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AO 106A i0R'l 81 Application for a Warrant by Telephone or Other Reliable Electronic Means
UNITED STATES DISTRICT COURT
for the
District of New Hampshire
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address) )
Case No.
The Premises Known and Described as 338 East
Washington Road, Bradford, New Hampshire 03221
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APPLICATION FOR A WARRANT BY TELEPHONE OR OTHER RELIABLE ELECTRONIC MEANS
I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe she
property to be searched and give its location):
Please see attached Affidavit and Attachment A.
located in the District of New Hampshire , there is now concealed °den* the
person or describe the property to be seized):
Please see attached Affidavit and Attachment A.
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
O evidence of a crime;
O contraband, fruits of crime, or other items illegally possessed;
O property designed for use, intended for use, or used in committing a crime;
tea person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section Offense Description
18 U.S.C. 371 conspiracy to entice minors and-transport minors
18 U.S.C. 2422,2423(a) enticement of a minor, and transportation of a minor
tt . . . 1b2 penury
The application is based on these facts:
Please see attached Affidavit.
el# Continued on the attached sheet.
lie Delayed notice of 30 days (give exact ending date if more than 30 days: ) is requested under
18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.
/s/Amanda Young
Applicant's signature
Special Agent, FBI
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by
telephonic means
Date: 07/02/2020
atediaanena_
Judge's signature
City and state: Concord. NH Hon. Andrea K. Johnstone, U.S. Magistrate Judge
Printed name angthiqt_Ght00000663
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In the Matter of the Application of the United TO BE FILED UNDER SEAL
States Of America for a Search and Seizure
Warrant for the Premises Known and Described Agent Affidavit in Support of
as 338 East Washington Road, Bradford, New Application for Search Warrant
Hampshire 03221
SOUTHERN DISTRICT OF NEW YORK) ss.:
being duly sworn, deposes and says:
1. Introduction
A. Affiant
1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since
2017. During that time, I have participated in numerous investigations and prosecutions of crimes
against children, including the sexual abuse of minors. I have also participated in the execution of
multiple search warrants.
2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal
Rules of Criminal Procedure for a warrant to search the premises specified below (the "Subject
Premises") for the purpose of locating GHISLAINE MAXWELL, who is a person to be arrested
pursuant to an arrest warrant issued by a United States Magistrate Judge sitting in the Southern
District of New York. This affidavit is based upon my personal knowledge; my review of
documents and other evidence; and my conversations with other law enforcement personnel.
Because this affidavit is being submitted for the limited purpose of establishing probable cause, it
does not include all the facts that I have learned during the course of my investigation. Where the
contents of documents and the actions, statements, and conversations of others are reported herein,
they are reported in substance and in part, except where otherwise indicated.
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B. The Subject Premises
3. The Subject Premises are particularly described as a 156-acre property located at
338 East Washington Road, Bradford, New Hampshire 03221 and containing three separate
structures: a main residence, a guesthouse, and a garage. As detailed further herein, GHISLAINE
MAXWELL, a Target Subject of this investigation, is believed to be currently present within the
Subject Premises. An aerial photograph depicting all three ofthe structures ofthe Subject Premises
is included below:
Two photographs of the front of the main residence of the Subject Premises from two different
angles are included below:
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A photograph of the guesthouse of the Subject Premises is included below:
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C. The Target Subject and the Subject Offenses
4. The Target Subject of this investigation is GHISLAINE MAXWELL.
5. On June 29, 2020, a grand jury in the Southern District of New York returned an
indictment charging GHISLAINE MAXWELL with violations of 18 U.S.C. § 371 (conspiracy to
entice minors to travel to engage in illegal sex acts); 18 U.S.C. § 2422 (enticement of a minor to
travel to engage in illegal sex acts); 18 U.S.C. § 371 (conspiracy to transport minors with intent to
engage in criminal sexual activity); 18 U.S.C. § 2423(a) (transportation of a minor with intent to
engage in criminal sexual activity); and 18 U.S.C. § 1623 (perjury) (collectively, the "Subject
Offenses"). The Indictment charging MAXWELL is attached as Exhibit A hereto (the
"Indictment").
6. Also on June 29, 2020, United States Magistrate Judge Lisa Margaret Smith signed
a warrant for OH ISLAINE MAXWELL's arrest, which is attached as Exhibit B hereto (the "Arrest
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Warrant"). Accordingly, I respectfully submit that there is probable cause to believe that
MAXWELL is a "person to be arrested" within the meaning ofFederal Rule ofCriminal Procedure
41(c)(4).
7. For the reasons detailed below, I respectfully submit that there is probable cause to
believe that GHISLAINE MAXWELL will be found within the Subject Premises.
