Text extracted via OCR from the original document. May contain errors from the scanning process.
years and would be caused to engage in a commercial sex act as defined in 18 PROT100. §
159 1(cX1):
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
51
12/6/2004 - 6/2/2005 Jane Doe 43
JEFFREY EPSTEIN
52
4/25/2004 - 6/29/2005 Jane Doe #4
JEFFREY EPSTED1
53
11/14/2004 - 3/29/2005 Jane Doe #5
54
7/15/2004 - 12/29/2004 Jane Doe #6
JEFFREY EPSTELN
55
7/22/2004 - 1/31/2005 Jane Doe #7
JEFFREY EPSTEEN
56
2/13/2005 - 10/3/2005 Jane Doe #8
57
401/-21194....______Iane-De 40 _.)44__
58
8/21/2004 - 5/27/2005 Jane Doe #13
All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2.
33
PROT0
2/
I
COUNT 59
(Transportation of an Individual for Criminal Sexual Activity: 18 PROT101. § 2421)
24.
Paragraphs I through 6 ofthis Indictment are re-alleged and incorporated by reference
as though fully set forth herein.
25.
From at least as early as July 2004, through in or about October 2005, the exact dates
being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
elsewhere, the defendant,
JEFFREY EPSTEIN, did knowingly transport an individual, that is, in interstate commerce, with the intent that such individual engage in any sexual activity for which any person can be charged with
a criminal offense; in violation of Title 18, United States Code, Sections 2421 and 2.
COUNT 60 (Attempted Solicitation of a Minor: 18 PROT102. § 2422(b))
26.
Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference
27.
From on or about March 30, 2005, through on or about April 1, 2005, in Palm Beach
County, in the Southern District of Florida, and elsewhere, the defendants,
JEFFREY EPSTEIN and did knowingly and intentionally by means of a facility of interstate commerce, that is, by telephone,
attempt to persuade, induce, and entice a person who had not attained the age of 18 years, that is Jane
Doe #2, to engage in prostitution and in a sexual activity for which any person can be charged with
a criminal offense; in violation of Title 18, United States Code, Section 2422(b).
FORFEITURE
34
PROT1
c
A TRUE BILL
FOREPERSON
35
PROT2
r.
JANE DOE a
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE engage in prostitution pCI.
engage in prostitution O.A. 95 2/6/05
EPSTEIN Conspiracy to entice a minor to engage in prostitution
O.A. 96 2/6/05
EPSTEIN IlIn O.A. 97 2/6/05
EPSTEIN O.A. 117 3/30/05 O.A. 120 3/31/05 O.A. 122
3/31/05
EPSTEIN O.A. 123 4/1/05
EPSTEIN Ct 5 . .
3/7/04- 3/11/04
EPSTEIN Enticement of a minor to engage in prostitution of 4.,
t
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JANE Dm #1
PROT3
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COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE O.A. 95 2/6/05
EPSTEIN O.A. 96 2/6/05
EPSTEIN O.A. 97 2/6/05
EPSTEIN O.A. 122 3/31/05
EPSTEIN
MIE
O.A. 123 4/1/05
EPSTEIN Conspiracy to. entice a minor to engage in prostitution
Ct 6 2/5/05 -
EPSTEIN Enticement of a minor to engage in 2/6/05
la
prostitution Ct. 43 3/31/05
STEWI - D
_r
vvttive431t:?..J.i.l.
Travel to engage in illicit sexual conduct a c.a \.....14xtv'A1 7-1 13
Ct 60 3/30/05 -
EPSTEIN Attempted enticement of a minor to 4/1/05 engage in prostitution
Qv..be 0. "...t tat cr., T.A.Ates.
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COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE O.A. 59 12/6/04 O.A. 60 12/12/04 O.A. 64 12/14/04
O.A. 71 12/20/04 O.A. 79 1/6/05 O.A. 83 1/14/05 O.A. 94
2/4/05 O.A. 100 2/10/05 O.A. 102 2/21/05 O.A. 104 2/24/05
O.A. 112 3/17/05 O.A. 118 3/30/05 Conspiracy to entice a minor to
O.A. 125 4/8/05 O.A. 129 4/26/05 O.A. 132 5/19/05 -0/ let
PAGE 1 OF 3
JANE DOE #3
PROT5
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• • ♦I I
COUNT/O A.
DATE
DEFENDANT(S)
CHARGE
3
12/6/04 - 6/29/05
EPSTEIN lir Enticement of a minor to engage in prostitution
Ct. 32 12/13/04 CLEPS.T_ETN -2,,,• C k -...,-A"
HYPERION Go.
• G't Travel to engage in illicit sexual conduct sse.
Ct. 35 1/6/05 -EPST 7 7)
HYPERION C, Travel to engage ' illicit sexual conduct
Ct. 36 1/14/05
EPSTEIO
rB
Travel to engage in illicit sexual conduct Ct. 37 2/3/05
CEPia.
JEGE
a
Ct. 38 2/10/05 .T.,.f,t_ir -aatititgim-G',R Ct. 39
2/21/05 • II
IW
-ES1 Il7T Ct. 40 2/24/05 'EPSTEIN: -.)
GE e Ct. 42 3/18/05 ,..,..EPSTEET - ,
JEGE
(3
Ct. 43 3/31/05 .PSTE1N
JEGE e )
PAGE 2 OF 3
JANE DOE #3 szes-ch_
PROT6
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE Ct. 44 4/8/05
CRPSTre
IIIIIP
HYPERION Cr;
Ct. 45 4/27/05 Minglipil0
CEPS TE INT:)
HYPERION Cr- Ct. 46 5/6/05 ($15Y-TETT-
)
Cr
HYPERION 1/2."--. I -.-,,-, Ct. 47 5/19/05 r
PRS-1:11147-D
HYPERION G- Ct. 51 12/6/04 - 6/2/05
EPSTEIN
Recruiting, enticing, providing, or obtaining a person, knowing that she
is a minor and will be caused to engage in a commercial sex act
Vs CAs \x,vot,sv\ \.o \( g ps Are..
(_ sc,
PAGE 3 OF 3 r4-<, -4-o cr-esci ste-c0A thte.ar.
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JANE DOE #3
PROT7
R - tvcr..,' a\ t) C-5-) NAL
k
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4.0 C ce'eccirt•i i .
. 1
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1
JANE DOE #4 (Favth P.)
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE O.A. 4 4/25/04
i
O.A. 6 5/3/04 O.A. 8 5/14/04 O.A. 9 5/20/04 O.A. 11
6/3/04 • O.A. 14 6/11/04 O.A. 15 6/20/04 O.A. 19 7/10/04
O.A. 24 7/18/04 O.A. 25 7/22/04 O.A. 29 7/22/04 O.A. 30
8/4/04 O.A. 37 8/25/04 O.A. 43 10/3/04 O.A. 47 10/30/04
PAGE 1 OF 3
JANE DOE #4
PROT8
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PAGE 2 OF 3
JANE DOE #4 11-Q- 490{ 2
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ALIZ.
S- 12 X (AA
ccy\ric., v t a s cilua :.t. ;
d Caj Lief
Cak
3E a-
c
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE • O.A. 48 11/4/04 O.A. 77 1/4/05 O.A. 87 1/22/05
O.A. 101 2/14/05 ' Conspiracy to entice a minor to engage in prostitution
O.A. 106 2/24/05 O.A. 114 3/18/05 Conspiracy to entice a minor to
Nouvrne icae4e,
ni
s
O.A. 116 3/29/05 O.A. 127 4/11/05
IN
'Ct. 8 4/25/04 -
EPSTEIN 6/29/05 prostitution Ct. 17 5/21/04
.1---> Ct. 18 6/4/04
CEPSTE1N2 •
BRION"- Ct. 19 6/20/04 ,...:E lEIN J E"
SA.- ecuic tee-O,c\ ca -LOCC cin cio. a.
PROT9
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COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE • Ct. 22 7/22/04 . PS. E
-
• -)
JEGE
13
Ct. 23 8/6/04
)
.• EPSTEIN
JEGE -c3.
Ct. 28 11/5/04 - .EPSTEIN 7)
HYPERION Ct. 35 1/6/05 ,
EPSTEIN - -5
a
e,
HYPERION LT' Travel to engage in illicit sexual conduct c"t'
Ct. 40 2/24/05
-
t
EPSTEIN
JE E
)
0.43 3/31/05 • WiE
JEGE Ct. 52
9
4/25/09- 6/29/05
EPSTEIN
r
it,J, day Sa -4.
°Y
tatAiNeCn 3-E o{ Ley
C)
4-tzta.v-e-
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PAGE 3 OF 3
JANE DOE #4
PROT10
IC•Ct. .1• 'lc' , c) Lait•-•
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JANE DOE #5 i
COUNT/O.A. DATE
DEFENDANT(S)
CHARGE O.A. 53 / 11/17/04 Conspiracy to entice a minor to • engage in prostitution
O.A. 58 / 12/5/04 O.A. 61 I 12/13/04 O.A. 65 12/14/04
O.A. 69 / 12/18/04 O.A. 72 , 12/23/04
EPSTEIN O.A. 74 ser 1/1/05 O.A. 81 we" 1/8/05 O.A. 82 y
1/9/05
M
O.A. 88 Coq len P 1/26/05 ,My.
