Document 20-cr-00330-ajn

Case 1:20-cr-00330-AJN Document 17 Filed 09/08/20 Page 26 of 125 13. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did persuade, induce, entice, and coerce an individual to travel in interstate and foreign commerce to engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do the same, and aided and abetted the same, to wit, MAXWELL persuaded, induced, enticed, and coerced Minor Victim-1 to travel from Florida to New York, New York on multiple occasions with the intention that Minor Victim-1 would engage in one or more sex acts with Jeffrey Epstein, in violation of New York Penal Law, Section 130.55. (Title 18, United States Code, Sections 2422 and 2.) COUNT THREE (Conspiracy to Transport Minors with Intent to Engage in Criminal Sexual Activity) The Grand Jury further charges: 14. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. 15. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, Jeffrey Epstein, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to 12 App.024 DOJ-OGR-00019483 --- PAGE BREAK --- Defense Counsel may make an appropriate application to the Court for any such modifications. SO ORDERED: Dated: New York, New York July 30, 2020 Alison J. Nathan HONORABLE ALISON J. NATHAN United States District Judge 12 App.086 DOJ-OGR-00019545 --- PAGE BREAK --- Case 20-cr-00330-AJN Document 473 Filed 03/24/21 Page 34 of 1 Criminal Notice of Appeal - Form A NOTICE OF APPEAL United States District Court Southern District of New York Caption: United States of America v. Ghislaine Maxwell Docket No.: 20-CR-00330-AJN Alison J. Nathan (District Court Judge) Notice is hereby given that Ghislaine Maxwell appeals to the United States Court of Appeals for the Second Circuit from the judgment other Order on Third Motion for Release on Bail (Doc. 169) entered in this action on March 22, 2021 (date) This appeal concerns: Conviction only | Sentence only | Conviction & Sentence | Other Defendant found guilty by plea | trial | N/A. Offense occurred after November 1, 1987? Yes | No | N/A Date of sentence: N/A Bail/Jail Disposition: Committed Not committed | N/A Appellant is represented by counsel? Yes | No If yes, provide the following information: Defendant's Counsel: David Oscar Markus Counsel's Address: Markus/Moss PLLC 40 NW Third Street, Ph 1, Miami, Florida 33128 Counsel's Phone: (305)379-6667 Assistant U.S. Attorney: Maurene Comey, Alison Moe & Lara Pomerantz AUSA's Address: The Silvio J. Mollo Building One Saint Andrew's Plaza, New York, New York 10007 AUSA's Phone: (212)637-2324 Signature DOJ-OGR-00000840 --- PAGE BREAK --- Case 1:20-cr-00330-AJN Document 17 Filed 09/08/20 Page 38 of 125 New York Residence, in violation of New York Penal Law, Section 130.55. c. In or about 1996, when Minor Victim-2 was under the age of 18, MAXWELL provided Minor Victim-2 with an unsolicited massage in New Mexico, during which Minor Victim-2 was topless. d. Between in or about 1994 and in or about 1995, when Minor Victim-3 was under the age of 18, 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. (Title 18, United States Code, Section 371.) COUNT FOUR (Transportation of a Minor with Intent to Engage in Criminal Sexual Activity) The Grand Jury further charges: 18. The allegations contained in paragraphs 1 through 8 of this Indictment are repeated and realleged as if fully set forth within. 19. From at least in or about 1994, up to and including in or about 1997, in the Southern District of New York and elsewhere, GHISLAINE MAXWELL, the defendant, knowingly did transport an individual who had not attained the age of 18 in interstate and foreign commerce, with the intent that the individual engage in sexual activity for which a person can be charged with a criminal offense, and attempted to do so, and 14 App.026 DOJ-OGR-00019485