Opening Statement by the Prosecution

MS. POMERANTZ: I want to tell you about a young girl named Jane. It was 1994 and Jane was spending her summer at a camp for talented young kids. Jane turned 14 years old that summer. She was sitting at a picnic table with friends when a man and a woman walked by. The man introduced himself as a donor who gave scholarships to students at this camp. The man and the woman spoke with Jane and, after discovering they all lived in Palm Beach, Florida, they asked Jane for her phone number. What Jane didn't know then was that this meeting at summer camp was the beginning of a nightmare that would last for years, that this meeting would pull Jane into a relationship with the man and the woman who were each more than double her age. What she didn't know then was that this man and woman were predators. What Jane didn't understand then or what you will learn at this trial was that this meeting was the beginning of that man and woman targeting Jane for sexual abuse that would last for years.

Jane was not their only victim. There were other young girls, teenagers who the man and woman targeted for sexual abuse. Who was that woman targeting young girls for sexual abuse? It was the defendant, Ghislaine Maxwell. The defendant took these girls on shopping trips, asked them about their lives, their schools, their families. She won their trust. She discussed sexual topics with them. She helped normalize abusive sexual conduct. She put them at ease and made them feel safe all so that they could be molested by a middle-aged man. She knew what was going to happen to those girls. The defendant walked the girls into a room where she knew that man would molest them, and there were times when she was in the room when it happened, making it all feel normal and casual. That is why we are here today, because between 1994 and 2004, the defendant sexually exploited young girls. She preyed on vulnerable young girls, manipulated them, and served them up to be sexually abused.

The defendant was trafficking kids for sex. That is what this trial is all about. Ladies and gentlemen, this opening statement is the government's opportunity to give you a roadmap of the evidence that you're going to see in this case, and I'm going to do that in two parts. First, I will tell you what I expect the evidence is going to show. Second, I'm going to talk about the different types of evidence that will prove that Ghislaine Maxwell is guilty beyond a reasonable doubt. So what will the evidence show? You're going to learn that the man and woman I just mentioned were Jeffrey Epstein and Ghislaine Maxwell. Maxwell was Epstein's best friend and right hand. Epstein was a multimillionaire connected to famous and powerful people. He lived a life of extraordinary luxury. He owned many properties, including a villa in Palm Beach, Florida, a mansion in Manhattan, a ranch in New Mexico, and an apartment in Paris.

He even owned an entire private island in the United States Virgin Islands. And he had staff who worked for him in his various homes. Epstein also owned private planes. He had pilots who worked for him full-time, flying him to his properties and other locations in the United States and internationally. The defendant got to enjoy that luxury right along with Epstein. Starting in the early 1990s, the defendant was in a personal intimate relationship with Epstein, they were a couple for many years, and when their relationship ended, they remained, in the defendant's own words, the best of friends. The defendant was Epstein's closest associate and second in command. She was involved in every detail of Epstein's life. During the ten years the defendant and Epstein committed these crimes together, the defendant was the lady of the house. She ran Epstein's various properties, hiring and firing employees.

She imposed rules, instructing employees to not speak directly with Epstein or talking with other people visiting Epstein's homes. When she took charge of those homes, the rules for staff were strict. Employees were to see nothing, hear nothing, say nothing. There was a culture of silence. That was by design, the defendant's design, because behind closed doors, the defendant and Epstein were committing heinous crimes. They were sexually abusing teenage girls. The defendant and Epstein were partners in crime. They had a playbook. First, they got access to young girls, then they gained their trust. They learned about each girl's hopes and dreams. They learned about each girl's families,

MS. POMERANTZ: often targeting the daughters of single mothers. The defendant and Epstein promised these girls the world. Some of the girls had difficult home lives and came from families that were struggling to make ends meet. The defendant and Epstein were wealthy, powerful, and well connected, and they flaunted it. They made sure everybody knew. The defendant and Epstein made young girls believe that their dreams could come true. They figured out what the girls dreamed of becoming when they grew up and they promised to help, promised to help pay for school, become actresses, models, professional musicians. They made these girls feel seen, they made them feel special, but that was a cover, a cover that enabled the defendant and Epstein to operate in plain sight. They were wealthy and influential people who used that cover to make the girls and their parents feel comfortable and safe. But what came next was anything but safe.

The next stage involved getting the girls comfortable with sexual contact involving Epstein. To do this, the defendant discussed sexual topics with the girls and then she used the same excuse over and over to get the girls to touch Epstein — massage. You will learn that the cover of massage was the primary way the defendant and Epstein lured girls into sexual abuse. The defendant massaged Epstein in front of the girls, then she encouraged the girls to massage Epstein. You see, Epstein's Palm Beach villa and his Manhattan mansion each had a room used for massage, massage rooms filled with photographs of naked females. Epstein brought girls into his massage room every single day. But what was happening inside those massage rooms was not a massage — it was sexual abuse. Calling it a massage was a rouse, a rouse designed to get young girls to touch Epstein, an excuse for Epstein to touch the girls.

