EFTA02731226

U.S. Department of Justice
United States Attorney
Southern District ofN ew York
Prosecution Memorandum
Privileged and Confidential - Attorney Work Product
Do Not Disseminate Outside of the SDNY USAO (or other DOS COMPONENT, as needed)
USAO #: United States v. Maxwell, 3/14/2021
S2 20 Cr. 330 (AJN)
I. Overview
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 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
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EFTA02731226