72
l'itk.di
FAD
O.A. 91
toe
2/1/05 O.A. 98 %,.. 2/10/05 O.A. 107 ""e'' 2/25/05
O.A. 108 , 3/1/05
IM
O.A. 111 e t 3/16/05
Conspiracy to entice a minor to engage in prostitution kVA_ fl u1 yi p
peas c- 6,t
CONFIDENTIA DRANO JURY MAT' AL g•-•EAT c,k.
we:kr ra.A.4- "tv\\;
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VA- esca-cal7 art,
PROT11
DEFENDANT(S)
CHARGE O.A. 115 -I' 3/21/05 Ct. 9 11/14/04 - 3/29/05
EPSTEIN
r
Ct. 30 11/18/04 c
t
k
-EPSTEIN - ')
.")
Ct. 31
M
t
12/3/04 c'Etstbrip Travel to engage in illicit sexual
.ii+ conduct ., il Ct. 32 12/13/04,..., -EPSTEIN' • •
MON
Ct. 34 1/1/05 "I;PST 41,11TERION Ct. 37 2/3/05 - El)STE ----7
.3
Ct. 38 2/10/05
C..
c..'..1
i
H3'
HYERIG Ct. 39 2/21/05 :-IIIMIES 'EPSTEIN . 'N
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PAGE 2 OF 3
06
11 o 5\ \votT-Qi (bcc-vg-te y tic." , ILA ( t" c
9,
JANE DOE #5
GLIncr , L-
PROT12
DEFENDANT(S)
CHARGE Ct. 41 3/4/05 , EPSTEIN T'
c
iri
`ma
c
Ct. 42 Ell • 3/18/05 __ _EPSTEIN.. ..' Travel to engage in illicit sexual / conduct
Ct. 53 11/14/04 -
EPSTEIN Recruiting, enticing, providing, or 3/29/05
1.
obtaining a person, knowing that she is a minor and will be caused to engage in a commercial sex act
C. S.'"
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PAGE 3 OF 3
JANE DOE #5
PROT13
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JANE DOE #i6
4 -
Ar:
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE O.A. 21 , 7/15/04 Conspiracy to entice a minor to .
O.A. 26 J 7/22/04 O.A. 34 , 8/19/04
i
O.A. 38 8/25/04
i
O.A. 49 ,/ 11/7/04 O.A. 51 ./ 11/10/04 O.A. 52 11/17/04
O.A. 55 .,, 12/1/04 O.A. 57 no CPA\ infl e 12/4/04
O.A. 62 ,,,,, 12/13/04 O.A. 68 4.,.-- 12/17/04 O.A. 73 ..,,,,-
12/29/04 -Ct. 101 7/15/04 - 12/29/04
EPSTEIN Ct. 21
MI
7/16/04 - 7 1-S - 'IN- ' -1444PEITION G evue,A, nmasov (ice(
Ce_cokitirezi
PAGE 1 OF 3 - hem) •OcakS QOC CJ GoG/ic rol,c4.4
IS,,a
Se.
INA ?kik e) Cie O.& it.(0 n
r,
JANE DOE it6 a- NV &Sat c -cor
PROT14
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE Ct. 22 7/22/04 c-E -FlicrE B Ct. 23 8/6/04
(
cal
•JEGE II Ct. 24 8/19/04
STE
- 6-'it,n;utvkx ..o.e.
Ct. 25 8/25/04 .-EPSTEPT) -JEGEl, Ct. 29 11/10/04 .S TEST ,
414cRERION G Ct. 30 11/18/04 , tisit --, Ct. 31
I
conduct 12/3/04 "EPSTE - ..)
YE
Ct. 32
W■
12/13/04
CEPS a) liligN
G-
Ct. 33
MI■
12/17/04 (Egfat.
-HYPERION G-
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at jr-.... , Te...\.ep Loyck c_ Co A. Irekcir o 6 c}w-ce v., se\ --Y0-ze Ls
• PAGE 2 OF 3
JANE DOE #6
i
, i, A 0
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i'
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Li-. /v a t AILL Ci..0.
PROT15
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE Ct. 54 7/15/04 - 12/29/04 mil
54
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t
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PAGE 3 OF 3 kiL\m-u • ...s•c"• c..J SS)
JANE DOE #6
PROT16
nn YIVit c.):\ conks u.A...a);\ Ic.;cA-PL.r 41.71s 1••_)43/4>
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JANEDOEIJL.M1
7
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE O.A. 23
1--
7/16/04 O.A. 27 7/22/04 O.A. 32 ./ 8/17/04 O.A. 39
iv
8/25/04 O.A. 41 .." 9/16/04 O.A. 44 / 1 1013/04 O.A. 45
10/26/04 O.A. 57 ..../ fflp 12/4/04 O.A. 66 1/40,,..- 12/16/04
O.A. 75 .../ 1/1/05 s v.. r 3 vs dr Itee s '-'" c C.
O.A. 85 ......-- 1/14/05 O.A. 89 '-' -1/27/05 A (2.-4:BZ
M
O.A. 90 ,,,e• 1/28/05
O9
4-
2/1/05
Tr'
4
re_ (he (1/4) s say.. cp.) c.(is te. (Amy au/In.% it -Q.
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44- (A.
RAGE 1 OF 2 1/1^E.
I
veer v
JANE DOE #7
MC SOS •••C -1)(/ • 4:11.
PROT17
DEFENDANT(S)
CHARGE
s
.Ct. 11 ) 7/22/04 - 1/31/05
EPSTEIN Ct. 21
L_
7/16/04 ( - EPSTEIN. --!
H;TERION• Ct. 22 7/22/04
t
'INN
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JEGE Ct. 24 8/19/04 C-
PPS.TgIN_..
JE
CIGHLIW Ct. 26 9/16/04 C.
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-
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JEGE Ct. 27 10/29/01L 1111,
EISTEnst-- )
-')
Ct. 33 12/17/04 Eniti?
-
III eiwn4ez r Ct. 34 1/1/05 1PSTE Ct. 55 7/22/04 -
1/31/05
EPSTEIN rec or&s, brakc_pstice.
PAGE 2 OF 2 ov,..c •
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PROT18
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4
JANE DOE #8
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE O.A. 110 3/7/05
i
Conspiracy to entice a minor to 1 engage in prostitution
O.A. 1 -'74/2/05
M
- i 44 O.A. 128 ...., 4/11/05 Conspiracy to entice a minor to 4,4 engage in prostitution
- . I 4"" O.A. 133 ...oec... /S03).
sil 17/04
v-
Sokot0t0,..
O.A. 136 %., 6/12/05
v
Conspiracy to entice a minor to tj .
L1 6•04.,0 O.A. 13 6/20/05 Conspiracy to entice a minor to 4, engage in prostitution
-z.4)...
d
O.A. 139 ......•-•- 6/30/05
ve
O.A. 141 . 7/2/05
i
Conspiracy to entice a minor to :114" engage in prostitution
2.
O.A. 142 ....,...• 7/22/05
i.
S;nv fi.s.
O.A. 145 ..----- 8/18/05 Conspiracy to entice a minor to
i
50- 0.6.
OA 1.i 8/19/05
M
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\pity ".
1
O.A. 147
IM-
8/21/05 3.1..81., O.A. lir
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5
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9/3/05 9/8/05
0 I
S.... kt A
ve
I b.. atkt" O.A. 152 ., 9/18/05
.1
Conspiracy to entice a minor to engage in prostitution sc--.44..
PAGE 1 OF 2
JANE DoE #8
PROT19
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COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
OA. 154 9/29/05
Conspiracy to entice a minor to engage in prostitution sue.,
OA. 156 a./ 10/3/05 Conspiracy to entice a minor to engage in prostitution tt.E
2/13/05 - 10/3/05 prostitution Ct. 47
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5/19/05
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Ct. 56 2/13/05 - Recruiting, enticing, providing, or
10/3/05 obtaining a person, knowing that she is a minor and will be caused to
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JURY MATERIAL
PAGE 2 OF 2
PROT20
JANE DOE #9
DEFENDANT(S)
CHARGE Ct. 13 2/05 -
EPSTEIN 4/05 prostitution
JANE DOES #10 and #11 MEI
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE O.A. 70 12/18/04 Ct. 14 (Jane Doe #11 only)
12/18/04
EPSTEIN
PAGE 1 OF I
JANE DOES #9-11
PROT21
JANE DOE #12
COUNT/O.A.
DATE
DEFENDANT(S)
CHARGE
OA. 18 7/4/04
OA. 20 7/10/04 Ct. 8 7/4/04 - 7/19/04
EPSTEIN illEnticement of a minor to engage in prostitution
Ct. 20 7/4/04
EPSTEIN pill
w
Ct. 21 7/16/04
EPSTEIN
LL
EN
Ct. 57 7/4/04- 7/19/04
EPSTEIN
PAGE I OF I
JANE DOE #12
PROT22
)
JANE
DOE #13
COUNT/O.A.
CHARGE : O.A. 35 8/21/04 O.A. 78 1/4/05 Ct. 16 8/21/04 -
5/27/05 prostitution Ct. 26 9/16/04
EPSTEIN
P
conduct Ct. 27 10/29/04
EPSTEIN
YPERION Ct. 34 1/1/05
EPSTEIN
MP
conduct Ct. 35 1/6/05
EPSTEIN
WON
Ct. 40 2/24/05
EPSTEIN
M
conduct
ON
Ct. 58 8/21/04 - . EPSTEIN Recruiting, enticing, providing, or
.5/27/05 obtaining a person, knowing that she is a minor and will be caused to
engage in a commercial sex act
CONFIDENTIAL Gizmo JURY MATERIAL
PAGE 1 OF 1
JANE DoE #13
PROT23
C1q
--I
SOUTHERN DISTRICT OF FLORID4'J I (40 - l Case No:
Tf ct,a. zuz (4.) 5e.k.
