Prosecution Memorandum

This memorandum seeks authorization to charge GHISLAINE MAXWELL with one count of conspiracy to violate 18 U.S.C. § 2423(a), which prohibits the transportation of a minor for illegal sexual activity, and one count of conspiracy to violate 18 U.S.C. § 2422, which prohibits the enticement of a minor to travel to engage in illegal sexual activity. These charges arise from Maxwell's role in facilitating Jeffrey Epstein's sexual abuse of minors. In particular, the proposed charges focus on the victimization of a minor who was abused by Epstein for several years, beginning when she was fourteen years old. Several months after Maxwell and Epstein met her, they began to encourage her to travel with them, and brought her to Epstein's mansion in New York, where she was also abused. Maxwell had a significant role in grooming her for abuse and facilitating Epstein's access to her.

The memorandum includes details from victim interviews and corroborating evidence, such as flight records and witness testimonies, to support the charges against Maxwell. It outlines the legal framework for the charges, including the elements of the offenses and the applicable statutes of limitations. The document also discusses anticipated defenses, discovery issues, and plans for arresting Maxwell.

The memorandum emphasizes the need for coordination with the FBI and other agencies to ensure a thorough investigation and successful prosecution. It also highlights the importance of victim support and restitution, as mandated by the Victims of Trafficking and Violence Protection Act of 2000.