This page of an indictment against Ghislaine Maxwell details specific allegations of abuse and recruitment. It charges that in 1996, Maxwell personally gave an unsolicited massage to a topless minor in New Mexico, and between 1994-1995, encouraged another minor to massage Jeffrey Epstein in London knowing abuse would occur. It also introduces 'Count Four,' charging Maxwell with the transportation of a minor with intent to engage in criminal sexual activity between 1994 and 1997.
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Charged with transporting minors and facilitating abuse; described as providing unsolicited massages.
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| Jeffrey Epstein | Co-conspirator / Abuser |
Intended to sexually abuse Minor Victim-3 during massages in London.
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| Minor Victim-2 | Victim |
Under age 18 in 1996; received unsolicited topless massage from Maxwell in New Mexico.
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| Minor Victim-3 | Victim |
Under age 18 between 1994-1995; encouraged by Maxwell to massage Epstein in London.
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| Name | Type | Context |
|---|---|---|
| The Grand Jury |
Charges Maxwell with Count Four.
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| Department of Justice (DOJ) |
Source of document (DOJ-OGR footer).
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| Location | Context |
|---|---|
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Mentioned in relation to violation of NY Penal Law.
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Location where Maxwell gave an unsolicited massage to Minor Victim-2.
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Location where Maxwell encouraged Minor Victim-3 to massage Epstein.
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Jurisdiction where the transportation of minors occurred.
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"MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless."Source
"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."Source
"GHISLAINE MAXWELL, the defendant, knowingly did transport an individual who had not attained the age of 18 in interstate and foreign commerce"Source
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