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Document 148-1

AI Analysis

Summary: This document is a list of particulars requested by the defense in the case against Ghislaine Maxwell, seeking detailed information about the allegations involving Minor Victims-1-3 and their interactions with Maxwell and Epstein. The list includes specific dates, locations, and actions related to the charges. The document is a court filing in the case United States v. Maxwell (1:20-cr-00330-AJN).
Significance: This document is potentially important as it provides detailed information requested by the defense regarding the allegations against Ghislaine Maxwell, which could be crucial for her defense in the criminal case.
Key Topics: Details about Minor Victims-1-3 and their interactions with Ghislaine Maxwell and Jeffrey Epstein Alleged crimes and conspiracies involving Ghislaine Maxwell and Jeffrey Epstein Specific actions and events related to the charges against Ghislaine Maxwell
Key People:
  • Ghislaine Maxwell - Defendant in the criminal case
  • Jeffrey Epstein - Co-conspirator and alleged perpetrator of sexual abuse
  • Minor Victim-1 - Alleged victim of sexual abuse
  • Minor Victim-2 - Alleged victim of sexual abuse
  • Minor Victim-3 - Alleged victim of sexual abuse
Document Type
Exhibit
Date
02/04/21
Pages
4
Folder
IMAGES001

Full Text

Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 1 of 4 Exhibit A DOJ-OGR-00002717 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 2 of 4 LIST OF PARTICULARS 1. Please provide the full names and full birthdays of the individuals identified in the Superseding Indictment as Minor Victims-1-3 (¶¶ 7, 11, 13, 17, 19). 2. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-1 (¶ 7a). 3. Please identify the dates when, and locations where, Ms. Maxwell allegedly "groomed" Minor Victim-1 "to engage in sexual acts with Epstein" (¶ 7a). 4. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-1 (¶ 7a). 5. Please identify the dates when, and locations where, Ms. Maxwell allegedly "was present for and involved in" Epstein's sexual abuse of Minor Victim-1 (¶ 7a). 6. Please identify the dates when, and locations where, Minor Victim-1 participated in "group sexualized massages" of Epstein (¶ 7a). 7. Please describe with particularity the conduct that the government contends is a "group sexualized massage" and identify the criminal statute(s) the conduct allegedly violates and the other participants in those massages (¶ 7a). 8. Please describe with particularity how Ms. Maxwell allegedly "involved" Minor Victim-1 in these massages and how Ms. Maxwell allegedly participated in these massages (¶ 7a). 9. Please identify the dates when Minor Victim-1 allegedly traveled "across state lines for the purpose of sexual encounters with Epstein" (¶ 7a). 10. Please identify the dates when Ms. Maxwell allegedly enticed Minor Victim-1 "to travel across state lines for the purpose of sexual encounters with Epstein" and describe with particularity the actions that Ms. Maxwell allegedly took to entice Minor Victim-1 to travel (¶ 7a). 11. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-2 (¶ 7b). 12. Please identify the dates when Minor Victim-2 allegedly traveled across state lines to and from New Mexico in 1996 (¶ 7b). 13. Please identify the dates when Ms. Maxwell allegedly "groomed" Minor Victim-2 to engage in "acts of sexual abuse" with Epstein (¶ 7b). DOJ-OGR-00002718 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 3 of 4 14. Please describe with particularity what Ms. Maxwell allegedly did as part of the "unsolicited massage" of Minor Victim-2 and identify the criminal statute(s) the conduct allegedly violates (¶ 7b, 11c, 17c). 15. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-3 (¶ 7c). 16. Please identify the dates when, and locations where, Ms. Maxwell allegedly introduced Minor Victim-3 to Epstein and the dates and locations of their subsequent "multiple interactions" (¶ 7c). 17. Please identify the dates when, and locations where, Ms. Maxwell allegedly "groomed" Minor Victim-3 to engage in sex acts with Epstein (¶ 7c). 18. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-3 (¶ 7c). 19. Please describe with particularity the "sex acts" that Minor Victim-3 allegedly engaged in with Epstein during massages and identify the criminal statute(s) the conduct allegedly violates and the other participants in those massages (¶ 7c). 20. Please identify the dates when Minor Victim-3 allegedly traveled in interstate or foreign commerce to engage in illegal sexual activity with Epstein (¶ 7c). 21. Please specify when the conspiracies charged in Count One and Count Three began and ended. (¶¶ 9, 15). 22. Please identify the "others" who allegedly participated in the conspiracies charged in Count One and Count Three with Epstein and Ms. Maxwell. (¶¶ 9-10, 15-16). 23. Please identify any individuals who were enticed to travel, or were transported, in interstate or foreign commerce to engage in illegal sexual activity with Epstein during the time period of the charged conspiracies (1994-1997), apart from Minor Victims-1-3 (¶ 10, 16). 24. Please identify the dates when, and the locations where, Ms. Maxwell participated in "group sexualized encounters" with Jeffrey Epstein and Minor Victim-1 (¶¶ 11a, 17a). 25. Please describe with particularity the conduct that the government believes constitutes a "group sexualized encounter" and identify the criminal statute(s) the conduct violates and the participants in those encounters (¶¶ 11a, 17a). 26. Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New York in 1996 (¶¶ 11b, 17b). DOJ-OGR-00002719 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 4 of 4 27. Please identify from whom Ms. Maxwell was allegedly trying to "conceal her crimes" when she allegedly lied under oath in depositions in 2016 (¶ 2). 28. Please identify "the specific events and acts of abuse" about which Ms. Maxwell allegedly "repeatedly provided false and perjurious statements" (¶ 8). 29. As to each statement alleged to be perjurious in Counts Five and Six of the Superseding Indictment please specify why the Government contends the statement was material (¶¶ 21, 23). DOJ-OGR-00002720