18 PROT103. § 18 PROT104. §
371
2423(e) (312,0 isgou) 18 PROT105. § 18 PROT106. § 2423(d)
1591(a)(2)
(j) 2,1( i4f6 14 18 PROT107. § 2422(b) 18 PROT108. § 2423(b)
18 PROT109. § 1591(a)(1)
UNITED STATES OF AMERICA, vs.
JEFFREY EPSTEIN, a/k/a Hilteltateettft*IrINC., Defendants.
/ •
INDICTMENT The Grand Jury charges that:
BACKGROUND At all times relevant to this Indictment:
1.
Defendant JEFFREY EPSTEIN employed defendants ailda and among other things, services as personal assistants..
to perform,
PROT24
2.
Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way,
Palm Beach, Florida, in the Southern District of Florida.
3.
Defendant JEFFREY EPSTEIN was the principal owner of9Xfi
EJEGE,
INC., a Delaware corporation. JEGE, INC.'s sole business activities related to the operation
and ownership of a Boeing 727-31 aircraft bearing tail number N9081E.
4.
Defendant JEFFREY EPSTEIN served as president, sole director, and sole
shareholder of Defendant JEGE, INC., and had the power to direct all of its operations.
5.
Defendant JEFFREY EPSTEIN was a principal owner of RS
HYPERION AIR, INC., a Delaware corporation. HYPERION AIR, INC.'s sole business
activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing
tail number N909JE.
6.
Defendant JEFFREY EPSTEIN served as president, sole director, and sole
shareholder of Defendant HYPERION AIR, INC., and had the power to direct all of its
operations.
COUNT 1 (Conspiracy: 18 PROT110. § 371)
7.
Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
8.
From at least as early as March 2004, the exact date being unknown to the
Grand Jury, through in or about October 2005, in Palm Beach County, in the Southern
District of Florida, and elsewhere, the defendants,
2
PROT25
JEFFREY EPSTEIN, did knowingly and willfully combine, conspire, confederate and agree with each other and
with others known and unknown to commit an offense against the United States, that is, to
use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or
entice individuals who had not attained the age of 18 years to engage in prostitution or any
sexual activity for which any person can be charged with a criminal offense, in violation of
Title 18, United States Code, Section 2422(b).
Purpose and Object of the Conspiracy
9.
It was the purpose and object of the conspiracy to procure females under the
age of 18 to travel to 358 El Brillo Way, Palm Beach, Florida so that JEFFREY EPSTEIN
could, in exchange for money, engage in lewd conduct with those minor females in order to
satisfy JEFFREY EPSTEIN's prurient interests.
Manner and Means
10.
The manner and means by which the defendants and other participants sought
to accomplish the purpose and object of the conspiracy included the following:
(a)
It was part of the conspiracy that Defendants alk al=IMM and3 would contact
PROT26
minor females via the use of cellular and other telephones to arrange appointments for minor
females to travel to 358 El Brillo Way to allow Defendant JEFFREY EPSTEIN to engage
in lewd conduct with them.
(b)
It was further a part of the conspiracy that Defendants JEFFREY
EPSTEIN, M=1, a/k/a and would make payments to, or cause payments to be made to, minor females
in exchange for engaging in lewd conduct.
(c) anda " " and
EPSTEIN, would ask females to recruit other minor females to engage in lewd conduct
with Defendant JEFFREY EPSTEIN.
(d) anda " ," and= would make payments to, or cause payments to be made to, the recruiters
for bringing additional minor females to 358 El Brillo Way to engage in lewd conduct with
Defendant JEFFREY EPSTEIN.
EPSTEIN,
4
PROT27
Overt
11.
In furtherance of this conspiracy and to effect the objects thereof, there was
committed by at least one of the co-conspirators herein, at least one of the following overt
acts, among others in the Southern District of Florida:
(1)
On March 11, 2004, Defendants JEFFREY EPSTEIN, IEM and traveled from Teterboro, New Jersey, to
Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant
(2)
On or about March 12, 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #1 to travel to 35
llo Way, Palm Beach c.cia 'cia 6C- Florida.
(3)
On or about March 12, 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #1.
(4)
On April 25, 2004, Defendant MI caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(5)
On May 1, 2004, Defendants
EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida
aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
5
PROT28
(6)
On May 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(7)
On May 14, 2004, Defendants EPSTEIN, and traveled from Canada to Palm Beach County, Florida aboard the
Boeing 727.aircraft owned by Defendant JEGE, INC.
(8)
On May 14, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(9)
On May 20, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(10) On May 21, 2004, Defendants EPSTEIN an traveled
from Teterboro; New Jersey to Palm Beach County, Florida aboard the Gulfstream
aircraft owned by Defendant HYPERION AIR, INC.
(11)
On June 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(12) On June 4, 2004, Defendants EPSTEIN and traveled
from New Haven, Connecticut to Palm Beach County, Florida aboard the Gulfstream
6
PROT29
(13) On June 11, 2004, Defendants EPSTEIN andEM traveled from
Chicago, Illinois to Palm Beach County, Florida aboard the Gulfstream aircraft owned
by Defendant HYPERION AIR, INC.
(14)
On June 11, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(15)
On June 20, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(16) On June 20, 2004, Defendants EPSTEIN and traveled
from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727
aircraft owned by Defendant JEGE, INC.
(17) On. July 4, 2004, Defendants
EPSTEIN, MI and traveled from Aspen, Colorado to Palm Beach County, Florida
aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
(18)
On July 4, 2004, Defendantcaused one or more telephone calls to be made to a telephone used by Jane Doe #12.
(19)
On July 10, 2004, Defendantcalls to be made to a telephone used by Jane Doe #4.
(20)
On July 10, 2004, Defendantcaused one or more telephone caused one or more telephone
calls to be made to a telephone used by Jane Doe #12.
7
PROT30
(21)
On July 15, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6.
(22) On July 16, 2004, Defendants EPSTEIN, MI and traveled from Teterboro, New Jersey to Palm Beach County, Florida
(23)
On July 16, 2004, Defendant caused Jane Doe # 6 to make one or more telephone calls to a telephone used by Jane Doe # 7.
(24)
On July 18, 2004, Defendantcalls to be made to a telephone used by Jane Doe #4.
(25) On July 22, 2004, Defendant calls to be made to a telephone used by Jane Doe #4.
(26) On July 22, 2004, Defendant made to a telephone used by Jane Doe #6.
(27) On July 22, 2004, Defendant calls to be made to a telephone used by Jane Doe #7.
(28) On July 22, 2004, Defendants EPSTEIN, caused one or more telephone
caused one or more telephone caused a telephone call to be caused one or more telephone
and traveled from the U.S. Virgin Islands to Palm Beach County, Florida
8
PROT31
(29)
On July 22, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe
(30)
On August 4, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(31)
On August 6, 2004, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft
owned by Defendant JEGE, INC.
(32)
On August 17, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(33) On August 19, 2004, Defendants EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing
727 aircraft owned by Defendant JEGE, INC.
(34)
On August 19, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6.
(35)
On August 21, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe # 13.
(36)
On August 25, 2004, Defendants EPSTEIN, and traveled from Ecuador to Palm Beach County, Florida aboard the
Boeing 727 aircraft owned by Defendant JEGE, INC.
9
PROT32
(37) • On August 25, 2004, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(38)
On August 25, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6.
(39) On 'August 25, 2004, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(40) On September 16, 2004, Defendants EPSTEIN, and traveled fromNew York, New York to Palm Beach County, Florida
aboard the Boeing 727 aircraft owned by Defendant, JEGE, INC.
(41)
On September 16, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(42)
On October 2, 2004, Defendants EPSTEIN, S and traveled from the U.S. Virgin Islands to Palm Beach County, Florida
(43)
On October 3, 2004, Defendan caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(44)
On October 3, 2004, Defendanta caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
10
PROT33
.(45)
On October 26, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(46) On October 29, 2004, Defendants EPSTEIN, S and traveled from Teterboro, New Jersey to Palm Beach County, Florida
aboard the Gulfstream aircraft owned by Defendant, HYPERION, AIR, INC. .
(47)
On October 30, 2004, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(48)
On November 4, 2004, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(49) .On November 7, 2004, Defendants caused a telephone call to be made to a telephone used by Jane Doe #6.
(50) On November 10, 2004, Defendants EPSTEIN and traveled
from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream
(51) On November 10, 2004, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #6.
(52) On November 17, 2004, Defendant caused a telephone call
to be made to a telephone used by Jane Doe #6.
11
PROT34
(53) On or about November 17, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #5.
(54)
On or about November 18, 2004, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach
County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION
AIR, INC.
(55) On December 1, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6.
(56) On or about December 3, 2004, Defendants EPSTEIN, =.
and traveled from New York, New York to Palm Beach County, Florida aboard the
(57)
On December 4, 2004, D efendantl l provided a written message
to Defendant EPSTEIN regarding Jane Doe #6 and Jane Doe #7.
(58)
On or about December 5, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(59) On or about December 6, 2004, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
(60)
On or about December 12, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
12
PROT35
(61)
On or about December 13, 2004, Defendant more telephone calls to be made to a telephone used by Jane Doe #5.
(62) On December 13, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6.
(63) On or about December 13, 2004, Defendant EPSTEIN traveled from the
U.S. Virgin Islands to Palm Beach County, Florida, aboard the Gulfstream aircraft
owned by Defendant HYPERION AIR, INC.
(64) On or about December 14, 2004, Defendant more telephone calls to Jane Doe #3.
(65) On or about December 14, 2004, Defendant more telephone calls to be made.to a telephone used by Jane Doe #5.
