EFTA01703052

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: Il UNITE STATES OF AMERICA vs. JE EPSTEIN, and Defendants. 18 U.S.C. § 371 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 1591(aX2) 18 U.S.C. § 2422(b) 18 U.S.C. § 2423(b) 18 U.S.C. § 1591(aX1) T e Grand Jury charges that: 1 INDICTMENT BACKGRgUND i A all times relevant to this Indictment: 1.1 Defendant JEFFREY EPSTEIN employed defendants allda and among other things, services as personal assistants. to perform, EFTA01703052 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 of JEGE, 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 N908JE. 4. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 5. Defendant JEFFREY EPSTEIN was a principal owner of 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 Hyperion Air, Inc., and had the power to direct all of its operations. 7. Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older who engages in sexual activity with a person 16 or 17 years of age commits a felony of the second degree." For purposes of "this section, `sexual activity' means oral, anal, or vaginal penetration by, or union with, the sexual organ of another; however, sexual activity does not • include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide belief that such person is over the specified age [shall] be a defense." 2 EFTA01703053 8. Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult "who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious molestation," which is a felony of the second degree if the victim is 12 years of age or older but less than 16 years of age. 9. Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who [i]ntentionally touches" a person under 16 years of age in a lewd or lascivious manner or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or lascivious conduct," which is a felony of the second degree. 10. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who: (1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual physical or sexual contact with the victim, including, but not limited to . . . the simulation of any act involving sexual activity in the presence of a victim who is less than 16 years of age, commits lewd or lascivious exhibition," which is a felony of the second degree. 11. Pursuant to Florida Statutes Section 800.04(2), "[n]either the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]." 3 EFTA01703054 12. Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide belief of the victim's age cannot be raised as a defense in a prosecution under [Section 800.04]." 13. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical licensure. 14. During the period of their involvement with the Defendants, Jane Does # 3 and 10 attended in Palm Beach County. 15. During the periods of their involvement with the Defendants, Jane Does # 5, 6, 8, 12, 13, 14, 15, 16, 17, 18, and 19 attended in Palm Beach County. 16. During the period of her involvement with the Defendants, Jane Doe #7 attended in Palm Beach County. 17. During the period of her involvement with the Defendants, Jane Doe #9 attended in Palm Beach County. 18. During the period of her involvement with the Defendants, Jane Doe #11 attended in Palm Beach County. COUNT 1 (Conspiracy: 18 U.S.C. § 371) 4 EFTA01703055 19. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 20. From at least as early as 2001, the exact date being unknown to the Grand Jury, through in or around October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, i and 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, and entice individuals who had not attained the age of 18 years to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b). Purpose and Object of the Conspiracy 21. 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 5 EFTA01703056 22. 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 and would contact 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, and a/k/a would make payments to, or cause payments to be made to, minor females in exchange for engaging in lewd conduct (c) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, and a/lcia` would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, and a/k/a would make payments to, or cause payments to be made to, the recruiters for bringing additional 6 EFTA01703057 yvt. ety 0 A\ \( br‘ o (5) In or around 2001, Defendant steQ af jk.s .(Qocs 1t t G ecC31 placed a telephone call to a telephone used by Jane Doc #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. In or aro 02, Defe (7) In or around 209, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who would be interested in engaging in similar activities with him. (8) In or around 2003, Defendant took nude photographs ofJane Doe #2, who was then a sixteen-year-old girl. (9) In or around 2003, Defendant made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. (10) In or around 2003, Defendant told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked to take nude photographs ofJane Doe #2. (1c$- )n or around 2003, Defendant JEFFREY EPSTEIN in the presence ofJane Doe #2, who was then a sixteen-year-old girl. ierte ich 12),4 In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2, who was then a sixteen-year-old girl. 8 EFTA01703058 minor females to 358 El Brillo Way to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (e) It was further a part of the conspiracy that Defendant JEFFREY EPSTEIN would pay minor females to engage in lewd conduct with Defendant to satisfy Defendant JEFFREY EPSTEIN's prurient interests. Overt Acta 23. 