II. Probable Cause
A. Probable Cause Regarding the "target Subject's Commission of the
Subject Offenses
8. As set forth in paragraph 5 above, a grand jury sitting in the Southern District of
New York has returned an indictment charging the Target Subject with the Subject Offenses.
B. Probable Cause Justifying Search of the Subject Premises
9. As detailed herein, and notwithstanding the efforts of GHISLAINE MAXWELL
described below to evade detection since the arrest in July 2019 of her co-conspirator, Jeffrey
Epstein, I and other agents have been able to identify a cellphone used by MAXWELL that, as
specified below, is presently located in or around the Subject Premises. In particular, as detailed
herein, a cell-site simulator placed the cellphone used by MAXWELL at the Subject Premises at
approximately 7:36 AM on July 2, 2020, and cell site data similarly confirms that the cellphone
used by MAXWELL has been in the vicinity of the Subject Premises on a regular basis for at
least the last 30 days.
10. Based on my participation in the investigation, I know that since the arrest of
GHISLAINE MAXWELL's co-conspirator, Jeffrey Epstein, in July 2019, MAXWELL has
intentionally sought to evade detection. For example, since that time, MAXWELL has avoided
public appearances, has moved at least twice, has stopped using a cellphone associated with her at
the time of Epstein's arrest and started using a new cellphone registered simply in the name "0
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Max," (described herein as the "Target Cellphone"), has ordered packages from her Amazon
account to be delivered to her under the name of another person, and has intentionally stayed out
of public view. I further know that, since approximately July 2019, MAXWELL has been aware
that she is the subject of an ongoing criminal investigation into her relationship with Epstein and
her role in facilitating his abuse of minor girls.
11. Based on my review of Customs and Border Patrol records, I know that
GHISLAINE MAXWELL is a United States citizen and that she most recently entered the United
States in or about June of 2019. There is no record of MAXWELL leaving the United States since
her arrival in June of 2019.
12. Based on my review of AT&T records, and as noted above, I have learned that the
cellphone with phone number (the "Target Cellphone") is subscribed in the name
of "G Max," which appears to be a shortened version of GHISLAINE MAXWELL's name. The
Target Cellphone is presently active.
13. On or about June 30, 2020, United States Magistrate Judge Katharine H. Parker,
signed a warrant for cellphone location information for the Target Cellphone (the "Cell Site
Warrant"), which is attached as Exhibit C, after finding probable cause to believe that GHISLAINE
MAXWELL is presently using the Target Cellphone. Pursuant to the Cell Site Warrant, the FBI
has received GPS location data for the Target Cellphone since approximately 10:15 PM on June
30, 2020 and has also received historical cell site data for the Target Cellphone for the period June
1, 2020 to June 30, 2020. As detailed further below, data obtained pursuant to the Cell Site Warrant
confirms that MAXWELL is presently in the general location of the Subject Premises and has
remained in that area consistently for at least the past 30 days.
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14. On July I, 2020, United States Magistrate Judge Andrea K. Johnstone signed a
warrant for the use of a cell-site simulator for the Target Cellphone (the "Cell-Site Simulator
Warrant"), which is attached as Exhibit D, after also finding probable cause to believe that
MAXWELL is presently using the Target Cellphone. A copy of the application in support of that
Cell-Site Simulator Warrant, which sets forth in greater detail the probable cause to believe
MAXWELL is using the Target Cellphone, is attached as Exhibit E.
15. Pursuant to the Cell-Site Simulator Warrant, the Target Cellphone was found to be
at the Subject Premises on July 2, 2020 at approximately 7:36 AM.
16. I know from my review of AT&T records and my conversations with other law
enforcement agents that the GPS location and cell site data collected pursuant to the Cell Site
Warrant revealed the following:
a. GPS location data, also known as precision location information, provides
relatively precise location information about a cellphone, which a provider can typically collect
either via GPS tracking technology built into the phone or by triangulating the device's signal as
received by the provider's nearby cell towers. Cell site data, by contrast, reflects only the cell
tower and sector thereof utilized in routing any communication to and from the cellphone, as well
as the approximate range of the cellphone from the tower during the communication (sometimes
referred to as "per-call measurement" ("PCM") or "round-trip time" ("RTT") data). Because cell
towers are often a half-mile or more apart, even in urban areas, and can be ten or more miles apart
in rural areas, cell site data is helpful but typically less precise than precision location information.
b. Through the Cell Site Warrant, law enforcement was able to obtain cell site
data for the Target Cellphone. While less precise than a cell-site simulator, consistent with the
current location obtained pursuant to the Cell-Site Simulator Warrant as detailed in paragraph 15,
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above, I am aware that the cell site data for the Target Cellphone reveals that it has been located
in and around Bradford, New Hampshire for at least the past 30 days. More specifically, I am
aware that during that same period, the Target Cellphone has regularly connected with a cell tower
that covers an area that includes the Subject Premises (the "Subject Premises Cell Tower".)
c. Cell site data further indicates that The Target Cellphone has been within
the vicinity of the Subject Premises Cell Tower as recently as within the last approximately 24
hours.
