EFTA00020401.pdf

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Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 1 of 24 
ORIGINAL 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
 
 
x 
• 
UNITED STATES OF AMERICA 
• 
• 
GHISLAINE MAXWELL, 
Defendant. 
COUNT ONE 
SUPERSEDING INDICTMENT 
S2 20 Cr. 330 (AJN) 
(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 2004, 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 
EFTA00020401


Case 1:20-cr-00330-AJN Document 187 Filed 03/29/21 Page 2 of 24 
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…
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