(66) On December 16, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(67) On or about. December 17, 2004, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida
(68) On December 17, 2004, Defendant caused a telephone call
13
caused one or made one or caused one or
PROT36
(69)
On or about December 18, 2004, Defendants caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(70) On or about December 18, 2004, Defendants caused Jane Doe
#10 to make one or more telephone calls to a telephone used by Jane Doe #.11.
(71)
On or about December 20, 2004, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
(72)
On or about December 23, 2004, Defendant EPSTEIN caused a Westem
Union wire transfer order to be sent to Jane Doe #5.
(73) On December 29, 2004, Defendant caused a telephone call
(74)
On or about January 1, 2005, Defendants caused a telephone call to be made to a telephone used by Jane Doe #5.
(75)
On January 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(76)
On or about January 1, 2005, Defendants EPSTEIN, S and traveled from Anguilla, British West Indies to Palm Beach County,
Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
(77)
On January 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
14
PROT37
(78)
On January 4, 2005, Defendant=. caused one or more telephone calls to be made to a telephone used by Jane Doe #13.
(79)
On or about January 6, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
(80)
On or about January 6, 2005, Defendant EPSTEIN traveled from
Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft
(81)
On or about January 8, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(82)
On or about January 9, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(83)
On or about January 14, 2005, DefendantIMI made one or more telephone calls to Jane Doe #3.
(84)
On or about January 14, 2005, Defendants EPSTEIN,MIIM and traveled from the U.S. Virgin Islands to Palm Beach County,
Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
(85)
On January 14, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
15
PROT38
(86)
On or about January 19, 2005, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County,
Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
(87)
On January 22, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(88)
On or about January 26, 2005, Defendants reviewed a telephone message from Jane Doe #5.
(89)
On January 27, 2005, Defendant= caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(90)
On January 28, 2005; Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(91)
On or about February 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(92)
On February 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(93)
On or about February 3, 2005, Defendants EPSTEIN, a and traveled from Columbus, Ohio, to Palm Beach County, Florida,
(94)
On or about February 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
16
PROT39
(95) On or about February 6, 2005, EPSTEIN and
cc.
ic.
40fr• 'U ; 1.`'`j -5 caused Jane
Doe #1 to make one or more telephone calls to Jane Doe #2. st,,Se
tt
(96) On or about February 6, 2005, EPSTEIN and caused Jane
Doe #1 to transport Jane Doe #2 to 358 El Brillo Way, Palm Beach, Florida. mo
4
' 4
(97)
On or about February 6, 2005, EPSTEIN made a payment of $300 to
Jane Doe #2 and a payment of $200 to Jane Doe #1.
(98) On or about February 10, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(99) On or about February 10, 2005, Defendants EPSTEIN,
in
and traveled from New York, New York to Palm Beach
County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
(100) On or about February 10, 2005, Defendant caused one or
(101) On February 14, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(102) On or about February 21, 2005, Defendant caused one or
(103) On or about February 21, 2005, Defendants EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County,
Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
17
PROT40
(104) On or about February 24, 2005, Defendant caused one or
(105) On or about February 24, 2005, Defendants EPSTEIN, =.
and traveled from Teterboro, New Jersey to Palm Beach County,
Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
(106) On February 24, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(107) On or about February 25, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(108) On or about March 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(109) On or about March 4, 2005, Defendants EPSTEIN,
M
I
and traveled from New York, New York to Palm Beach County, Florida
(110) On March 7, 2005, Defendant - calls to be made to a telephone used by Jane Doe #8.
(111) On or about March 16, 2005, Defendant telephone calls to be made to a telephone used by Jane Doe #5.
(112) On or about March 17, 2007, Defendant telephone calls to be made to a telephone used by Jane Doe #3.
18
caused one or more telephone caused one or more caused one or more
PROT41
(113) On or about March 18, 2005, Defendant EPSTEIN traveled from New
York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft
(114) On March 18, 2005, Defendant prepared a written message
to Defendant EPSTEIN regarding Jane Doe #4.
(115) On or about March 21, 2005, Defendants caused one or more
(116) On March 29, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(117) On or about March 30, 2005, caused one or more calls to be made to a telephone used by Jane Doe #1.
(118) On or about March 30, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
(119) On or about March 31, 2005, Defendant EPSTEIN traveled from New
York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft
(120) On or about March 31, 2005, caused one or more calls to be made to a telephone used by Jane Doe #1.
(121) On or about March 31, 2005, EPSTEIN traveled from New York, New
York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by
Defendant JEGE, INC.
19
PROT42
(122) On or about March 31, 2005, EPSTEIN andMicaused Jane Doe
#1 to make a call to a telephone used by Jane Doe #2.
(123) On or about April 1, 2005, EPSTEIN and caused Jane Doe
#1 to make one or more calls to a telephone used by Jane Doe #2.
(124) On April 2, 2005, Defendant= caused one or more telephone calls
to be made to a telephone used by Jane Doe #8.
(125) On or about April 8, 2005, Defendant caused one or more
(126) On or about April 8, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County,
(127) On April 11, 2005, Defendant= caused one or more telephone calls
to be made to a telephone used by Jane Doe #4.
(128) On April 11, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(129) On or about April 26, 2005, Defendant caused one or more
(130) On or about April 27, 2005, Defendants EPSTEIN and =I traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the
Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
20
PROT43
(131) On or about May 6, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County,
(132) On or about May 19, 2005, Defendant caused one or more
(133) On May 19, 2005, Defendant caused one or more telephone
(134) On or about May 19, 2005, Defendants EP STEIN,IM ana traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the
Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
(135) On June 8, 2005, Defendants EPSTE1N,I I and traveled
from New York, New York to Palm Beach County, Florida aboard the Boeing 727
aircraft owned by Defendant, JEGE, INC.
(136) On June 12, 2005, Defendant caused one or more telephone
• calls to be made to a telephone used by Jane Doe #8.
(137) On June 18, 2005, Defendants EPSTEIN andEM traveled from
Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft
(138) On June 20, 2005, Defendant caused one or more telephone
21
PROT44
(139) On June 30, 2005, Defendant =.
caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(140) On June 30, 2005, Defendants EPSTEIN, la traveled from
(141) On July 2, 2005, Defendant caused one or more telephone
O42) On July 22, 2005, Defendant caused one or more telephone
(143) On July 22, 2005, Defendants EPSTEIN, I= traveled from
(144) On August 18, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard
the Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
(145) On August 18, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(146) On August 19, 2005, Defendant
caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(147) On August 21, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
22
PROT45
(148) On September 3, 2005, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft
(149) On September 3, 2005, Defendant caused one or more telephone
(150) On September 8, 2005, Defendant received a telephone call from
Jane Doe #8.
(151) On September 9, 2005, Defendants EPSTEIN, =NM, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard
(152) On September 18, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(153) On September 18, 2005, Defendants EPSTEIN, ME and= traveled from Westchester County, New York to Palm Beach County, Florida aboard
(154) On September 29, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(155) On September 29, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida
23
PROT46
(156) On October 3, 2005, Defendant caused one or more telephone
All in violation of Title 18, United States Code, Sections 371 and 2.
COUNT 2 (Conspiracy to Travel: 18 PROT111. § 2423(e))
12.
Paragraphs 1 through 6 of this indictment are re-alleged and incorporated by
• reference as fully set for the herein.
13.
From at least as early as March 2004 through in or around October 2005; the
exact dates being unknown to the Grand Jury, the defendants,
JEFFREY EPSTEIN, crop
.1:14/PERieN-24%.111C., did knowingly and willfully conspire with each other and with others known and unknown
to travel in interstate commerce far the purpose of engaging in illicit sexual conduct, as
defined in 18 PROT112. § 2423(1), with another person, in violation of Title 18, United States
• Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e).
COUNT 3
(Facilitation of Unlawful Travel of Another: 18 PROT113. § 2423(d))
14.
24
PROT47
:IS.
From at least as early as in or about March 2004 through in or about October
;20Q5y the exact dates being unknown to the Grand Jury, in Palm Beach County, in the
Southern District of Florida, and elsewhere, the defendant, did, for the purpose of commercial advantage or private financial gain, arrange or facilitate
the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was
traveling in interstate commerce for the purHose of engaging in illicit sexual conduct, as
defined in 18 PROT114. § 2423(O; in violation of Title 18, United States Code, Section 2423(d).
COUNT4 (Sex Trafficking: 18 PROT115. § 1591(a)(2))
16.
17.
From at least as early as in or about March 2004 through in or about October
2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the
Southern District of Florida, arid elsewhere, the defendants,
Ma
an/ an= and did knowingly benefit, financially or by receiving anything of value, from participation in a
venture, as defined in 18 PROT116. § 1591(c)(3), which had engaged in an act described in
violation of 18 PROT117. § 1591(a)(1), that is, the recruiting, enticing, providing, or obtaining
by any means a person, in or affecting interstate commerce, knowing that the person or
25
PROT48
persons had not attained the age of 18 years and would be caused to engage in a commercial
sex act as defined in 18 PROT118. § 1591(0)(1); in violation of Title 18, United States Code,
Sections 1591(a)(2), 1591(b)(2); and 2.
t,5
COUNTS 5 THROUGH (Enticement of Minor: 18 PROT119. § 2422(b))
18.
19.
On or about the dates enumerated as to each count listed below, in Palm Beach
County, in the Southern District of Florida, and elsewhere; the Defendant(s) listed below did
use a facility or means of interstate commerce, that is, telephone(s), to knowingly persuade,
induce, or entice the individual noted in each count listed below, who was a person in Palm
Beach County in the Southern District of Florida who had not attained the age of 18 years,
to engage in prostitution or sexual activity for which any person can be charged with a
criminal offense:
COUNT
DATE(S)
MINOR INVOLVED
DEFENDANT(S) --5-ro
JEFFREY EPSTITI e 1 3/11/2004 2/5/2005 - Jane Doe #2
5
2/6/2005 12/6/2004 - Jane Doe #3
C
6/2/2005
1
4/25/2004 - Jane Doe #4
1
6/29/2005
26
PROT49
COUNT
DATE(S)
DEFENDANT(S) 11/14/04 - Jane Doe #5
Y
3/29/05 itil 7/15/04 - Jane Doe #6
.1.
