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STATES
CT COU
v. 19 Cr. .
JEFFREY EPSTEINDefendant.
COUNT ONE
(Sex Trafficking Conspiracy)
The Grand Jury charges:
1. As set forth herein, over the course of many
years, JEFFREY EPSTEIN, the defendant, sexually exploited and?
abused dozens of minor girls at his homes in Manhattan, New
York, and Palm Beach, Florida, among other locations.
2. In particular, from at least in or about 2002, up
to and including at least in or about 2005, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, minor girls to visit his mansion in Manhattan, New
York (the ?New York Residence?) and his estate in Palm.Beach,
engage in sex acts with
Florida (the ?Palm Beach Residence?)
him, after which he would give the victims hundreds of dollars
in cash. Moreover, and in order to maintain and increase his
supply of victims, EBSTEIN also paid certain of his victims to
be similarly abused by EPSTEIN. In
recruit additional girls
Palm Beach.
3. The victims described herein were as young as 14
years old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for various reasons, often particularly
vulnerable to exploitation. EPSTEIN intentionally sought out
minors and knew that many of his victims were in fact under the
.age of 18, including because, in some instances, minor victims
expressly told him their age.
4. In creating and maintaining this network of minor
victims in multiple states to sexually abuse and exploit,
JEFFREY EPSTEIN, the defendant, worked and conspired with
others, including employees and associates who facilitated his
conduct by, among other things, contacting victims and
scheduling their sexual encounters with EPSTEIN at the New York
Residence and at the Palm Beach Residence.
5. During all time periods charged in this
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with
multiple residences in the continental United States, including
the New York Residence and the Palm Beach Residence.
6. Beginning in at least 2002, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
years Old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for various reasons, often particularly
vulnerable to exploitation. EPSTEIN intentionally sought out
:minors and knew that many of his victims were in fact under the
'age of 18, including because, in some instances, minor victims
expressly told him their age.
4. In creating and maintaining this network of minor
victims in multiple states to sexually abuse and exploit,
JEFFREY EPSTEIN, the defendant, worked and conspired with
others, including employees and associates who facilitated his
among other things, contacting victims and
conduct by,
scheduling their sexual encounters with EPSTEIN at the New York
Residence and at the Palm Beach Residence.
5. During all time periods charged in this
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with
multiple residences in the continental United States, including
the New York Residence and the Palm Beach Residence.
6 Beginning in at least 2002, JEFFREY EPSTEIN, the
ndant enticed and recruited, and caused to be enticed and
7.
the In both New York and Florida, JEFFREY EPSTEIN,
endant, perpetuated this abuse in similar ways. Victims
were initially recruited to provide ?massages? to EPSTEIN, which
would be performed nude or partially nude, would become
increasin
9 sexual in nature, and would typically include one
or more i ar
sex a ts. EPSTEIN paid his victims hundreds of doll
in cash for each encounter. Moreover, EPSTEIN actively
encouraged certain of his victims to recruit additional girls to
be similarly sexually abused. EPSTEIN incentivized his victims
to become recruiters by paying these victim?recruiters hundreds
of dollars for each girl that they brought to EPSTEIN. In so
doing, EPSTEIN maintained a steady supply of new victims to
exploit.
The New York Residence
8. At all times relevant to this Indictment, JEFFREY
EPSTEIN, the defendant, possessed and controlled a multi?story
private residence on the Upper East Side of Manhattan, New York,
the New York Residence. Between at least in or about 2002
and in or about 2005, EPSTEIN abused numerous minor victims at
the New York Residence by causing these victims to be recruited
to engage in paid sex acts with him.
defendant. The victims, who were as young as 14 years of age,
were told by EPSTEIN or other individuals to partially or fully
undress betore beginning the ?massage.? During the encounter,
EPSTEIN would escalate the nature and scope of physical contact
with his victim to include, among other things, sex acts such as
groping and direct and indirect contact with the victim?s
genitals. EPSTEIN typically would also masturbate during these
sexualized encounters, ask victims to touch him while he
masturbated, and touch victims? genitals with his hands or with
sex toys.
10. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars in cash for each encounter.
ll. JEFFREY EPSTEIN, the defendant, knew that many of
his New York victims were underage, including because certain
victims told him their age. Further, once these minor victims
PSTEIN on multiple
were recruited, many were abused by
subsequent occasions?at the New York Residence. EPSTEIN
nally contacted victims to schedule appointments
sometimes perso
In other instances,\EPSTEIN directed
at the New York Residence.
oyees and associates, inclu
to comm .. ding a New York-based employee
unlcate with victims via phone to arrange
for these ViCtims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform ?massages? and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim?recruiter and the new
victim hundreds of dollars in cash. Through these victim?
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
gage in sex acts with JEFFREY EPSTEIN, the
massages to and en
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim?recruiters for every
additional girl they brought to EPSTEIN. When a victim?
new minor victim to the New York
recruiter accompanied a
Residence, both the victim?recruiter and the new minor victhn
were paid hundreds of dollars by EPSTEIN for each encounter: In
addition, certain victim?recruiters routinely scheduled these
Counters throu
gh Employee?l, who sometime
as ed the
recruiters to
.
ing a specrfic minor girl for EPSTE
IN.
The Palm Beach Residencei
14. In a
ddition to recruiting and abusing minor girls
in New York
JEFFREY EPSTEIN, the defendant, created a similar
netwo I
rk of minor girls to Victimize in Palm Beach, Florida
I
wh
ere EPSTEIN owned, possessed and controlled another large
reSidence, the Palm Beach Residence. EPSTEIN frequently
traveled from New York to Palm Beach by private jet, before
which an employee or associate would ensure that minor victims
were available for encounters upon his arrival in Florida.
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
at times, two assistants (?Employee?2? and?
including,
?Employee?3?) who, as described herein, were also responsible
for scheduling sexual encounters with minor victims. Once
inside, the victim would provide a nude or semi-nude massage for
EPSTEIN, who would himself typically be naked. During these
ate the nature and scope of the
encounters, EPSTEIN would escal
physical contact to include sex acts such as groping and direct
and indirect contact with the victim?s genitals. EPSTEIN would
ncounters, ask victims
masturbate during these
also typicall
I and touch victims? genitals
16. I
connection With each sexual encounter, JEFFREY
EPSTEIN .
he defendant, or one of his employees or associates,
aid
the Victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
l7. JEFFREY EPSTEIN, the defendant, knew that certain
of his victims were underage, including because certain victims
told him their age. In addition, as with New York?based
Victims, many Florida victims, once recruited, were abused by
JEFFREY EPSTEIN, the defendant, on multiple additional
occasions.
18. JEFFREY EPSTEIN, the defendant, who during the
relevant time period was frequently in New York, would arrange
for Employee?2 or other employees to contact victims by phone in
advance of travel to Florida to ensure appointments
were scheduled for when he arrived. In particular, in certain
instances, Employee?2 placed phone calls to minor victims in
encounters at the Palm Beach Residence. At
Florida to schedule
the time of certain of those phone calls, EPSTEIN and Employee?2
were in New York, New York. Additionally, certain of the
individuals victimized at the Palm Beach Residence were
contacted by phone by Employee?3 to schedule these encounters.
girls to
. EPSTEIN paid hundreds of dollars to victim?
recrui .
ters for each additional girl they brought to the Palm
Beach Residence.
20. From at least in or about 2002, up to and.
including in or about 2005, in the Southern District of New.York
and elsewhere, JEFFREY EPSTEIN, the defendant, and others known
and unknown, willfully and knowingly did combine, conspire,
confederate, and agree together and with each other to commit an
offense against the United States, to wit, sex trafficking of
minors, in violation of Title 18, United States Code, Section.
