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Case 20-3061, Document 60, 09/24/2020, 2938278, Page6 of 58

Statement of the Case and the Facts

The indictment.

In a superseding indictment, the government alleges that Ms. Maxwell:
conspired with Jeffrey Epstein to entice minors to travel to engage in illegal sex acts
(Count 1); enticed a minor to travel to engage in illegal sex acts (Count 2);
conspired with Epstein to transport minors with the intent to engage in criminal
sexual activity (Count 3); transported a minor with the intent to engage in criminal
sexual activity (Count 4); committed perjury in the April 2016 deposition in Giuffre
v. Maxwell, No. 15-cv-7433 (S.D.N.Y) (Count 5); and committed perjury in the July
2016 deposition in Giuffre v. Maxwell (Count 6). App. 13–30.

The civil case.

Giuffre v. Maxwell is a long-dismissed defamation case in which Virginia L.
Giuffre alleged that Ms. Maxwell defamed her. The alleged defamation centered on
a statement from Ms. Maxwell’s attorney-hired press agent generally denying as
“untrue” and “obvious lies” plaintiff’s numerous allegations, over the span of four
years, that Ms. Maxwell participated in a scheme causing her to be “sexually
abused and trafficked” by Epstein. The case settled after discovery and before trial,
and the district court dismissed the case with prejudice in May 2017.

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