Individual Pages

Page 1 - DOJ-OGR-00002717
Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 1 of 4 Exhibit A DOJ-OGR-00002717
Page 2 of 4 - DOJ-OGR-00002718
Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 2 of 4 LIST OF PARTICULARS 1. Please provide the full names and full birthdays of the individuals identified in the Superseding Indictment as Minor Victims-1-3 (¶¶ 7, 11, 13, 17, 19). 2. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-1 (¶ 7a). 3. Please identify the dates when, and locations where, Ms. Maxwell allegedly "groomed" Minor Victim-1 "to engage in sexual acts with Epstein" (¶ 7a). 4. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-1 (¶ 7a). 5. Please identify the dates when, and locations where, Ms. Maxwell allegedly "was present for and involved in" Epstein's sexual abuse of Minor Victim-1 (¶ 7a). 6. Please identify the dates when, and locations where, Minor Victim-1 participated in "group sexualized massages" of Epstein (¶ 7a). 7. Please describe with particularity the conduct that the government contends is a "group sexualized massage" and identify the criminal statute(s) the conduct allegedly violates and the other participants in those massages (¶ 7a). 8. Please describe with particularity how Ms. Maxwell allegedly "involved" Minor Victim-1 in these massages and how Ms. Maxwell allegedly participated in these massages (¶ 7a). 9. Please identify the dates when Minor Victim-1 allegedly traveled "across state lines for the purpose of sexual encounters with Epstein" (¶ 7a). 10. Please identify the dates when Ms. Maxwell allegedly enticed Minor Victim-1 "to travel across state lines for the purpose of sexual encounters with Epstein" and describe with particularity the actions that Ms. Maxwell allegedly took to entice Minor Victim-1 to travel (¶ 7a). 11. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-2 (¶ 7b). 12. Please identify the dates when Minor Victim-2 allegedly traveled across state lines to and from New Mexico in 1996 (¶ 7b). 13. Please identify the dates when Ms. Maxwell allegedly "groomed" Minor Victim-2 to engage in "acts of sexual abuse" with Epstein (¶ 7b). DOJ-OGR-00002718
Page 3 - DOJ-OGR-00002719
Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 3 of 4 14. Please describe with particularity what Ms. Maxwell allegedly did as part of the "unsolicited massage" of Minor Victim-2 and identify the criminal statute(s) the conduct allegedly violates (¶ 7b, 11c, 17c). 15. Please identify the dates when, and locations where, Ms. Maxwell allegedly met and/or interacted with Minor Victim-3 (¶ 7c). 16. Please identify the dates when, and locations where, Ms. Maxwell allegedly introduced Minor Victim-3 to Epstein and the dates and locations of their subsequent "multiple interactions" (¶ 7c). 17. Please identify the dates when, and locations where, Ms. Maxwell allegedly "groomed" Minor Victim-3 to engage in sex acts with Epstein (¶ 7c). 18. Please identify the dates when, and locations where, Jeffrey Epstein allegedly sexually abused Minor Victim-3 (¶ 7c). 19. Please describe with particularity the "sex acts" that Minor Victim-3 allegedly engaged in with Epstein during massages and identify the criminal statute(s) the conduct allegedly violates and the other participants in those massages (¶ 7c). 20. Please identify the dates when Minor Victim-3 allegedly traveled in interstate or foreign commerce to engage in illegal sexual activity with Epstein (¶ 7c). 21. Please specify when the conspiracies charged in Count One and Count Three began and ended. (¶¶ 9, 15). 22. Please identify the "others" who allegedly participated in the conspiracies charged in Count One and Count Three with Epstein and Ms. Maxwell. (¶¶ 9-10, 15-16). 23. Please identify any individuals who were enticed to travel, or were transported, in interstate or foreign commerce to engage in illegal sexual activity with Epstein during the time period of the charged conspiracies (1994-1997), apart from Minor Victims-1-3 (¶ 10, 16). 24. Please identify the dates when, and the locations where, Ms. Maxwell participated in "group sexualized encounters" with Jeffrey Epstein and Minor Victim-1 (¶¶ 11a, 17a). 25. Please describe with particularity the conduct that the government believes constitutes a "group sexualized encounter" and identify the criminal statute(s) the conduct violates and the participants in those encounters (¶¶ 11a, 17a). 26. Please identify who allegedly enticed Minor Victim-1 to travel from Florida to New York in 1996 (¶¶ 11b, 17b). DOJ-OGR-00002719
Page 4 - DOJ-OGR-00002720
Case 1:20-cr-00330-AJN Document 148-1 Filed 02/04/21 Page 4 of 4 27. Please identify from whom Ms. Maxwell was allegedly trying to "conceal her crimes" when she allegedly lied under oath in depositions in 2016 (¶ 2). 28. Please identify "the specific events and acts of abuse" about which Ms. Maxwell allegedly "repeatedly provided false and perjurious statements" (¶ 8). 29. As to each statement alleged to be perjurious in Counts Five and Six of the Superseding Indictment please specify why the Government contends the statement was material (¶¶ 21, 23). DOJ-OGR-00002720