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) In 2001, Defendant '—'-Jane Doe #2 eretherlaishem-si c OCc ck matermtraisty upstairs to Dcfeadant JEFFREY EPSTEIN's bedroom at 358 El Brillo 0 4( ay. 2) In the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in with Jane Doe #1, who was then a seventeen-year-old girl, in the presence of Jane Doc #2, who was then a fourteen-year-old girl. (3) In oll ' Itsl iMkendant JEFFREY EPSTEIN presence of Jane Doe #2, who was then a fourteen-year-old girl. (4) Int A— irMtdant JEFFREY EPSTEIN made a payment of OL( CA $300 to Jane Doe #2 7 n the 9Ct • v o r eh a cat*. va. 2-OC I Dalet-haat\. 17 TAP EP4cul ti ed Oott 2-, wt.* te4ks '3/4-Vsf•- ly Y ea.( s' °N.& +0 EFTA01703059 .;b, t- or zbo ps+L1/4 v. #±2 krit\ (_•.1C4- kie-4 AL•14-C-0.1"\ _ y cow- - ti EFTA01703060 (Te k 40V\`/ ) no f t (.. (fn. oo1/4...vc(....4.3 6 or C., v.:, 1-...P)°1) (13) In or around 2003, Defendant placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. (14) In or around 200), JEFFREY EPSTEIN engaged in / (4- with an unidentified female in the presence of Jane Doe #2, who was then a year-old girl. girl. • °Dews1/4 (1 5) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane v-a-p;w_\. Doe #2, who was then a stx4esh-yea.414-girl, for allowing an unidentified female to perform on Jane Doe #2 in EPSTEIN's presence. (16) In or around dairpIrf 2003, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #4, who was then a fifteen-year-old girl. (17) In or around t 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe ti4. (18) In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe #4, who was then a sixteen- or seventeen-year-old girl, to an adult female and to the adult female's (19) Ina' around 2004, Defendant JEFFREY EPSTEIN placed a of an adult female in the presence of Jane Doe #4, who was then sixteen- or seventeen-year-old girl. EFTA01703061 (20) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of 200 to Jane Doe /M. (21) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe girl. (22) In or around 2004, Defendant JEFFREY EPSTEIN placed a of Jane Doe #4, who was then a sixteen- or seventeen-year-old 2(a- 29 (231 In or around the first half of 2004, Defendant JEFFREY EPSTEIN -iskaikais"" offered to pay Jane Doe #6 to bring additional girls to 358 El Brillo Way. , ‘0, "(a) In or around ra 2004, Defendant made a payment of S200 to Jane Doe #6 for recruiting a minor female to travel to 358 El Brillo Way. lo t 25) In or around the Mnet half of 2004, Defendant JEFFREY EPSTEIN Jane Doe #8, who was then a seventeen-year-old girl. 26) On or about March 11, 2004, Defendants JEFFREY EPSTEIN, =I and traveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 0444 k raA. 0 icL7- 10 (./ EFTA01703062 3 Ci v cA. V1/4 (9... Ci s\--4 t Tatra &-e_ 4t(c) A e brk tcici-exun Qr %ex) -e kcirca elp 5 r( • 2_00 EFTA01703063 0 G r °Ai\ c. cc ) N p ivt4fckl 27) In or around March 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #5, who was then a seventeen-year-old girl, to travel to 358 El Brillo Way, Palm Beach, Florida. (28) In or around March 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #5, who was then a seventeen-year-old girl (29) In or around March 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Ja (3 On or about May , 2004, Defendant Beach County,-For laabc:rd the Boeing (31) On or about May 14, 2004, Defendants JEFFREY EPSTEIN, and traveled from Canada to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (32) On or about May 14, 2004, Defendant telephone call to a telephone used by Jane Doe #6. (33) In or around May 2004, Defendant led Jane Doe #6 placed a from the kitchen at 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. 11 EFTA01703064 (34) In or around May 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #6, who was then a sixteen-year-old girl. (35) In or around May 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe O. c—Sx (36) On or about June 11, 2004, Defendants JEFFREY EPSTEIN and traveled I go, IIlino to Palm Beach County, Florida L.— aboard the Gulfstream aircraft owned y H erion Air, Inc. (37) On or about June I._1, 0 , Defendant made one or 6 el II \N ) rajz' more telephone calls to a telephtt use ki Jane Doe #6. V'fr ) 5morc telephone calls to a telephWu d by Jane Doe #6. (38) On or about June 20, 2i 04 pcfendant made one or (39) On or about 2004 Defendants JEFFREY EPSTEIN and trave Lffom the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (40) On or about July 4, 2004, Defendants JEFFREY EPSTEIN, and traveled from Aspen, Colorado to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (41) On or about July 4, 2004, Defendant made one or more telephone calls to a telephone used by Jane Doe #7. 