And before I describe those so called massages for you, let me just say, I know this is hard to hear, but these are the facts of the case. This is what happened to these children. These are the crimes the defendant and Epstein committed. The sexual abuse started with Epstein lying facedown for so called massages, but escalated as he turned over and touched the girls. And they escalated beyond that. Epstein touched the teenage girls' vaginas with a massager device or a vibrator. He directed girls to massage him while he masturbated. He sometimes touched the girls' breasts or vaginas. He sometimes received oral sex, and he sometimes penetrated the girls' vaginas with his penis. The defendant helped Epstein find those girls. She helped him recruit girls for so called massages. She manipulated the girls, groomed them for abuse, helped the girls feel comfortable as friendliness escalated to abuse.

Sometimes she was even in the room for the massages herself, and sometimes she touched the girls' bodies. And even when she was not in the room, make no mistake, she knew exactly what Epstein was going to do to those children when she sent them to him inside the massage rooms, massage rooms inside the houses the defendant ran for over a decade. When the defendant sent a 14-year-old girl into a massage room with an adult man, she knew exactly what was going to happen. The defendant was essential to this scheme. As an adult woman, she was able to provide a cover of respectability to Epstein that lulled these girls and their families into a false sense of security. She was in on it from the start. The defendant and Epstein lured their victims with the promise of a brighter future only to sexually exploit them and forever change their lives.

And while this horrific abuse was going on behind closed doors, the defendant was jet setting in private planes and living a life of extraordinary luxury. These girls were just a means to support her lifestyle, a way for the defendant to make sure that Epstein — who demanded constant sexual gratification from young girls — remained satisfied so that the defendant could stay in the lifestyle to which she was accustomed. So what happened to Jane, the 14-year-old who met the defendant and Epstein at her summer camp in 1994? You will hear from Jane about the day she met these predators. You'll hear that after Jane returned to Florida from camp, someone from Epstein's office reached out to Jane and invited her to Epstein's house in Palm Beach for tea. Jane went to Epstein's house with her mother. Epstein explained that he liked to mentor young talented people, that he gave scholarships and

MS. POMERANTZ: that he wanted to help Jane. Jane started spending time with the defendant and Epstein at Epstein's house in Palm Beach. Jane was 14 years old. She was a kid. Epstein was in his early 40s, the defendant was in her early 30s — they were adults. They were each more than double her age. Yet, they were befriending a child. They pretended to be Jane's friend. They took her to the movies and on shopping trips. Jane spent time with the defendant and Epstein at Epstein's house in Palm Beach, often by the pool. During those visits, Epstein regularly gave Jane hundreds of dollars, knowing that her family needed the money. He also paid for voice lessons for Jane. During those visits, the defendant asked Jane about her life, but that wasn't all that happened during those visits. Within that first year, while Jane was just 14 years old, Epstein started sexually abusing Jane. He did not abuse her alone. There were times when the defendant was in the room.

She was in the room for the abuse, making it feel normal, making it feel okay that a man in his 40s was naked and touching Jane's body. There were times when the defendant undressed in front of Jane, times when the defendant was in the room when Jane undressed in front of Epstein, and she was sometimes in the room when Epstein engaged in sex acts with Jane. The sexual abuse, these horrifying massages occurred frequently. It continued for years when Jane was 14, when Jane was 15, when Jane was 16, it went on for years. And the abuse was not limited to Palm Beach, Florida. Both the defendant and Epstein encouraged Jane to travel with them, and she did. She traveled with the defendant and Epstein to New York where she stayed at Epstein's Manhattan mansion. During those trips, Epstein sexually abused her just like he did in Florida. Ladies and gentlemen, Jane was not the only one.

During the course of this trial, you will learn about multiple girls who were targeted by the defendant and Epstein for sexual abuse. You will learn about other girls who the defendant encouraged to massage Epstein, knowing that Epstein planned to engage in sex acts during those massages. For example, you will learn about a 16-year-old girl who traveled to Epstein's ranch in New Mexico and found herself alone with the defendant and Epstein. Once the girl was isolated, the defendant took steps to normalize sexual contact under the rouse of massage, preparing her to be sexually abused by Epstein. The defendant told the girl she was going to give her a massage, and once she got the girl on the massage table, the defendant started touching the girl's breasts. The girl was 16 years old. You will also learn about a 17-year-old girl the defendant spotted in a parking lot and recruited out of the blue.

