This document is a page from a legal filing (Case 1:20-cr-00330-PAE) detailing overt acts for Counts Three and Five of an indictment against Ghislaine Maxwell. It lists specific allegations of sexual abuse and recruitment involving minors named Jane and Carolyn between 1994 and 2004 in New York and Florida. The document is heavily edited with strike-throughs, notably removing allegations related to victims named Annie and Kate, and adjusting the age of victims from 17 to 18.
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant/Accused |
Accused of participating in sexual encounters, enticing minors to travel, and recruiting minors for Epstein.
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| Jeffrey Epstein | Co-conspirator |
Accused of sexually abusing minors and paying for sex acts.
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| Jane | Victim (Minor) |
Under age 18 (edited from 17); victim of group sexual encounters in NY and FL (1994-1997).
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| Annie | Victim (Minor) |
Mentioned in a struck-through section regarding an unsolicited massage in New Mexico (1996).
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| Kate | Victim (Minor) |
Mentioned in a struck-through section regarding massages in London (1994-1995).
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| Carolyn | Victim (Minor) |
Under age 18; recruited for sex acts at Palm Beach Residence; recruited other girls; received cash and gifts.
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| Location | Context |
|---|---|
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Location of sexual encounters and residence.
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Location where victims resided and traveled from.
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Specific location of abuse for Jane.
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Specific location of abuse for Carolyn.
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Location mentioned in struck-through text regarding Annie.
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Location mentioned in struck-through text regarding Kate.
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Origin address for gifts sent to Carolyn.
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"Maxwell participated in multiple group sexual encounters with Epstein and Jane in New York and Florida"Source
"Epstein and, at times, Maxwell provided Carolyn with hundreds of dollars in cash for each encounter."Source
"Carolyn truthfully told both Epstein and Maxwell her age"Source
"Epstein and Maxwell both encouraged and enticed Carolyn to recruit other girls to engage in paid sex acts with Epstein"Source
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