury further charges: 
20. The allegations contained in paragraphs 1 
through 8 of this Indictment are repeated and realleged as if 
fully set forth within. 
21. On or about April 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. 7433, knowingly made false material 
declarations, to wit, MAXWELL gave the following underlined 
false testimony: 
Q. 
Did Jeffrey Epstein have a scheme to recruit 
underage girls for sexual massages? If you know. 
A. 
I don't know what you're talking about. 
• 
• 
• 
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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. 7433, knowingly made false material 
declarations, to wit, MAXWELL gave the following underlined 
false testimony: 
0: 
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. 
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• 
• 
• 
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.) 
17 
AUDREY 
RAUSS 
Acting sited States Attorney 
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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. 
SUPERSEDING INDICTMENT 
S1 20 Cr. 330 (AJN) 
(18 U.S.C. SS 371, 1623, 2422, 2423(a), 
and 2) 
AUDREY STRAUSS 
Acting United States Attorney 
Foreperson 
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EXHIBIT D 
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02/26/2016 14:Qe*A41Sam.24)1721.313dcAPIe CitaliarilieffiltrI8Q4RO,Faii9657329 
Puce 202 laib 0001/0026 
BOLES, SCHILLER & FLEXNER LLP
Sie,'w Vert( ■ WasbinntotitDC 
Florida • New 
i California 
New Jersc • 
401 East Las Olas Blvd., Suite 1200 
Fort Lauderdale, Florida 33301 
Telephone: (954) 356-0011 
Facsimile: (954) 356-0022 
FACSIMILE COVER SHEET 
TO: Laura Menninger, Esq. 
Haddon, Morgan and Foreman, P.C. 
Fax No. 
Telephone No. 
303.832.2628 
301831.7364 
FROM: 
Sigrid S. McCawley, Esq. 
DATE: 
February 26, 2016 
RE: 
v. Maxwell, 
Case no. 15-cv-07433-RWS 
Total Number of Pages: 
26 
(including this cover sheet) 
MESSAGE: 
Attached please find a copy of my email transmission to you from 
today at 12:10 pm, along with the accompanying Agreed Protective 
Order in both redline and clean version. Thank you. 
THE ATTORNEY-CLIENT AND/OR ATTORNEY WORK-PRODUCT PRIVILEGES 
This facsimile transmission is intended solely for the above-named recipient and may contain confidential information which is exempt from disclosure 
and protected by the attorney-client and/or attorney work-product privikges. Any unauthorised use or disclosure is strictly prohibited and may result in 
civil and/or criminal liability. limy of the information contained in this transmission is misdirected to you, pkase call (954) 356-0011 collect and mail 
such information back to us. Thank you. 
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