12 EFTA01703065 (42) In or around July 2004, Defendant JEFFREY EPSTEIN led Jane Doe #3, who was then a fifteen-year-old girl, and Jane Doe #7, who was then a sixteen- years-old girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (43) In or around July 2004, Defendant JEFFREY EPSTEIN the presence of Jane Doe #7, who was then a sixteen-year-old girl. (44) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #7, who was then a sixteen-year-old girl, (45) In or around July 2004, Defendant JEFFREY EPSTEIN EMcif Jane Doe #7, who was then a sixteen-year-old girl. (46) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #7. (47) In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe #7 that if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN's home, bad things could happen to her. (48) In or around July 2004, Defendant JEFFREY EPSTEIN of Jane Doe #8, who was then a seventeen-year-old girl. (49) In or around July 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #8, who was then a seventeen-year-old girl. 13 EFTA01703066 0 )t orvii 1/4-- (50) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of 5200 to Jane Doc #8. (51) On or about July 15, 2004, Defendant placed one or (7\e', more telephone calls to a telephone used by Jane Doc #7. 7.4? .//. CkiAA4)- ri) On or about July 15, 2004, Defendant ay- placed one or more telephone calls to a telephone used by Jane Doe #8. (53) On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. (54) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, and traveled from Teterboro. New Jersey to Palm Bcach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (55) On or about July 16, 2004, Defendant caused Jane Doe #8 to make one or more telephone calls to a telephone used by Jane Doe #9. ga, (56) On or about July 17, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #8. (57) On or about July 18, 2004, Defendant more telephone calls to a telephone used by Jane Doe #6. 14 placed one or EFTA01703067 Q,CL (58) On or about July 18, 2004, Defendant more telephone calls to a telephone used by Jane Doe #8. (59) On or about July 22, 2004, Defendant more telephone calls to a telephone used by Jane Doc #6. (60) On or about July 22, 2004, Defendant telephone call to a telephone used by Jane Doe #8. (61) On or about July 22, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #9. (62) On or about July 22, 2004, Defendants JEFFREY EPSTEIN, a and placed one or placed one or placed a traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (63) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and n the presence engaged in of Jane Doe O. who was then a seventeen-year-old girl. (64) In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly of Jane Doe #8, who was then a seventeen- year-old girl. (65) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 or more to Jane Doe #8. Ler - 15 EFTA01703068 (66) In or around the last half of 2004, Defendant JEFFREY EPSTEIN r ef.( endues. cr% Jane Doe #9, who was then a seventeen- r- 0 CA- Ow - k„.LA-Sf LA c) year-old girl. ‘f • 44C4 4..en-en tut3s (67) In or around the last half of 2004, efendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #9. o Tc".-b wko wi S •N. SCV44+cab-r-yeAtd& Z.Ve (68) In or around the last half of 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #10, who was then a seventeen-year-old girl. (69) In or around the last half of 2004, Defendant JEFFREY EPSTEIN Jane Doe h10, who was then a seventeen-year-old girl. (70) In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to of Jane Doe #10, who was then a seventeen-year-old girl. (71) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #10. (72) In or around the last half of 2004, Defendant led Jane Doe #I3 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (73) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked VJane Doe #13 to provide her telephone number. (74) In or around the last half of 2004, Defendant JEFFREY EPSTEIN (- instructed Jane Doe #13, who was then a seventeen-year-old girl, 16 EFTA01703069 C I:in. at " -": 3 A \ 'let 4 ea( -S \ La S t ,/t +t-c- c Se krto. -IrcateN - y ask s k . EFTA01703070 CO (75) (76) In or around the last half of 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #I3, who was then a seventeen-year old girl. In or around the last hal f of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #13. (77) On or about August 19, 2004, Defendants JEFFREY EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (78) On or about August 21, 2004, Defendant or more calls to a telephone used by Jane Doe #11. placed one (79) On or about August 25, 2004, Defendants JEFFREY EPSTEIN, and traveled from Ecuador to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (80) In or around the last quarter of 2004, Defendant caused Jane Doe #5 to place a telephone call to Jane Doe #12. (81) In or around the last quarter of 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #5 to travel with Jane Doe #12 to 358 El L.