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ORIGINAL 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
GHISLAINE MAXWELL, 
Defendant. 
SUPERSEDING INDICTMENT 
S2 20 Cr. 330 (AJN) 
COUNT ONE 
(Conspiracy to Entice Minors to Travel to Engage in 
Illegal Sex 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 2004, 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 as 14 years old when they were 
groomed and abused by MAXWELL and Epstein, both of whom knew 
that certain victims were in fact 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. Additionally, between in or about 1994 and in or about 
2004, MAXWELL was paid by Epstein to manage his various 
properties. 
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 
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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 
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 
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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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6. 
Additionally, beginning at least in or about 
2001, GHISLAINE MAXWELL, the defendant, and Jeffrey Epstein 
enticed and recruited, and caused to be enticed and recruited, 
minor girls to visit Epstein's Palm Beach Residence to engage in 
sex acts with Epstein, after which Epstein, MAXWELL, or another 
employee of Epstein's would give the victims hundreds of dollars 
in cash. Epstein and MAXWELL encouraged one or more of those 
victims to travel with Epstein with the intention that the 
victim engage in sex acts with Epstein. Moreover, and in order 
to maintain and increase his supply of victims, Epstein, 
MAXWELL, and other Epstein employees also paid certain victims 
to recruit additional girls to be similarly abused by Epstein. 
In this way, Epstein and MAXWELL created a network of underage 
victims for him to sexually exploit. 
7. 
Between at least in or about 2001 and in or about 
2004, GHISLAINE MAXWELL, the defendant, and Epstein encouraged 
and enticed one or more minor victims to engage in paid sex acts 
with Epstein through a variety of means and methods, including 
but not limited to the following: 
a. 
Epstein's employees, including, at times, 
MAXWELL, would call a victim to schedule an appointment for the 
victim to massage Epstein at his Palm Beach Residence. MAXWELL 
placed at least some of those calls while with Epstein in 
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Manhattan, New York. Epstein would often travel from New York 
to Florida, where he would then have the scheduled appointments. 
b. 
When a victim initially arrived at the Palm 
Beach Residence, she would be greeted by an employee of 
Epstein's, including, at times, MAXWELL. The victim would then 
be escorted to a room with a massage table. Once inside, the 
victim would provide a nude or semi-nude massage for EPSTEIN, 
who would himself typically be naked. During these encounters, 
EPSTEIN would escalate the nature and scope of the physical 
contact to include sex acts such as groping and direct and 
indirect contact with the victim's genitals. EPSTEIN would also 
typically masturbate during these encounters, ask the victim to 
touch him while he masturbated, and touch the victim's genitals 
with his hands or with sex toys. 
c. 
In connection with each sexual encounter, 
Epstein or one of his employees or associates, including, at 
times, MAXWELL, paid the victim in cash. Each victim was 
typically paid hundreds of dollars for each encounter. 
8. 
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, 
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placing a sex toy such as a vibrator on a victim's genitals, 
directing a victim to touch Epstein while he masturbated, and 
directing a victim to touch Epstein's genitals. 
MAXWELL AND EPSTEIN'S VICTIMS 
9. 
Among the victims induced or enticed by GHISLAINE 
MAXWELL, the defendant, were minor victims identified herein as 
Minor Victim-1, Minor Victim-2, Minor Victim-3, and Minor 
Victim-4. 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 
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first year after MAXWELL and Epstein met Minor Victim-1, Epstein 
began sexually abusing Minor Victim-1. MAXWELL was present for 
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. Minor 
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-
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2. In New Mexico, MAXWELL began her efforts to groom Minor 
Victim-2 for abuse by Epstein by, among other things, providing 
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. 
d. 
Minor Victim-4 was recruited to provide 
Epstein with sexualized massages for which Minor Victim-4 was 
paid by Epstein and/or one of his associates, including, at 
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times, MAXWELL, at the Palm Beach Residence beginning in or 
around 2001. MAXWELL met Minor Victim-4 at Epstein's Palm Beach 
Residence when Minor Victim-4 was approximately 14 years old. 
MAXWELL subsequently interacted with Minor Victim-4 on multiple 
occasions at Epstein's Palm Beach Residence, knowing that Minor 
Victim-4 was under the age of 18 at the time. During these 
interactions, which took place between approximately 2001 and 
2004, MAXWELL groomed Minor Victim-4 to engage in sexual acts 
with Epstein through multiple means. For example, MAXWELL asked 
Minor Victim-4 about her family and other aspects of her life. 
MAXWELL also sought to normalize inappropriate and abusive 
conduct by, among other things, discussing sexual topics in 
front of Minor Victim-4 and being present when Minor Victim-4 
was nude in the massage room of the Palm Beach Residence. On 
multiple occasions between approximately 2001 and 2004, Minor 
Victim-4 provided nude massages to Epstein at the Palm Beach 
Residence, during which Epstein engaged in multiple sex acts 
with Minor Victim-4. Epstein's employees, including at times 
MAXWELL, called Minor Victim-4, including from New York, to 
schedule appointments for Minor Victim-4 to massage Epstein. 
After each massage, Epstein or one of his employees, including 
at times MAXWELL, paid Minor Victim-4 hundreds of dollars in 
cash. At some point during this period, both Epstein and 
MAXWELL invited Minor Victim-4 to travel with Epstein and 
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offered to assist Minor Victim-4 with obtaining a passport for 
purposes of such travel, but Minor Victim-4 declined the 
invitation. On multiple occasions between approximately 2001 
and 2004, Epstein's employees, including at times MAXWELL, sent 
Minor Victim-4 gifts, including lingerie, from an address in 
Manhattan, New York to Minor Victim-4's residence in Florida. 
