Prosecution Memorandum: United States v. Maxwell

This memorandum seeks authorization to charge GHISLAINE MAXWELL with additional criminal offenses based on her participation in the recruitment, grooming, and abuse of minor girls with Jeffrey Epstein in a superseding indictment.

Our Office previously obtained a six-count Indictment charging Maxwell with one count of conspiracy to transport a minor for illegal sexual activity, in violation of 18 U.S.C. § 371; one count of transporting a minor, in violation of 18 U.S.C. § 2423(a); one count of conspiracy to entice a minor to travel to engage in illegal sexual activity, in violation of 18 U.S.C. § 371: one count of enticing a minor to travel, in violation of 18 U.S.C. § 2422; and two counts of perjury. in violation of 18 U.S.C. § 1623. The evidence supporting those charges and the legal issues surrounding those charges were discussed at length in previous prosecution memos dated April 10, 2020 and April 28. 2020. As detailed in those memos, the current charges focus on the victimization of , all of whom were sexually abused by Epstein, with assistance from Maxwell, between 1994 and 1997. The perjury charges arise from false statements Maxwell made during a civil deposition in 2016. which statements are directly contradicted by the evidence we have gathered regarding-

Since obtaining the original Indictment charging Maxwell, our investigation has continued, including through the interviews of multiple Epstein victims who previously either declined to be interviewed or had not previously been identified. The charges we propose expanding and adding in a superseding indictment against Maxwell are based on the experiences of one victim in particular named who was sexually abused by Epstein at his Palm Beach residence from in or about 2001 throu 2005 when was between the ages of 14 and 18.1 As discussed in greater detail below, was one o e earliest recruits into s "pyramid scheme" of paid sexualized massages m Palm Beach. As a result, when first met Epstein in or about 2001. Maxwell was still directly involved in the scheme to

arrange for minor girls to provide sexualized massages to Epstein. In this vein, recalls multiple interactions with Maxwell that demonstrate Maxwell's knowledge of a e, Maxwell's knowledge that the massages were sexual, Maxwell's attempts to entice to travel with Epstein. and actions in the Southern District of New York in furtherance of the scheme to sexually abuse

With the addition of= as "Minor Victim-C to the charges against Maxwell, we believe that a superseding indictment could contain the following charges:

• Count One: Conspiracy to Transport Minors from 1994 to 2004, in violation of 18 U.S.C. § 371. This charge would expand the end date of the conspiracy from 1997 to 2004 and would add an overt act involving Minor Vicitm-4.

• Count Two: Transportation of a Minor from 1994 to 1997, in violation of 18 U.S.C. § 2423(a). This charge would be identical to Count Two of the original Indictment.

• Count Three: Conspiracy to Entice Minors from 1994 to 2004, in violation of 18 U.S.C. § 371. This charge would expand the end date of the conspiracy from 1997 to 2004 and add an overt act involving Minor Vicitm-4.

• Count Four: Enticement of a Minor from 1994 to 1997, in violation of 18 U.S.C. § 2422. This charge would be identical to Count Four of the original Indictment.

• Count Five: Conspiracy to Commit Sex Trafficking from 2001 to 2004, in violation of 18 U.S.C. § 371. This charge would be entirely new and would exclusively reference Minor Vicitm-4.

• Count Six: Sex Trafficking of a Minor from 2001 to 2004, in violation of 18 U.S.C. § 1591. This charge would be entirely new and would exclusively reference Minor Victim-4.

• Counts Seven & Eight: Perjury, in violation of 18 U.S.C. § 1623. These charges would be identical to Counts Five and Six, respectively, in the original Indictment.