---- Brillo Way. (82) In or around the last quarter of 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #12, who was then a sixteen-year-old girl. (83) In or around the last quarter of 2004, Defendant JEFFREY EPSTEIN of Jane Doe #12, who was then a sixteen-year-old girl. 17 EFTA01703071 (84) In or around the last quarter of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doc #12. (85) In or around the last quarter of 2004, Defendant JEFFREY EPSTEIN caused a payment to be made to Jane Doe #5 for recruiting Jane Doc #12 to travel to 358 El Brillo Way. (86) On or about October 2, 2004, Defendants JEFFREY EPSTEN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (87) On or about October 29, 2004, Defendants JEFFREY EPSTEIN, , and traveled from Teterboro, New Jersey to Palm Bcach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, INC. (88) In or around the cnd of 2004, Defendant led Jane Doe #19, who was then a sixteen-year-old girl, from the kitchen of 358 El Brillo Way, upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (89) In or around the end of 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #19, who was then a sixteen-year-old girl. (90) In or around the end of 2004, Defendant JEFFREY EPSTF,IN made a payment of $200 to Jane Doe #19. 18 EFTA01703072 n or around the end of 2004, Defendant placed a teleP one call to a telephone used by Janc Doc 0/5 to arrange for Jane Doe #19 to travel to 358 El Brillo Way. (92) On or about November 10,2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (93) On or about November 18, 2004, Defendants JEFFREY EPSTEIN, a/Ida and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (94) In or around December 2004, Defendant caused Jane Doe #I2 to place a telephone call to Jane Doe #15. &Sint In or around December 2004, Defendant JEFFREY EPSTEIN Ow otc ..asaisposiamiliErf yment of S100 to Jane Doe #12 for bringing Jane Doe #15 to 358 El Brillo Way. (96) In or around December 2004, Defendant led Jane Doe #15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (97) In or around December 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #15, who was then a sixteen-year-old girl. (98) In or around December 2004, Defendant JEFFREY EPSTEIN ofJane Doe #15, who was then a sixteen-year-old girl. 19 EFTA01703073 In or around December 2004, Defendant JEFFREY EPSTEIN o ane oe 15, who was then a sixteen-year-old girl. (100) In or around December 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe 415, who was then a sixteen-year-old girl. (101) On or about December 3, 2004, Defendants JEFFREY EPSTEIN, and a/k/a " traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (102) On or about December 4, 2004, Defendant provided a written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 8 and 9, stating: "[Jane Doe #9] would like to work @ 4:00 pm if possible. [[Jane Doe #8] is scheduled for 5:00 today.] the movie is @ 7:30". (103) On or about December 6, 2004, Defendant placed one or more calls to a telephone used by Jane Doe #14. (104) On or about December 13, 2004, Defendant JEFFREY EPSTEIN traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (105) On or about December 17, 2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstrcam aircraft owned by Hyperion Air, Inc. 20 EFTA01703074 fq (106) On or about December 18, 2004, Defendant eatteed place one or more telephone calls to a telephone used by Jane Doe (t0- In or around the last half of 2004 or January 2005, Defendant then a seventee placed al_ ofiarre-Dote_p_t_who was ear-old girl, in the presence of Defendant JEFFREY EPSTEIN. (108) In or a last half of 2 nuary-2005,Delendanal efendant JEFFREY EPSTEIN performed'- in the presence of Jane Doe #9, who was then a seventeen-year-old girl. (109) In or around the end of 2004 and the beginning of 2005, Defendant Jane Doc #13, who was then a seventeen- JEFFREY EPSTEIN year-old girl. (110) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #13. (111) On or about December 29, 2004, Defendant a telephone call to a telephone used by Jane Doe #8. (112) On or about December 30, 2004, Defendant used a credit card to purchase Broadway tickets as an eighteenth birthday gift for Jane Doe #8. placed (113) On or about January 1, 2005, Defendants JEFFREY EPSTEIN,M. an 21 raveled from Anguilla, British West Indies EFTA01703075 to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (114) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed aafJane Doc #13, who was then a seventeen- V — year-old girl. (115) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged in girl. with Jane Doe 413, who was then a seventeen-year-old t — (116) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN performed on Jane Doe #13, who was then a seventeen-year-old girl. (117) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $600 to Jane Doe #13. (118) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #17 to place a telephone call to Jane Doe #18 to ask her to travel to 358 El Brillo Way. (119) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN °mac/ c1/4 e fret e4 prat to Jane Doe #17 for recruiting Jane Doe #18 to travel to 358 El Brillo Way. (120) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN in the presence of Jane Doe 418, who was then a sixteen-year-old girl. 22 EFTA01703076 (121) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doc #18, who was then a sixteen-year-old girl, to remove all of her clothing. (122) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a of Jane Doe #18, who was then a sixteen- year-old girl. (123) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #18, who was then a sixteen-year-old girl. (124) In or around the first half of 2005, Defendant made a payment of $200 to Jane Doe #6 for recruiting another minor female to travel to 358 El Brillo Way. (125) In or around the first half of 2005, Defendant led Jane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (126) In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe 414, who was then a seventeen-year-old girl, (127) In or around the first half of 2005, Defendant JEFFREY EPSTEIN of Jane Doe #14. (128) In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #I4. Vr V". 