12/29/04
a
7/22/04 - Jane Doe #7 1/31/05 itiV1OPPRIIIMINISPINIMA
a
2/13/05 - Jane Doe #8 10/3/05
a
2/05 - 4/05 Jane Doe #9
j2
ST
7/4/04 - Jane Doe #12
l3
7/19/04
a
8/21/04 - Jane Doe #13
1 i
5/27/05
i
I
is
. ,..71, jc,5 CY ex.N.J- -c...-07 y C
All in viola on of 'It e 18, United States Code, Sections 422(b) and 2.
S8 THROUGH'
COUNTS S8THROUGH'wki.
(Travel to Engage in Illicit Sexual Conduct: 18 PROT120. § 2423(b))
20.
27
PROT50
21.
On or about the dates enumerated as to each count listed below, from a place
outside the Southern District of Florida to a place inside the Southern District of Florida, the
Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in
illicit sexual conduct as defined in 18 PROT121. § 2423(f), with a person under 18 years of age,
that is, the person(s) listed in each count below:
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
17
5/21/2004 Jane Doe #4 Mkt REY EPSTEIN
18
6/4/2 4 Jane Doe #4
EPSTEIN
19
6/20/2004
J
o
JEGE, INC.
20
/2004 Jane Doe #12
JEF
EPSTEIN
HYPE R, IN .
ai
lc
7/16/2004 Jane Doe #6 "illit taig- Jane Doe #12
JEFFREY EPSTEIN miter 7/22/2004 Jane Doe #4
IF
EFFREY CFSTEIrr
at
JEGE, NC.
28
PROT51
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
2
8/6/04 Jane Doe #4 Jane Doe #6
JEFFREY EPST IN
JEGE,
24
8 9/04 Jane Doe #6 Jane Doe #7
JEFFREY EP
GE, INC.
25
8/25/2004 Jane Doe #6
EPSTEIN
JEGE, INC.
26
9/16/2004 Jane oe #7 Jane D
#13
JE E, 1NC.
27
10/29/2004 Jane oe #7 Jan oe #13
28
11/5/2004 Jane Doe #4
FREY EPSTEIN
HYPER'
AIR, INC.
29
11/1
004
Jane Doe #6
JEFFREY E TEN
SARAH KEL EN
HYPERION AIR,
C.
30
11/18/2004 Jane Doe #5 Jane Doe #6
JEFFREY EPST
i
29
PROT52
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
31
12/3/2004 Jane Doe #5 Jane Doe #6
JEFFREY EPST
JEGE,
C.
32
1
3/2004 Jane Doe #3 Jane Doe #5 Jane Doe #6
JEFF
EPSTEIN
ERION AIR, INC.
33
12/17/20 Jane Doe #6 Jane Doe #7
34
1/1/2005 e Doe 5 Jan D e #7 Jane e #13
35
1/6/2005 Jane Doe 3 Jane Doe Jane Doe #1
36
1/14/2005 Jane Doe #3
JEGE, INC.
37
2/3/ 005 Jane Doe #3 Jane Doe #5
JEGE, INC.
38
2/10/2005 Jane Doe #3 Jane Doe #5
FREY EPSTEIN
JEGE,
C.
30
PROT53
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
39
2/21/2005 Jane Doe #3 Jane Doe #5
40
2/24/20 Jane Doe #3 Jane Doe #4 ane Doe #13
JEGE, INC.
41
3/4/2005
J
Do
JEGE, INC.
42
3/18/2005 Jane Doe #3 Jane Doe #5
EPSTEIN
JEGE, IN I- 2 3/31/2005 Jane Doe #2 Jane Doe #3 Jane Doe #4
ll
4
4.'8/2005 Jane Doe #3
JEFFREY
45
4/27/2005
J e
3
ERION AIR, INC.
46
, 12005 Jane Doe #3
JEFF
EPSTEIN
31
PROT54
It
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
47
5/19/2005 Jane Doe #3 Jane Doe #8
JEFF
STEIN
48
6/30
5
Jane Do
49
9/9/200 Jane Doe #8
BRION AIR,
SP
tee
it
9/18/2005 9/2.ilo s Jane Doe #8 I' c.-,.."00'4ci Frag;R:rgi
All in violation of Tit e 18, United States Code, Sections k423(b) and 2.
20
277
COUNTSO THROUGH 58 (Sex Trafficking: 18 PROT122. § 1591(a)(1)
22.
23.
On or about the dates enumerated as to each count listedbelow, the exact dates
being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida,
and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and
foreign commerce, recruit, entice, provide, and obtain by any means a person, that is, the
person in each count listed below, knowing that the person had not attained the age of 18
32
PROT55
years and would be caused to engage in a commercial sex act as defined in 18 PROT123. §
1591(c)(1):
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
21
12/6/2004 - Jane Doe #3 6/2/2005
2,0
WE
I
0
4/25/2004 - Jane Doe #4
2-4
6/29/2005 11/14/2004 - Jane Doe #5 3/29/2005
ME
all
7/15/2004 - Jane Doe #6
1...3 12/29/2004
oa
7/22/2004 - Jane Doe #7
JEFFREY EPSTEIN li lt 1/31/2005
46
2/13/2005 - Jane Doe #8 10/3/2005
XS
I
i
(
4
0
1412004 - Jane Doe i t
2.1
2117/200c
l
40
8/21/2004 - Jane Doe #13
t°
5/27/2005
All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2.
33
PROT56
COUNT 59
(Transportation of an Individual for Criminal Sexual Activity: 18 U.S.0
421)
24.
Paragraphs 1
6 of this Indictment are re-alleged and i rporated by reference
25.
From at least as early as July 2004, or about October 2005, the exact dates
being unknown to the Grand Jury, in Palm B
County, in e Southern District of Florida, and elsewhere, the defendant,
JEFFREY EPSTEIN, did knowingly transport an ividual, that in interstate commerce, 'th the
intent that such individu engage in any sexual activity for which any person can be charged with
a criminal offense; in violation of Title 18, United States Code, Sections 2421 and 2.
2-1c
COUNT a (Attempted Solicitation of a Minor: 18 PROT124. § 2422(b))
26.
Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference
27.
From on or about March 30, 2005, through on or about April 1, 2005, in Palm Beach
County, in the Southern District of Florida, and elsewhere, the defendants,
JEFFREY EPSTEIN and did knowingly and intentionally by means of a facility of interstate commerce, that is, by telephone,
attempt to persuade, induce, and entice a person who had not attained the age of 18 years, that is Jane
Doe #2, to engage in prostitution and in a sexual activity for which any person can be charged with
a criminal offense; in violation of Title 18, United States Code, Section 2422(b).
FORFEITURE
34
PROT57
A TRUE BILL
FOREPERSON
35
PROT58
SOUTHERN DISTRICT OF FLORIDA Case No:
18 PROT125. § 371 18 PROT126. § 2423(e) 18 PROT127. § 2423(d)
18 PROT128. § 1591(a)(2) 18 PROT129. § 2422(b) 18 PROT130. § 2423(b)
18 PROT131. § 1591(a)(1)
UNITED STATES OF AMERICA, vs.
JEFFREY EPSTEIN, a/k/a "
JEGE, INC., an
HYPERION AIR, INC., • Defendants.
INDICTMENT The Grand Jury charges that:
BACKGROUND At all times relevant to this Indictment:
1.
Defendant JEFFREY EPSTEIN employed defendants
I.= alda "MEM and among other things, services as personal assistants..
to perform,.
PROT59
2.
Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way,
Palm Beach, Florida, in the Southern District of Florida.
Defendant JEFFREY EPSTEIN was the principal owner of Defendant JEGE,
INC., a3D. elaware corporation. JEGE, INC.'s sole business activities related to the operation
and ownership of a Boeing 727-31 aircraft bearing tail number N908JE.
4.
Defendant JEFFREY EPSTEIN served as president, sole director, and sole
shareholder of Defendant JEGE, INC., and had the power to direct all of its operations.
5.
Defendant JEFFREY EPSTEIN was a principal owner of Defendant
HYPERION AIR, INC., a Delaware corporation. HYPERION AIR, INC.'s sole business
activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing
tail number N909JE.
6
Defendant JEFFREY EPSTEIN served as president, sole director, and sole
shareholder of Defendant HYPERION AIR, INC., and had the power to direct all of its
operations.
COUNT 1 A (Conspiracy: 18 PROT132. § 371)
7.
Paragraphs I through 6 of this Indictment are re-alleged and incorporated by
8.
From at least as early as March 2004, the exact date being unknown to the
Grand Jury, through in or about October 2005, in Palm Beach County, in the Southern
District of Florida, and elsewhere, the defendants,
2
PROT60
JEGE, INC., and
HYPERION AIR, INC., did knowingly and willfully combine, conspire, confederate and agree with each other and
with others known and unknown to commit an offense against the United States, that is, to
use a facility or means of interstate or foreign commerce to knowingly persuade, induce, or
entice individuals who had not attained the age of 18 years to engage in prostitution or any
sexual activity for which any person can be charged with a criminal offense, in violation of
Title 18, United States Code, Section 2422(b).
Purpose and Object of the Conspiracy
9.