Epstein and MAXWELL each also encouraged Minor Victim-4 to 
recruit other young females to provide sexualized massages to 
Epstein. In response, Minor Victim-4 brought multiple females, 
including girls under the age of 18, to provide sexualized 
massages for Epstein at the Palm Beach Residence. On such 
occasions, both Minor Victim-4 and the girl she brought were 
paid hundreds of dollars in cash. 
MAXWELL'S EFFORTS TO CONCEAL HER CONDUCT 
10. 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 
abuse of minor victims by Jeffrey Epstein, including some of the 
specific events and acts of ,ib.:se d,=t=ilnl above. 
STATUTORY ALLEGATIONS 
11. From at _east. in or about 1994, up to and 
including in or about 2004, in the Southern District of New York 
and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey 
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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. 
12. 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 
13. 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. 
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 
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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: 
16. The allegations contained in paragraphs 1 through 
9 of this Indictment are repeated and realleged as if fully set 
forth within. 
17. From at least in or about 1994, up to and 
including in or about 2004, 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 
wit, transportation of minors, in violation of Title 18, United 
States Code, Section 2423(a). 
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18. 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 years 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 
19. 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-i 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 
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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 FOUR 
(Transportation of a Minor with Intent to 
Engage in Criminal Sexual Activity) 
The Grand Jury further charges: 
20. The allegations contained in paragraphs 1 through 
9 of this Indictment are repeated and realleged as if fully set 
forth within. 
21. 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 years 
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 
(Sex Trafficking Conspiracy) 
The Grand Jury further charges: 
22. The allegations contained in paragraphs 1 through 
9 of this Indictment are repeated and realleged as if fully set 
forth within. 
23. From at least in or about 2001, up to and 
including in or about 2004, 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 
wit, sex trafficking of minors, in violation of Title 18, United 
States Code, Section 1591(a) and (b). 
24. It was a part and object of the conspiracy that 
GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others 
known and unknown, would and did, in and affecting interstate 
and foreign commerce, recruit, entice, harbor, transport, 
provide, and obtain, by any means a person, and to benefit, 
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financially and by receiving anything of value, from 
participation in a venture which has engaged in any such act, 
knowing that the person had not attained the age of 18 years and 
would be caused to engage in a commercial sex act, in violation 
of Title 18, United States Code, Sections 1591(a) and (b) (2). 
Overt Acts 
25. 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 2001 and in or about 
2004, Epstein and MAXWELL recruited Minor Victim-4 to engage in 
sex acts with EPSTEIN at the Palm Beach Residence, after which 
Epstein and, at times, MAXWELL provided Minor Victim-4 with 
hundreds of dollars in cash for each encounter. Minor Victim-4 
truthfully told both Epstein and MAXWELL her age. 
b. 
Between in or about 2001 and in or about 
2004, Epstein and MAXWELL both encouraged and enticed Minor 
Victim-4 to recruit other girls to engage in paid sex acts with 
Epstein, which she did. 
c. 
Between in or about 2001 and in or about 
2004, Epstein's employees, including at times MAXWELL, sent 
Minor Victim-4 gifts, including lingerie, from an address in the 
Southern District of New York to Minor Victim-4's residence in 
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Florida. For example, on one occasion in or about October of 
2002, Epstein caused a package to be sent by Federal Express 
from an address in Manhattan to Minor Victim-4 in Florida. 
d. 
On multiple occasions between in or about 
2001 and in or about 2004, Epstein, MAXWELL, or one of Epstein's 
other employees called Minor Victim-4 to schedule an appointment 
for Minor Victim-4 to massage Epstein. For example, in or about 
April of 2004 and May of 2004 another employee of Epstein's 
called Minor Victim-4 to schedule such appointments. 
(Title 18, United States Code, Section 371.) 
COUNT SIX 
(Sex Trafficking of a Minor) 
The Grand Jury further charges: 
26. The allegations contained in paragraphs 1 through 
9 of this Indictment are repeated and realleged as if fully set 
forth within. 
27. From at least in or about 2001, up to and 
including in or about 2004, in the Southern District of New York 
and elsewhere, GHISLAINE MAXWELL, the defendant, willfully and 
knowingly, in and affecting interstate and foreign commerce, did 
recruit, entice, harbor, transport, provide, and obtain by any 
means a person, knowing that the person had not attained the age 
of 18 years and would be caused to engage in a commercial sex 
act, and did aid and abet the same, to wit, MAXWELL recruited, 
enticed, harbored, transported, provided, and obtained 
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individuals who were less than 16 years old, including but not 
limited to Minor Victim-4, as described above, and who were then 
caused to engage in at least one commercial sex act with Jeffrey 
Epstein, and aided and abetted the same. 
(Title 18, United States Code, Section 1591(a), 
(b)(2), and 2.) 
COUNT SEVEN 
(Perjury) 
The Grand Jury further charges: 
28. The allegations contained in paragraphs 1 through 
9 of this Indictment are repeated and realleged as if fully set 
forth within. 
29. 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. 
Q. 
List all the people under the age of 18 that you 
interacted with at any of Jeffrey's properties? 
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