This document is page 16 of a legal indictment against Ghislaine Maxwell, filed on March 29, 2021. It details specific allegations, including Maxwell encouraging 'Minor Victim-3' to massage Epstein in London (1994-1995) and inviting 'Minor Victim-4' to travel from Florida with Epstein (2001-2002). The page formally lays out '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 |
|---|---|---|
| Minor Victim-2 | Victim |
Mentioned as receiving an unsolicited message in New Mexico while topless.
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| Minor Victim-3 | Victim |
Allegedly encouraged by Maxwell to provide massages to Epstein in London between 1994-1995 while under the age of 18.
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| MAXWELL | Defendant |
Mentioned as encouraging Minor Victim-3 and inviting Minor Victim-4. Full name GHISLAINE MAXWELL is used later in the...
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| Epstein | Co-conspirator |
Mentioned as the recipient of massages from Minor Victim-3 and as inviting Minor Victim-4 to travel.
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| Minor Victim-4 | Victim |
Allegedly invited by Maxwell and Epstein to travel from Florida between 2001-2002 while under the age of 18.
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| GHISLAINE MAXWELL | Defendant |
Named as the defendant in Count Four, accused of transporting a minor for the purpose of criminal sexual activity.
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| Name | Type | Context |
|---|---|---|
| The Grand Jury | government agency |
Stated as bringing the charges in the indictment.
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| Location | Context |
|---|---|
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Location where an unsolicited message was sent to Minor Victim-2.
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Location where Maxwell allegedly encouraged Minor Victim-3 to provide massages to Epstein.
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Location from which Minor Victim-4 was invited to travel.
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Location where the alleged crime of transporting a minor occurred, among other places.
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