It was the purpose and object of the conspiracy to procure females under the
age of 18 to travel to 358 El Brillo Way, Palm Beach, Florida so that JEFFREY EPSTEIN
could, in exchange for money, engage in lewd conduct with those minor females in order to
satisfy JEFFREY EPSTEIN's prurient interests.
Manner and Means
10.
The manner and means by which the defendants and other participants sought
to accomplish the purpose and object of the conspiracy included the following:
(a)
It was part of the conspiracy that Defendants a/k/a
3
and would contact
PROT61
minor females via the use of cellular and other telephones to arrange appointments for minor
females to travel to 358 El Brillo Way to allow Defendant JEFFREY EPSTEIN to engage
in lewd conduct with them.
(b)
EPSTEIN, and OF erirsIS anda would make payments to, or cause payments to be made to, minor females
in exchange for engaging in lewd conduct.
(c)
EPSTEIN, a/k/a caM= and 1.
cipat) would ask females to recruit ether minor females to engage in lewd conduct
with Defendant JEFFREY EPSTEIN.
(d)
EPSTEIN, ailda and would make payments to, or cause payments to be made to, the recruiters
for bringing additional minor females to 358 El Brillo Way to engage in lewd conduct with
Defendant JEFFREY EPSTEIN.
4
PROT62
Overt Acts
11.
In furtherance of this conspiracy and to effect the objects thereof, there was
committed by at least one of the co-conspirators herein, at least one of the following overt
acts, among others in the Southern District of Florida:
(1)
On March 11, 2004, Defendants JEFFREY EPSTEIN,
EM, and traveled from Teterboro, New Jersey, to
Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant
(2)
On or about March 12, 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #1 to travel to 358 El Brillo Way, Palm Beach,
Florida.
(3)
On or about March 12, 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #1.
(4)
On April 25, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(5)
On May 1,
2004, Defendants EPSTEIN, S and traveled from New York, New York to Palm Beach County, Florida
5
PROT63
(6)
On May 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(7)
On May 14, 2004, Defendants EPSTEIN, MI and traveled from Canada to Palm Beach County, Florida aboard the
(8)
On May 14, 2004, Defendant calls to be made to a telephone used by Jane Doe #4.
(9)
On May 20, 2004, Defendant calls to be made to a telephone used by Jane Doe #4.
(10)
On May 21, 2004, Defendants EPSTEIN and caused one or more telephone caused one or more telephone traveled
from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream
(11)
On June 3, 2004, Defendants caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(12) On June 4, 2004, Defendants EPSTEIN and traveled
from New Haven, Connecticut to Palm Beach County, Florida aboard the Gulfstream
6
PROT64
(13) On June 11, 2004, Defendants EPSTEIN and traveled from
Chicago, Illinois to Palm Beach County, Florida aboard the Gulfstream aircraft owned
by Defendant HYPERION AIR, INC.
(14)
On June 11, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(15)
On June 20, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(16) On June 20, 2004, Defendants EPSTEIN and traveled
from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727
aircraft owned by Defendant JEGE, INC.
(17) On July
4,
2004, Defendants
EPSTEIN, a, and traveled from Aspen, Colorado to Palm Beach County, Florida
(18)
On July 4, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #12.
(19)
On July 10, 2004, Defendantcalls to be made to a telephone used by Jane Doe #4.
(20)
On July 10, 2004, Defendant caused one or more telephone caused one or more telephone
calls to be made to a telephone used by Jane Doe #12.
7
PROT65
(21)
On July 15, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6.
(22)
On July 16, 2004, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida
(23)
On July 16, 2004, Defendant caused Jane Doe # 6 to make one or more telephone calls to a telephone used by Jane Doe # 7.
(24)
On July 18, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(25)
On July 22, 2004, Defendant la caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(26)
On July 22, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6.
(27)
On July 22, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(28)
On July 22, 2004, Defendants EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida
8
PROT66
(29)
On July 22, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(30)
On August 4, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(31) On August 6, 2004, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft
(32)
On August 17, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(33)
On August 19, 2004, Defendants EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing
727 aircraft owned by Defendant JEGE,
(34) On August 19, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6.
(35)
On August 21, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe # 13.
(36) On August 25, 2004, Defendants EPSTEIN, and traveled from Ecuador to Palm Beach County, Florida aboard the
9
PROT67
(37)
On August 25, 2004, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(38)
On August 25, 2004, Defendant made to a telephone used by Jane Doe #6.
(39)
On August 25, 2004, Defendant caused a telephone call to be caused one or more
telephone calls to be made to a telephone used by Jane Doe #7.
(40)
On September 16, 2004, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida
aboard the Boeing 727 aircraft owned by Defendant, JEGE, INC.
(41)
On September 16, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(42)
On October 2, 2004, Defendants EPSTEIN, a and traveled from the U.S. Virgin Islands to Palm Beach County, Florida
(43)
On October 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(44)
On October 3, 2004, Defendana caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
10
PROT68
(45)
On October 26, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(46)
On October 29, 2004, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida
aboard the Gulfstream aircraft owned by Defendant, HYPERION, AIR, INC.
(47)
On October 30, 2004, Defendant EM caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(48)
On November 4, 2004, Defendant I.= caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(49)
On November 7, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6.
(50) On November 10, 2004, Defendants EPSTEIN and traveled
from TeterbOro, New Jersey to Palm Beach County, Florida aboard the Gulfstream
aircraft owned by Defendant HYPERION AIR,
(51)
On November 10, 2004, Defendant .= caused one or more telephone calls to be made to a telephone used by Jane Doe #6.
(52) On November 17, 2004, Defendant caused a telephone call
11
PROT69
(53)
On or about November 17, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #5.
(54)
On or about November 18, 2004, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach
County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION
AIR, INC.
(55)
On December 1, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6.
(56) On or about December 3, 2004, Defendants EPSTEIN, =.
and traveled from New York, New York to Palm Beach County, Florida aboard the
(57) On December 4, 2004, Defendant provided a written message
to Defendant EPSTEIN regarding Jane Doe #6 and Jane Doe #7.
(58) On or about December 5, 2004, Defendant M.
caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(59)
On or about December 6, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
(60) On or about December 12, 2004, Defendant MM
. caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
12
PROT70
(61)
On or about December 13, 2004, Defendant IMMI caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(62)
On December 13, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6.
(63)
On or about December 13, 2004, Defendant EPSTEIN traveled from the
U.S. Virgin Islands to Palm Beach County, Florida, aboard the Gulfstream aircraft
(64)
On or about December 14, 2004, Defendant made one or more telephone calls to Jane Doe #3.
(65)
On or about December 14, 2004, Defendant MM caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(66)
On December 16, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(67)
On or about December 17, 2004, Defendants EPSTEIN and traveled from Teterb oro, New Jersey to Palm Beach County, Florida
(68) On December 17, 2004, Defendant .= caused a telephone call
13
PROT71
(69)
On or about December 18, 2004, Defendants caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(70) On or about December 18, 2004, Defendant caused Jane Doe
#10 to make one or more telephone calls to a telephone used by Jane Doe #11.
(71)
On or about December 20, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
(72)
On or about December 23, 2004, Defendant EPSTEIN caused a Western
Union wire transfer order to be sent to Jane Doe #5. •
(73) On December 29, 2004, Defendant a caused a telephone call
(74)
On or about January 1, 2005, Defendants caused a telephone call to be made to a telephone used by Jane Doe #5.
(75)
On January 1, 2005, Defendanaf caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(76) On or about January 1, 2005, Defendants EPSTEIN, and traveled from Anguilla, British West Indies to Palm Beach County,
Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
(77)
On January 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
14
PROT72
(78)
On January 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #13.
(79)
On or about January 6, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
(80)
On or about January 6, 2005, Defendant EPSTEIN traveled from
Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft
owned by Defendant HYPERION AIR; INC.
(81)
On or about January 8, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jdne Doe #5.
(82)
On or about January 9, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(83)
On or about January 14, 2005, Defendant made one or more telephone calls to Jane Doe #3.
(84)
On or about January 14, 2005, Defendants EPSTEIN.= and traveled from the U.S. Virgin Islands to Palm Beach County,
Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
(85)
On January 14, 2005, Defendant IMM caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
15
PROT73
(86)
On or about January 19, 2005, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County,
Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
(87)
On January 22, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(88)
On or about January 26, 2005, Defendant= reviewed a telephone message from Jane Doe #5.
(89)
On January 27, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(90) On January 28, 2005, Defendant =.
caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(91)
On or about February 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(92)
On February 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7.
(93) On or about February 3, 2005, Defendants EPSTEIN, =.
and traveled from Columbus, Ohio, to Palm Beach County, Florida,
(94)
On or about Febtuary 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3.
16
PROT74
(95) On or about February 6, 2005, EPSTEIN and Doe #1 to make one or more telephone calls to Jane Doe #2.
(96)
On or about February 6, 2005, EPSTEIN and caused Jane caused Jane
Doe #1 to transport Jane Doe #2 to 358 El Brillo Way, Palm Beach, Florida.
(97)
On or about February 6, 2005, EPSTEIN made a payment of $300 to
Jane Doe #2 and a payment of $200 to Jane Doe #1.
(98)
On or about February 10, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5.
(99)
On or about February 10, 2005, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach
County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
(100) On or about February 10, 2005, Defendants caused one or
(101) On February 14, 2005, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(102) On or about February 21, 2005, Defendants caused one or
(103) On or about February 21, 2005, Defendants EPSTErN,a and traveled from the U.S. Virgin Islands to Palm Beach County,
Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC.