1591(a) and
21. It was a part and objeCt of the conspiracy that
JEFFREY EPSTEIN, the defendant, and others known and unknown,
would and did, in and affecting interstate and foreign commerce,
recruit, entice, harbor, transport, provide, and obtain, by any
means a person, and to benefit, financially and by receiving
anything of value, from participation in a venture which has
engaged in any such act, knowing that the person had not
ed the age of 18 years and would be caused to engage in a
attain
ommercial sex act, in violation of Title 18, United States
Code, Sections 1591(a) and
Overt Acts
22. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a. In or about 2004, JEFFREY EPSTEIN, the
defendant, entiCed and recruited multiple minor victims,
including minor victims identified herein as Minor Victim-1,
Minor Victim?2, and Minor Victim?3, to engage in sex acts with
EPSTEIN at his residences in Manhattan, New York, and Palm
Beach, Florida, after which he provided them with hundreds of
(1
dollars in cash for each encounter.
b. In or about 2002, Minor Victim?l was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the New York Residence over a
period of years and was paid hundreds of dollars for each
1
encounter. EPSTEIN also encouraged and enticed Minor Victim~
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim?l how old she was, and Minor
Victim~1 answered truthfully.
c. In or about 2004, Employee?1, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
telephone call to .
Minor Victim?l in order to schedule an
app01ntment for Minor Victim?1 to engage in paid sex acts with
EPSTEIN.
d. In or about 2004, Minor Victim-2 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars after each
encounter. EPSTEIN also encouraged and enticed Minor Victim-2
to recruit other girls to engage in paid sex acts, which she
did.
e. In or about 2005, Employee?2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim?2 in order to schedule an
appointment for Minor Victim?2 to engage in paid sex acts with
EPSTEIN.
f. In or about 2005, Minor Victim-3 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the balm Beach Residence over a
period of years and was paid hundreds of dollars for each
encounter. also encoUraged and enticed Minor Victim?3
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim?3 how old she was, and Minor
VictimvB answered truthfully.
g. In 0
about 2005, Employee?2, located in the
~southern Distri
Ct of New York, and on behalf of EPSTEIN, placed
a tele
one call to Minor Victim?3 in Florida in order to
schedul
an appOintment for Minor Victim?3 to engage in paid sex
acts with EPSTEIN.
h. In or about 2004, Employee?3 placed a
,telephone call to Minor Victimr3 in order to schedule an
appointment for Minor Victim?3 to engage in paid sex acts with'
(Title 18, United States Code, Section 371.)
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
23. The allegations contained in paragraphs 1
through 19 and 22 of this Indictment are repeated and realleged
as if fully set forth within.
24. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New
York, JEFFREY EPSTEIN, the defendant, willfully and knowingly,
in and affecting interstate and foreign commerce, did recruit,
entice, harbor, transport, provide, and obtain by any means a
person, knowing that the person had not attained the age of 18
years and would be caused to engage in a commercial sex act, and
did aid and abet the same, to wit, EPSTEIN recruited, enticed,
harbored, transported, provided, and obtained numerous
ll
_1imited to Minor Victim-l
a .
3 described above, and who were then
ause
engage in at least one commercial sex act
Manhattan, New York;
(Title 18, United States Code,
and 2.)
Sections 1591(a),
25. As a result of committing the offense alleged in
Count Two of this Indictment, JEFFREY EPSTEIN, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594(c)(l), any property, real and
personal, that was used or intended to be used to commit or to
facilitate the commission of the offense alleged in Count Two,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Two, or any property traceable to
such property, and the following specific prOperty:
a. The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 9 East 7lst Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
03) has been transferred or sold to
I
or deposited with, a
third person;
has been placed beyond the jurisdiction of the Court;
has been substantially diminished in value; or
Inns been commingled with other property which cannot
'be subdivided without difficulty;
it.ij3?bhe intent of the United States, pursuant to 21 U.S.C.
853(p) and 28 U.S.C. 2461(0), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853(p); and
Title 28, United States Code, Section 2461.)
MW {49%
United States Attorney
Form
No. (Ed 9 25 58
.
UNITED STATE
DISTRICT
V.
Defendant.
'w
(18 U.S.C. 371, 1591(a),
and 2)
-United States Attorney
Forepefgbn
l4