This document page, part of the government's case against Ghislaine Maxwell, details the grooming of 'Minor Victim-4' between 2001 and 2004, including the sending of lingerie from New York to Florida and the encouragement by both Epstein and Maxwell for the victim to recruit other underage girls for sexualized massages at the Palm Beach residence. It alleges that Maxwell and Epstein paid cash for these acts. Furthermore, it charges Maxwell with perjury regarding these events during a 2016 civil deposition.
| Name | Role | Context |
|---|---|---|
| Minor Victim-4 | Victim/Recruiter (under duress) |
Target of grooming; received gifts; encouraged to recruit other girls.
|
| Jeffrey Epstein | Perpetrator |
Received sexualized massages; paid victims.
|
| Ghislaine Maxwell | Defendant/Perpetrator |
Sent gifts (lingerie); encouraged recruitment; accused of perjury in 2016 deposition.
|
| Epstein's employees | Facilitators |
Sent gifts to Minor Victim-4.
|
| Multiple females/girls under the age of 18 | Victims |
Recruited by Minor Victim-4 to provide sexualized massages.
|
| Name | Type | Context |
|---|---|---|
| Southern District of New York |
Location of statutory allegations.
|
| Location | Context |
|---|---|
|
Origin address of gifts sent to victim.
|
|
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Residence of Minor Victim-4.
|
|
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Location where sexualized massages occurred.
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Jurisdiction for statutory allegations.
|
"Epstein's employees, including at times MAXWELL, sent Minor Victim-4 gifts, including lingerie"Source
"Epstein and MAXWELL each also encouraged Minor Victim-4 to recruit other young females to provide sexualized massages to Epstein."Source
"Minor Victim-4 brought multiple females, including girls under the age of 18, to provide sexualized massages for Epstein at the Palm Beach Residence."Source
"GHISLAINE MAXWELL, the defendant, repeatedly provided false and perjurious statements, under oath"Source
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