17
PROT75
(104) On or about February 24, 2005, Defendant caused one or
(105) On or about February 24, 2005, Defendants EPSTEIN, IM and traveled from Teterboro, New Jersey to Palm Beach County,
(106) On February 24, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(107) On or about February 25, 2005, Defendant more telephone calls to be made to a telephone used by Jane Doe #5.
(108) On or about March 1, 2005, Defendant caused one or more
(109) On or about March 4, 2005, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida
(110) On March 7, 2005, Defendant caused one or more telephone
(1 11) On or about March 16, 2005, Defendant caused one or more
(112) On or about March 17, 2007, Defendant caused one or more
18
caused one or
PROT76
(113) On or about March 18, 2005, Defendant EPSTEIN traveled from New
York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft
(114) On March 18, 2005, Defendant a prepared a written message
to Defendant EPSTEIN regarding Jane Doe #4.
(115) On or about March 21, 2005, Defendant caused one or more
(116) On March 29, 2005, Deferdanta caused one or more telephone calls to be made to a telephone used by Jane Doe #4.
(117) On or about March 30, 2005, a caused one or more calls to be made to a telephone used by Jane Doe #1.
(118) On or about March 30, 2005, Defendant caused one or more
(119) On or about March 31, 2005, Defendant EPSTEIN traveled from New
York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft
(120) On or about March 31, 2005, a caused one or more calls to be made to a telephone used by Jane Doe #1.
(121) On or about March 31, 2005, EPSTEIN traveled from New York, New
York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by
Defendant JEGE, INC.
19
PROT77
(122) On or about March 31, 2005, EPSTEIN anacaused
Jane Doe #1 to make a call to a telephone used by Jane Doe #2.
(123) On or about April 1, 2005, EPSTEIN and caused Jane Doe
#1 to make one or more calls to a telephone used by Jane Doe #2.
(124) On April 2, 2005, Defendant= caused one or more telephone calls
to be made to a telephone used by Jane Doe #8.
(125) On or about April 8, 2005, Defendant caused one or more
(126) On or about April 8, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County,
(127) On April 11, 2005, Defendant= caused one or more telephone calls
to be made to a telephone used by Jane Doe #4.
(128) On April 11, 2005, Defendant caused one or more telephone
(129) On or about April 26, 2005, Defendant caused one or more
(130) On or about April 27, 2005, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the
Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
20
PROT78
(131) On or about May 6, 2005, Defendants EPSTEIN, =.= and traveled from Teterboro, New Jersey to Palm Beach County,
(132) On or about May 19, 2005, Defendant caused one or more
(133) On May 19, 2005, Defendant caused one or more telephone
(134) On or about May 19, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the
Gulfstream aircraft owned by Defendant HYPERION AIR, INC.
(135) On June 8, 2005, Defendants EPSTEIN,IIM, and traveled
from New York, New York to Palm Beach County, Florida aboard the Boeing 727
aircraft owned by Defendant, JEGE, INC.
(136) On June 12, 2005, Defendant caused one or more telephone
(137) On June 18, 2005, Defendants EPSTEIN and traveled from
(138) On June 20, 2005, Defendant caused one or more telephone
21
PROT79
(139) On June 30, 2005, Defendant caused one or more telephone
(140) On June 30, 2005, Defendants EPSTEIN, traveled from
(141) On July 2, 2005, Defendants caused one or more telephone
(142) On July 22, 2005, Defendant caused one or more telephone
(143) On July 22, 2005, Defendants EPSTEIN, a traveled from
(144) On August 18, 2005, Defendants EPSTEIN, S and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard
(145) On August 18, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(146) On August 19, 2005, Defendant= caused one or more telephone
(147) On August 21, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
22
PROT80
(148) On September 3, 2005, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft
(149) On September 3, 2005, Defendant caused one or more telephone
(150) On September 8, 2005, Defendant received a telephone call from
Jane Doe #8.
(151) On September 9, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard
(152) On September 18, 2005, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(153) On September 18, 2005, Defendants EPSTEIN, a andtraveled from Westchester County, New York to Palm Beach County, Florida aboard
(154) On September 29, 2005, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #8.
(155) On September 29, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida
23
PROT81
(156) On October 3, 2005, Defendan caused one or more telephone
All in violation of Title 18, United States Code, Sections 371 and 2.
COUNT 2 (Conspiracy to Travel: 18 PROT133. § 2423(e))
12.
Paragraphs 1 through 6 of this indictment are re-alleged and incorporated by
reference as fully set for the herein.
13.
From at least as early as March 2004 through in or around October 2005, the
exact dates being unknown to the Grand Jury, the defendants,
JEFFREY EPSTEIN, aryl did knowingly and willfully conspire with each other and with others known and unknown
to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as
defined in 18 PROT134. § 2423(f), with another person, in violation of Title 18, United States
Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e).
COUNT 3
(Facilitation of Unlawful Travel of Another: 18 PROT135. § 2423(d)) •
14.
24
PROT82
From at least as early as in or about March 2004 through in or about October
.6.,; the exact dates being unknown to the Grand Jury, in Palm Beach County, in the
Southern District of Florida, and elsewhere, the defendant, did, for the purpose of commercial advantage or private fnancial gain, arrange or facilitate
the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was
traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as
defined in 18 PROT136. § 2423(f); in violation of Title 18, United States Code, Section 2423(d).
COUNT 4 (Sex Trafficking: 18 PROT137. § 1591(a)(2))
16.
17.
From at least as early as in or about March 2004 through in or about October
2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the
Southern District of Florida, and elsewhere, the defendants, a ties and did knowingly benefit, financially or by receiving anything of value, from participation in a
venture, as defined in 18 PROT138. § 1591(c)(3), which had engaged in an act described in
violation of 18 PROT139. § 1591(a)(I), that is, the recruiting, enticing, providing, or obtaining
by any means a person, in or affecting interstate commerce, knowing that the person or
25
PROT83
e
xctotr
-tiTro-c3._ persons had not attained the age of 18 years and would be caused to engage in a commercial
sex act as defined in 18 PROT140. § 1591(c)(1); in violation of Title 18, United States Code,
Sections 1591(a)(2), 1591(b)(2), and 2.
COUNTS 5 THROUGH 16 (Enticement of Minor: 18 PROT141. § 2422(b))
18.
19.
On or about the dates enumerated as to each count listed below, in Palm Beach
County, in the Southern District of Florida, and elsewhere, the Defendant(s) listed below did
use a facility or means of interstate commerce, that is, telephone(s), to knowingly persuade,
induce, or entice the individual noted in each count listed below, who was a person in Palm
Beach County in the Southern District of Florida who had not attained the age of 18 years,
to engage in prostitution or sexual activity for which any person can be charged with a
criminal offense:
COUNT r
DATE(S)
MINOR INVOLVED
DEFENDANT(S) 7/2004 Jane Doe #
6
2/5/2005 - 2/6/2005 Jane Doe #2 Ts, i 6
47
7
12/6/2004 - 6/2/2005
i
Jane Doe #3
8
4/25/2004 - 6/29/2005 Jane Doe #4
26
PROT84
I COUNT
DATE(S)
MINOR INVOLVED
DEFENDANT(S)
9
11/14/04 - 3/29/05 Jane Doe #5
10
7/15/04 - 12/29/04 Jane Doe #6
11
7/22/04 - 1/31/05 Jane Doe #7
i
12
2/13/05 - 10/3/05 Jane Doe #8
i
13
2/05 - 4/05 Jane Doe #9
14
12/18/04 Jane Doe #11
15
7/4/04 - 7/19/04 Jane Doe #12
16
8/21/04 - 5/27/05 Jane Doe #13
All in violation of Title 18, United States Code, Sections 2422(b) and 2.
COUNTS 17 THROUGH 50
(Travel to Engage in Illicit Sexual Conduct: 18 PROT142. § 2423(b))
20.
27
PROT85
21.
On or about the dates enumerated as to each count listed below, from a place
outside the Southern District of Florida to a place inside the Southern District of Florida, the
Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in
illicit sexual conduct as defined in 18 PROT143. § 2423(f), with a person under 18 years of age,
that is, the person(s) listed in each count below:
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
17
5/21/2004 calk t/lol
Ea
Jane Doe #4 iia awe 3.:4
JEFFREY EPSTEIN liATERBala
18
6/4/2004 2 ca//r OM Jane Doe #4
19
9
NEF-P 6/20/2004 If oili WO/ 4 in" h oft441/ Jane Doe #4
"4 sa+of
JEGE, INC.
20
7/4/40Q4 I4+11 7/v/inv int 'it/ ---"m Jane Doe #12 bs. #.14---f
21
0
9,yA 1 14A fftell 7/16/2004 404 "fisioy Jane Doe #6
- 4staaa6S5 Jane Doe #12
41
22
7/22/2004 7).2.144 Jane Doe #4 Jane Doe #6 Jane Doe #7
JEGE, INC.
7
• a) a tl .
4 a
• z•sioy
28
PROT86
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
23
8/6/04 Jane Doe #4 Jane Doe #6
JEGE, INC.
24
8/19/04 Jane Doe #6 Jane Doe #7
JE E, INC.
25
8/25/2004 Jane Doe #6
JEFFREY EPSTEIN ,IN •
26
9/16/2004 Jane Doe #7 Jane Doe #13
JEGE, INC.
27
10/29/2004 Jane Doe #7 Jane Doe #1,3
28
11/5/2004 Jane Doe #4
HYP
N AIR, INC.
29
11/10/2004 Jane Doe #6
30
11/18/2004 Jane Doe #5 Jane Doe #6
JEFFRE EPSTEIN
ERION AIR, INC.
29
PROT87
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
31
12/3/2004 Jane Doe #5 Jane Doe #6
JEGE, INC.