You'll hear that the defendant made her driver pull over so that she could approach that 17-year-old girl to recruit her to give Epstein massages. And you will learn about the way the defendant and Epstein's sexual abuse evolved over the course of a decade. You will learn that in the 1990s, they used the cover of mentoring young girls, of promising them scholarships and opportunity, to introduce massage, inviting them on trips and transporting them across state lines, and that you will learn that they used these so called massages as a way to sexually abuse the victims. During that earlier phase, the defendant and Epstein had to find each girl individually themselves, but by the early 2000s, the defendant and Epstein found an easier way to maintain a continuous flow of girls to abuse. They were no longer finding girls through the cover of scholarships and opportunity.

Instead, they devised a pyramid scheme of abuse, a scheme that no longer required the defendant to personally find young girls for Epstein. So what did the defendant and Epstein do? They encouraged girls to bring other girls. They asked the girls if they had any young friends to bring over. And when a girl brought someone new, she was rewarded with cash, extra cash on top of the hundreds of dollars she got for giving Epstein a sexualized massage. The defendant and Epstein handed hundred dollar bills to poor teenage girls in exchange for them giving Epstein so called massages. To be clear, those girls were not professional masseuses — they were kids being sexually exploited and abused. Under this pyramid scheme of abuse, the defendant could just call girls to schedule massage appointments and hand

MS. POMERANTZ: them cash afterwards, overseeing the operation and normalizing the abuse by showing these young girls that she, an older, purportedly respectable woman, had no problem with the paid sex acts that were taking place during these so called massages. For a decade, the defendant played an essential role in this scheme. She knew exactly what she was doing. She was dangerous. She was setting young girls up to be molested by a predator. That's what we expect the evidence will show, that the defendant enticed and groomed multiple young girls to engage in sex acts with Jeffrey Epstein, that the defendant and Epstein enticed some of those girls to travel to Epstein's homes in different states, which the defendant knew would result in sexual abuse. As a result of these actions, the defendant is charged in six counts. Four of the counts charge her with working with Epstein to transport girls under the age of 17 across state lines to be sexually abused.

Two of the counts charge her with crimes for sex trafficking of minors. Sex trafficking of minors, as I expect Judge Nathan will instruct you, means recruiting or enticing a girl under the age of 18 for sex acts in exchange for money. Now, how will we prove to you that the defendant is guilty of these crimes? We're going to prove it to you in several different ways. I want to highlight just a few of those ways for you now. First, you will hear from the victims, including Jane herself. They will take that stand and describe the sexual abuse they suffered at the hands of the defendant and Epstein. They will tell you about the defendant's significant role in that sexual abuse, how the defendant helped put them at ease, how she talked about sexual topics with them, how the defendant was sometimes in the room for the sexual abuse, how the defendant sometimes touched their bodies, how the defendant encouraged some of them to travel with Epstein to his homes.

These witnesses will be testifying about some of the most painful and private experiences of their childhood, experiences they couldn't talk about for years, experiences that forever changed their lives, experiences that scarred them. You will also hear that a fund to compensate girls who Epstein abused awarded some of these witnesses millions of dollars, but it will be obvious to you at this trial that these witnesses would have paid anything for this not to have happened to them. They would pay anything to have never met the defendant and Epstein. You'll also hear from people who knew some of the victims, who knew them not as the adults that you will see during the course of this trial, but as the kids they were when the abuse happened. You'll hear from relatives from some of the victims.

They will tell you about the victims spending time with the defendant and Epstein, traveling to meet the defendant and Epstein, and receiving phone calls from the defendant, all when those victims were between the ages of 14 and 17. You'll also hear from some of Epstein's staff. You'll hear from the pilots who flew Epstein and the defendant and some of the victims in Epstein's private planes. You'll also hear from some of the employees who worked at Epstein's Palm Beach residence. They will tell you what it was like to work for Epstein and the defendant. The rules the defendant imposed on staff, rules designed by the defendant to ensure a culture of silence. You'll also hear from law enforcement witnesses. You'll hear from law enforcement witnesses who participated in a search of Epstein's Palm Beach home in 2005 and a search of Epstein's New York mansion in 2019. You'll see photographs from those searches.

You will see that Epstein lived in mansions filled with photographs of naked females, and you will learn that he had a massage room in each of those houses that was decorated with more nude photographs. You'll also see evidence recovered from the searches of Epstein's Palm Beach and New York residences, backing up the victims' accounts, like massage tables, a school girl outfit, and nude photographs. Finally, you'll also see a variety of other types of records that further back up the victims' testimony. To name just three examples, you'll see flight logs of Epstein's private planes, logs that include the names of some of the defendant and Epstein's victims, confirming that the defendant and Epstein flew on his planes with minor girls. You'll see FedEx records confirming that Epstein sent a gift to one victim