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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 21 of 24 
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 EIGHT 
(Perjury) 
The Grand Jury further charges: 
30. The allegations contained in paragraphs 1 through 
9 of this Indictment are repeated and realleged as if fully set 
forth within. 
31. 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: 
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? 
Other than yourself and the blond and brunette 
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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. 
• 
e 
• 
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.) 
FORFEITURE ALLEGATIONS 
32. As a result of committing the offense alleged in 
Count Six of this Indictment, GHISLAINE MAXWELL, the defendant, 
shall forfeit to the United States, pursuant to Title 18, United 
States Code, Section 1594(c)(1), any property, real and 
personal, that was used or intended to be used to commit or to 
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facilitate the commission of the offense alleged in Count Six, 
and any property, real or personal, constituting or derived from 
any proceeds obtained, directly or indirectly, as a result of 
the offense alleged in Count Six, or any property traceable to 
such property. 
Substitute Asset Provision 
33. If any of the above-described forfeitable 
property, as a result of any act or omission of the defendant: 
(a) cannot be located upon the exercise of due diligence; 
(b) has been transferred or sold to, or deposited with, a 
third person; 
(c) has been placed beyond the jurisdiction of the Court; 
(d) has been substantially diminished in value; or 
(e) has been commingled with other property which cannot 
be subdivided without difficulty; 
it is the intent of the United States, pursuant to 21 U.S.C. 
853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any 
other property of the defendant up to the value of the above 
forfeitable property. 
(Title 18, United States Code, Section 1594; Title 21, 
United States Code, Section 853; and 
Title 28, United States Code, Section 2461.) 
FOREPERSON 
AUD
Y STRAUSS 
United 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 
S2 20 Cr. 330 (AJN) 
(18 U.S.C. §S 371, 1591, 1623, 2422, 
2423(a), and 2) 
AUDREY STRAUSS 
United States Attorney 
7  L 
i t  {- 71 
oreperson 
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