32
12/13/2004 Jane Doe #3 Jane Doe #5 Jane Doe #6
33
12/17/2004 Jane Doe #6 Jane Doe #7
34
1/1/2005 Jane Doe #5 Jane Doe #7 Jane Doe #13
35
1/6/2005 Jane Doe #3 Jane Doe #4 Jane Doe #13
36
1/14/2005 Jane Doe #3
JEGE, INC.
37
2/3/2005 Jane Doe #3 Jane Doe #5
JEGE, INC.
38
2/10/2005 Jane Doe #3 Jane Doe #5
JE E, INC.
30
PROT88
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
39
2/21/2005 Jane Doe #3 Jane Doe #5 -
I
JEGE, INC.
40
2/24/2005 Jane Doe #3 Jane Doe #4 Jane Doe #13
JEGE, INC.
41
3/4/2005 Jane Doe #5
-
I
JEGE, INC.
42
3/18/2005 Jane Doe h3 Jane Doe h5
JEGE, INC.
:1 3 3/31/2005 Jane Doe #2 Jane Dce #3 Jane Doe #4
_I
l iffl
il
44
4/8/2005 Jane Doe #a__-- -- JEFFEETIPSTEIN HaPPARIC.
45
-44,12/2.005 Jane Doe #3
REY EPSTEIN
X46
5/6/2005 Jane Doe #3
JEFFRES? EPSTEIN
31
PROT89
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S) Thir -- --.5a9/2005 Jane Doe #3
EPSTEIN -...48, 6/30/2005
Jai ie L1loos_a_.-----------MPFR:ErEATEIN 9/9/2005
Jane Doe #8
JEF
EPSTEIN
5
9/18/2005 Jane Doe #8 .411 in violatio7 of Tit e 18, United States C de, Sectio
3
q 1 2_6( op S tja-v•-t.bcr-e-3
COUNTS 51 THROUGH 58 (Sex Trafficking: 18 PROT144. § 1591(a)(1)
22.
23.
On or about the dates enumerated as to each count listed below, the exact dates
being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida,
and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and
foreign commerce, recruit, entice, provide, and obtain by any means a person, that is, the
person in each count listed below, knowing that the person had not attained the age of 18
32
PROT90
years and would be caused to engage in a commercial sex act as defined in 18 PROT145. §
1591(O(1):
COUNT
DATE(S)
MINOR(S)
INVOLVED
DEFENDANT(S)
51
12/6/2004 - 6/2/2005 Jane Doe #3
52
4/25/2004 - 6/29/2005 Jane Doe #4
53
11/14/2004 - 3/29/2005 Jane Doe #5
54
7/15/2004 - 12/29/2004 Jane Doe #6
55
7/22/2004 - 1/31/2005 Jane Doe #7
56
2/13/2005 - 10/3/2005 Jane Doe #8
I
57.
2/4/9004 - Jane Doe rurazD3231 lacMcf--- -..
ao4-c r A' 1.t Dire 14
58
8/21/2004 - 5/27/2005 Jane Doe 413
All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2.
33
PROT91
COUNT 59
(Transportation of an Individual for Criminal Sexual Activity: 18 PROT146. § 2421)
24.
Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference
25.
From at least as early as July 2004, through in or about October 2005, the exact dates
being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and
elsewhere, the defendant,
JEFFREY EPSTEIN, did knowingly transport an individual, that is, in interstate commerce, with the intent that such individual engage in any sexual activity for which any person can be charged with
a criminal offense; in violation of Title 18, United States Code, Sections 2421 and 2.
COUNT 60 (Attempted Solicitation of a Minor: 18 PROT147. § 2422(b))
26.
Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference
27.
From on or about March 30, 2005, through on or about April 1, 2005, in Palm Beach
County, in the Southern District of Florida, and elsewhere, the defendants,
JEFFREY EPSTEIN and did knowingly and intentionally by means of a facility of interstate commerce, that is, by telephone,
attempt to persuade, induce, and entice a person who had not attained the age of 18 years, that is Jane
Doe #2, to engage in prostitution and in a sexual activity for which any person can be charged with
a criminal offense; in violation of Title 18, United States Code, Section 2422(b).
FORFEITURE
34
PROT92
A TRUE BILL
FOREPERSON
35
PROT93
A
1
VICTIM WITNESS
DOB
i
j
Jane Jane Doe #1 Doe #2 ane oe
2
---r•
AGE AT FIRST
CONTACT
17
I
14
IIII
16
3
4
HIGH SCHOOL
BROUGHT BY
5
DATES OF
CONTACT/ SOURCE 03/12/2004 - 07/24/2005 Telephone 02/06/2005 - 04/2005
Telephone 12/06/04 -10/27/2005 .
Telephone. Spring 04U telephone contact.
6
7
GIRLS RECRUITED
l
I
I
N/A
(18)
NUMBER OF
MASSAGES
1
1
Unknown/Multiple
8
ENTICEMENT /Ms 18 PROT148 2422(b)_ Interstate Commerce
Connection !Telephone records Telephone records between MS
Telephone records
10
Phone calls with
F
33
0
Total - Over 50 (70)
From
77
Total Over 125 (156)
11
0
12
Phone call
TM: 6
0
Total - Approx. 26 (28)
13
Under 18 at time of sexual activity
YES - 17
YES - 14
YES -16/17
14
Advised if asked to state they were over 18/Advised by whom?
YES -
S.
YES - .Advi
t
I
and
HS
YES -
PROT94
A
VICTIM WITNESS
DOB
Jane ane oe 1 . oe #2 Jane oe
15
Knowledge or Discussion of Age with JE?
told JE she was u she said that she thought he knew better.
`told she was and a
at
High
oo
Never told JE her age.
Discussed and would be attending stated that attending care, when it came to her age.
told she was worried b I she ad mentioneidirom to
JE.) Ill -Rand good lien s an ey went to same school and in same class.
and JE discussed b/c o girls frdshU. Ss she wane
16
Payment for services?/Amount
YES/$200.00
YES/$300.00
YES/$200.00
17
Payment for recruitment $200.00 per girl
NO
YES
18
Payments made by Epstein [repeated 3 times]
19
Taken upstairs by Unknown female assistant -.or Epstein and Jeffrey
20
Clothing worn during massage Nude Nude Underwear/Nude
PROT95
1
21
A
VICTIM WITNESS
DOB
Jane Doe 1 Sexual activity Performed massages in the nude.
would not allow him to ouch her.
YES
YES, made moaning noises while touching himself.
YES
Doe #2
22
23
Statements made by Epstein
24
YES ni pay you $200.00 for every girl you bring to me. Make sure they know what is expected.
The younger the better.
JE wiped penis with towel, "'believed he ejaculated..
Asked to use her. I gave you $100 because I you and used a on you.
PROT96
A
I
B
I
C
I
D
1
VICTIM WITNESS
DOB ane oe 1 Jane oe #2 ane oe 3
25
Asked to bring others/By whom?
YES/ Epstein
NO
call to Sister)
26
Gifts
NO
NO
YES - VS Bra & Panty sets, Vibrator, and Rental Car
27
Physical Evidence (Le. Message Pads, Trash Pulls, Search
Warrant, Payment Documentation, etc.) Confession
MP - 4
TP - 4 Controlled call to.
MP - 0
TP-
2 items 04/08/2005.
TP- 09/21/2005, TP - 10/04/2005, TP-10/07/2005.
MP - 1
28
Counts
29
30
TRAVEL Title 18 PROT149 2423(b)
31
Dates of Travel/Aircraft
32
33
34
TRANSPORTATION Title 18 PROT150 2421
Dates of Travel/Aircraft
N/A
[repeated 3 times]
35
S
al activi with
No
[repeated 3 times]
36
Counts
37
38
HUMAN SEX
TRAFFICKING Title 18 PROT151 1591(a)
PROT97
A
I
B
C
I
D
1
VICTIM WITNESS
DOB
Jane ane oe 1 oe #2 ane oe 3
39
Who Scheduled Appointments?
- 11ria
NM
40 Counts
41
42
Interviewed by PBPD Yes
Yes
Yes
43 Interviewed by FBI
No
Yes
Yes
44
Miscellaneous
JE offeiedTonto his island arou and for eir June birthdays.
new about JE pawl ing wit lingerie for birthday, and rental car.
told that JE oesn't o that (referring to sex) he la s around with them.
said it
JE liked and the most.
to l.
that JE had
pu
and had • ought out t e
PROT98
A
1
VICTIM WITNESS
DOB
Jane Jane Doe #4 oe.#5
2
AGE AT FIRST
CONTACT
16
17
17
3
HIGH SCHOOL
4
BROUGHT BY
5
DATES OF
CONTACT/ SOURCE 4/25/2004 - 10/06/2005 "Telephone Sometime between
04/2004 - 07/2004 via M & telephones -Start
D
l
11/12/2004 - 03/29/2005 'Telephone
6
GIRLS RECRUITED
N/A
1yoa) Pai $200.00 each be
7
NUMBER OF
MASSAGES 3-4 times 3-4 times More than 10
8
ENTICEMENT Title 18 PROT152 2422(W_ Interstate Commerce .Telephone
Connection
9
records Number unidentified 2 Telephone Records
10
Phone calls with
From' - 60
Total - Approx 100 (104)
From,- 31
Total prox 70
11
Phone call
0
0
12
Phone calls
2
Total - 7
13
Under 18 at time of sexual activity
YES
YES
YES "
14
Advised if asked to state they were over 18/Advised by whom?
YES - Advised would make
$200.00, ress cute, might tibuch, say if uncomfortable and JE stop
YESa Advised she would make $200.00, wear something sexy and you if asked
PROT99