This document is page 11 of a criminal filing (Case 1:20-cr-00330-PAE) against Ghislaine Maxwell, filed in March 2021. It details allegations that between 2001 and 2004, Maxwell and Epstein groomed 'Minor Victim-4' by sending gifts (including lingerie) and encouraged her to recruit other underage girls for sexualized massages at the Palm Beach residence in exchange for cash. Additionally, it alleges that in 2016, Maxwell committed perjury during a civil deposition regarding her role in these abuses.
| Name | Role | Context |
|---|---|---|
| Ghislaine Maxwell | Defendant |
Accused of sending gifts (lingerie) to a minor, encouraging recruitment of other minors, and committing perjury in a ...
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| Jeffrey Epstein | Perpetrator |
Recipient of 'sexualized massages' from minors; accused of abusing minor victims.
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| Minor Victim-4 | Victim / Recruiter |
Received gifts/lingerie; encouraged by Maxwell/Epstein to recruit other girls; paid cash for bringing girls to Palm B...
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| Epstein's Employees | Intermediaries |
Sent gifts to Minor Victim-4.
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| Unidentified young females/girls under 18 | Victims |
Recruited by Minor Victim-4 to provide sexualized massages.
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| Name | Type | Context |
|---|---|---|
| Southern District of New York |
Location mentioned in statutory allegations.
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| Department of Justice (DOJ) |
Indicated by footer stamp 'DOJ-OGR'.
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| Location | Context |
|---|---|
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Origin location of gifts/lingerie sent to victim.
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Destination of gifts sent to victim.
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Location where sexualized massages took place.
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Jurisdictional location for statutory allegations.
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"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
"both Minor Victim-4 and the girl she brought were paid hundreds of dollars in cash."Source
"GHISLAINE MAXWELL, the defendant, repeatedly provided false and perjurious statements, under oath"Source
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