Ghislaine Maxwell – the Charge Sheet

The following is taken from USA v. Ghislaine Maxwell, indictment 20 CR.330, and other sources to understand and clarify.

Terms like trafficking are used in ways that ‘the rest of us’ understand, rather than being the legal terms in the document

So what is she finally being charged for?

Ghislaine Maxwell is being charged for her role in the sexual exploitation and abuse of multiple girls by Jeffrey Epstein. From at least 1994 to 1997, Maxwell assisted, facilitated , and contributed to Jeffrey Epstein’s abuse of minor girls by helping Epstein to recruit and abuse victims under the age of 18 – some as young as 14.

Should this say allegedly? Probably. But 23 young women gave compelling testimony at the aborted trial of Jeffrey Epstein. It’s almost impossible to believe that all are ‘lying’ No-one would want the spotlight these women have been put under. Some of them were even persuaded themselves to recruit others. Their testimonies are raw and painful, and it is a credit to the judge in the Epstein case that they were allowed to testify, giving us all a sense of the importance of this case.

And, as part of a civil lawsuit in 2016, Maxwell repeatedly provided false statements, under oath (perjury), regarding, among other things, her role in facilitating the abuse of children by Jeffrey Epstein, including those mentioned here (below).

The Background

Ghislaine Maxwell and Jeffrey Epstein enticed and caused minor victims to travel to Epstein’s residences in different states, which she knew – and intended – would result in sexual abuse.

In the United States, age of consent laws are different at state, territorial, and federal district levels. Each U.S. state has its own age of consent, as does the District of Columbia. Therefore, the location of offences stressed in this indictment matters. Several federal statutes relate to protecting minors (children) from sexual predators, but none of them put age limits on sexual acts. In 2003, both heterosexual and homosexual sodomy, between non-commercial, consenting adults in a private bedroom, became legal across the U.S. states. As at August 2018, the age of consent in each state in the United States was either 16, 17 or 18 years of age – the most common age is 16. So the location of the offences matters.

it is well documented that Maxwell had both a personal (intimate) and professional relationship with Jeffrey Epstein and was among his closest associates. She was paid by Epstein to manage his various properties.

She used classic grooming techniques, befriending the victims prior to their abuse showing an interest in their lives, their schools and their families. She and Epstein would spend time building friendships by, for example, taking them to the movies or shopping. Some outings would be both of them with the victim, whilst others would involve just one of them.

Epstein offered to help some victims by paying for travel and/ or educational opportunities, and Maxwell encouraged the victims to accept Epstein’s assistance. Consequently, victims felt indebted and believed that the couple were trying to help them.

Having established a rapport with a victim, Maxwell would try to normalise sexual abuse, discussing sexual topics, undressing in front of the victim, being present when a minor victim was undressed, and/or being present for sex acts involving the victim and Epstein. She was often present for, and actively participated in, the abuse.

Sometimes the child was undressed or involved in sex acts with Epstein, with victims put at ease by the presence of Ghislaine, an adult woman. Sometimes she would massage Epstein in front of a victim; other times Maxwell would encourage victims to provide massages to Epstein, including sexualized massages during which the child would be fully or partially nude. Many of those massages resulted in sexual abuse, which might include touching a victim’s breast or genitals, or placing a sex toy such as a vibrator on a victim’s genitals.

The Victims

Victim 1 was 14 years old. Maxwell and Epstein befriended her, taking her to the movies and on shopping trips. Maxwell would relax her by being curious about her life. She would then engage in inappropriate and abusive conduct by things like undressing in front of her.  She was then present when the girl was encouraged to undress in front of Epstein. Within a year, Epstein’s sexual  abuse began. Maxwell was present for and involved in some of this abuse, notable during sexualized group massages. Maxwell encourage the young woman to travel, resulting in abuse in both in both New York and Florida.

Victim 2 was flown into New Mexico from out of state at Epstein’s invitation. Maxwell was well aware that she was under the age of 18. In New Mexico, Maxwell and Epstein took her to a movie and shopping. Maxwell began warming the victim up for abuse by Epstein by, among other things, providing an unsolicited massage to the victim whilst the victim was topless. She also encouraged the victim to massage Epstein.

Victim 3 was groomed and befriended in London, England. Again Maxwell was well aware that the girl was under 18. As with the others, Maxwell befriended her and asked about her life and family, eventually introducing her to Epstein. She encourage the girl to massage Epstein , knowing that he would engage in sex acts with her during those massages on multiple occasions.