17. In addition to the cell-site simulator data, which has confirmed that the Target
Cellphone was at the Subject Premises on the morning of July 2, 2020, and the Cell Site Data
confirming that the Target Cellphone has been in the vicinity of the Subject Premises for at least
the past 30 days, I know based on my review of property records and my conversations with other
law enforcement agents the following:
a. Although there are multiple residences, including the Subject Premises,
within the vicinity of the Subject Premises Cell Tower, with the exception of the Subject Premises,
all of the other residences in that area are owned in the names of individuals or in the names of
identified family trusts. By contrast, the Subject Premises is the only property within the vicinity
of the Subject Premises Cell Tower that is owned by an entity. In particular, the Subject Premises
is owned by an entity called Granite Realty LLC, a name seemingly designed to obscure the true
identity of its owner.
b. On or about December 13, 2019, Granite Realty LLC purchased the Subject
Premises for $1,070,000 in an all cash sale.
18. Based on the above, I respectfully submit that there is probable cause to believe
that GHISLAINE MAXWELL is currently located within the Subject Premises. In particular,
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the fact that the cell-site simulator confirmed the Target Cellphone was located in the Subject
Premises at approximately 7:36 AM this morning and that cell site data confirmed that the
Target Cellphone has been located in the vicinity of the Subject Premises on a regular basis for
the past 30 days, makes it likely that MAXWELL is currently in the Subject Premises with her
phone. Moreover, although there are multiple residences located within the range of the Subject
Premises Cell Tower, the Subject Premises is the only residence located within that area that is
owned in the name of an anonymous entity, which is consistent with MAXWELL's extensive
efforts, described above, to remain anonymous after the arrest of her co-conspirator, Jeffrey
Epstein.
III. Conclusion and Ancillary Provisions
19. Based on the foregoing, I respectfully submit that there is probable cause to believe
that GHISLAINE MAXWELL is a person to be arrested for the Subject Offenses and that she is
currently located at the Subject Premises. I therefore respectfully request the court to issue a
warrant to search for the individual specified in Attachment A to this affidavit and to the Search
and Seizure Warrant.
Respectfully submitted,
/5/
Special Agent
Federal Bureau of Investigation
The affiant appeared before me by telephonic conference on this date pursuant to Fed. R.
Crim. P. 4.1 and affirmed under oath the content of this affidavit and application.
limdea-lappenta_
Honorable Andrea K. Johnstone
United States Magistrate Judge
District of New Hampshire
Dated: Jul 2, 2020
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ATTACHMENT A
I. Premises to be Searched—Subject Premises
The Subject Premises are particularly described as a 156-acre property located at 338 East
Washington Road, Bradford, New Hampshire 03221 and containing three separate structures: a
main residence, a guesthouse, and a garage. As detailed further herein, GHISLA1NE MAXWELL,
a Target Subject of this investigation, is believed to be currently present inside the Subject
Premises. An aerial photograph depicting all three of the structures of the Subject Premises is
included below:
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Two photographs of the front of the main residence of the Subject Premises from two different
angles are included below:
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A photograph of the guesthouse of the Subject Premises is included below:
11. Person to Be Seized
This warrant authorizes executing agents to search the Subject Premises for GHISLAINE
MAXWELL, who is a person to be arrested for violations of 18 U.S.C. § 371 (conspiracy to entice
minors to travel to engage in illegal sex acts); 18 U.S.C. § 2422 (enticement of a minor to travel
to engage in illegal sex acts); 18 U.S.C. § 371 (conspiracy to transport minors with intent to engage
in criminal sexual activity); 18 U.S.C. § 2423(a) (transportation of a minor with intent to engage
in criminal sexual activity); and 18 U.S.C. § 1623 (perjury).
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EXHIBIT A
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
SEALED
UNITED STATES OF AMERICA INDICTMENT
20 Cr.
GHISLAINE MAXWELL,
Defendant.
20 Cr. 330
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 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 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 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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d. MAXWELL's personal residence in London,
England.
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 i8. 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-
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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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, 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, 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
(Transpo rtation 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. 7344, 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. 7344, knowingly made false material
declarations, to wit, MAXWELL gave the following underlined
false testimony:
Q: 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.)
"PERS /a— AUDREY RAUSS
Acting n
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EFTA01251115
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