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Case 1:20-cr-00330-PAE Document 767 Filed 08/10/22 Page 222 of 257 3056
LCKCmax9 Charge

1 by at least one of the conspirators in furtherance of that
2 conspiracy. In other words, the government must show that the
3 agreement went beyond the mere talking stage. It must show
4 that at least one the conspirators in furtherance of the
5 conspiracy.
6 With respect to the overt acts for Count One, the
7 indictment alleges as follows:
8 One, between in or about 1994 and in or about 1997,
9 when Jane was under the age of 17, Maxwell participated in
10 multiple group sexual encounters with Epstein and Jane in New
11 York and Florida.
12 Two, in or about 1996, when Jane was under the age of
13 17, Jane was enticed to travel from Florida to New York for
14 purposes of sexually abusing her at the New York residence in
15 violation of New York Penal Law, Section 130.55.
16 Three, in or about 1996, Maxwell provided Annie with
17 an unsolicited massage in New Mexico during which Annie was
18 topless.
19 Four, between in or about 2001 and in or about 2002,
20 when Carolyn was under the age of 17, Maxwell and Epstein
21 invited Carolyn to travel from Florida to a place outside of
22 Florida with Epstein.
23 With respect to the overt acts to Count Three, the
24 indictment alleges as follows:
25 Between in or about 1994 and in or about 1997 when

SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300

DOJ-OGR-00017243