I am struck by the fact that 23 stood up and testified against Epstein, but only three are on this charge sheet. And by the similarities with the Weinstein case, right down to the massages. My guess is that this is partly to do with age and location. But that’s just a guess. The charge sheet does make clear that there are other victims.

The charges

Count one: the sexual grooming charges

Count one legal breaches are detailed as being under Title 18, United States Code

  • violation of Section 2422: enticement;
  • violation of Section 2422: persuading, inducing, enticing, and coercing one and more individuals to travel interstate and abroad to engage in criminal sexual activity;
  • violation of Section 371: multiple group sexual encounters with a minor;
  • violation of Section 371 (and of New York Penal Law, Section 130.55): sexually abusing a victim at Epstein’s New York residence;
  • violation of Section 371: the unsolicited sexual, topless massage of victim 2;
  • violation of Section 371: encouraging victim 3 to give massages to Epstein in London, knowing that Epstein intended to sexually abuse her during those massages. (Maxwell was well aware of both the abuse and of the age of the girl.)

Count two: Trafficking – enticement

Count two legal breaches are detailed as “enticement of a minor to travel to engage in illegal sex acts”: Maxwell persuaded , induced , enticed , and coerced victim 1 to travel from Florida to New York on multiple occasions so that she, victim one, would engage in one or more sex acts (Breaches New York Penal Law, Section 130.55; and Title 18 , United States Code, Sections 2422 and 2. )

Count three: Trafficking – conspiracy

There are repeated listings of sexual abuse and of forwarding naked pictures of one of the victims by Maxwell.

Count three is “conspiracy to transport minors with intent to engage in criminal sexual activity”, in violation of Title 18 , United States Code ,Section 2423 (a).

Count four: Trafficking

Victim one was transported from Florida to New York multiple times for Jeffrey Epstein to abuse.

Count four is transportation of a minor with intent to engage in criminal sexual activity (not simply the conspiracy listed above) in violation of New York Penal Law, Section 130.55

Count five: Perjury

Maxwell knowingly lied under oath in court. Specifically, she claimed not to know that Jeffrey Epstein had a scheme to recruit underage girls for sexual massages. Asked to list all the people under 18 that she interacted with at any of Epstein’s properties, she claimed to be unaware of any other than the plaintiff in that case, who was 17.

Count five is therefore perjury. The charge is made under Title 18, United States Code, Section 1623). In April 2016, in the Southern District of New York , when Maxwell took an oath to testify truthfully (docket number 15 Civ 7344) – but failed.

Count six: Perjury

In court in July 2016, Maxwell:

  • claimed to be unaware of the presence/existence of sex toys or devices used in sexual activities in Epstein’s Palm Beach house;
  • claimed to be unaware that he was having sexual activities with anyone herself, despite already having already identified “a blond and brunette” as being involved in three way sexual activities (with her and Epstein)
  • claimed not to have given anyone a massage including both Epstein and victim 2.

This was in July 2016, in the Southern District of New York, Mall. Maxwell knowingly made “false material declarations” even though she had taken an oath to testify truthfully in a deposition in connection with a case then pending (docket number 15, 7344),

Therefore count 6 is also for perjury under Title 18, United States Code, Section 1623. 

Final Notes

I repeat that these are the unproven ALLEGATIONS that are being made against her, and for which she will be tried. However, as noted, it is incredibly hard to disbelieve the 23 victims who spoke out in the Epstein case.

Maxwell’s testimony needs to go way beyond what’s listed here if the victims are to see justice.

There are others whose names have been given in connection with Epstein, including Weinstein, Prince Andrew, Clinton, Trump, “senior academics”, judges and more.

They will either be queueing around the block to clear their names, or wishing her as vanished as Epstein.

What is grooming?

Read the CAAGe review of ‘Filthy Rich’, a great background to the Epstein story, putting Maxwell in context.

Understanding enablers like Maxwell

If you have been groomed and would like support or to share your story, contact CAAGe

<p class="has-text-align-center has-very-light-gray-color has-vivid-cyan-blue-background-color has-text-color has-background" value="<amp-fit-text layout="fixed-height" min-font-size="6" max-font-size="72" height="80"><strong><a href="">Get involved in raising awareness of, and fighting, grooming</a></strong>Get involved in raising awareness of, and fighting, grooming

Published by Claire (claireatwaves)

Founder, Waves PR To be found as claireatwaves in most social spaces. Helping people's reputations, online and off. Passionate advocate against adult grooming and groomers at

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