23 EFTA01703077 #14. (129) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN lof Jane Doe #I7, who was then a seventeen- year-old girl. (130) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN lof Jane Doe #17, who was then  a seventeen-year-old girl. (131) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Janc Doc #17, who was then a seventeen-year-old girl, how old she was. CYD*Ci cal s. 4 war /7 (132) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN with Defendan in the v „.. presence of Jane Doe #17, who was then a seventeen-year-old girl. (133) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #17, who was then a seventeen-year-old girl, to MEof Defendant (134) On or about January 6, 2005, Defendant JEFFREY EPSTEIN traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (135) On or about January 7, 2005, Defendant placed one or more calls to a telephone used by Jane Doe 24 EFTA01703078 Jersey to Palm Beach County, Florida, aboard the Gulfstrcam aircraft owned by Hyperion Air, Inc. 168) In or around hileramleaft, Pendant JEFFREY EPST Jane Doe #1 I, who was then a seventeen-year-old girl. (169) On or about March 1, 2005, Defendant ailda placed one or more telephone calls to a telephone used by Jane Doe #13. (170) On or about March 4, 2005, Defendants JEFFREY EPSTEIN, a/k/al " andl traveled L---- from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (171) On or about March 16, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #13. (172) On or about March 17, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #14. (173) On or about March 18, 2005, Defendant JEFFREY EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (174) On or about March 18, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN regarding Jane Doe #6, stating: "Is it ok if [Jane Doe #6] will come at 5?" 29 EFTA01703079 (143) On or about January 28, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #9. placed one (144) In or around the February 2005, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #8 for recruiting Jane Doe #.61,4 to travel to 358 El Brillo Way. $ (145) In or around Feltmmeeriiii4s Defendants JEFFREY EPSTEIN and Brillo Way. caused Jane Doe 4-10 to recruit Jane Doe #11 to travel to 358 El 4 1-^N., LA+. t'"'"•••4 (1 2d dif (146) In or around r-'- , efendant JEFFREY EPSTEIN of Janc Doe 411, who was then a seventeen-year-old girl. 4-tc o -tow+ k- (147) In or around fegatorpillibi, fend'Ant JEFFREY EPSTEIN of Jane Doe #11, who was thcn a seventeen-year-old girl. 1414 —Pe Ot itt /LW -- 148) acto 4 -fondant JEFFREY EPSTEIN made a payment of $200 to Jane Doe 411. (149) On or about February 1, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #13. (150) On or about February 1, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #9. placed one c.^ 26 EFTA01703080 (151) On or about February 3, 2005, Defendants JEFFREY EPSTEIN, and traveled from Columbus, Ohio, to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (152) On or about February 4, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe 414. (153) On or about February 6, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #5 to make one or more telephone calls to Jane Doe #16. (154) On or about February 6, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #5 to transport Jane Doc #16 to 358 El Brillo Way, Palm Beach, Florida. (155) On or about February 6, 2005, Defendant JEFFREY EPSTEIN lofJane Doe 416, who was then a fourteen-year-old girl. (156) On or about February 6, 2005, Defendant JEFFREY EPSTEIN Jane Doe #16, who was then a fourteen-year-old girl. (157) On or about February 6, 2005, Defendant JEFFREY EPSTEIN placed of Jane Doe 416, who was then a fourteen-year-old girl. (158) On or about February 6, 2005, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #16. 27 \/. EFTA01703081 (159) On or about February 6, 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #5. (160) On or about February 10, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #13. (161) On or about February 10, 2005, Defendants JEFFREY EPSTEIN, a/k/a " and raveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (162) On or about February 10, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #14. (163) On or about February 21, 2005, Defendant placed one or more telephone calls to a telephone used by Jane (164) On or about February 21, 2005, Defendants and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (165) On or about February 23, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #4. CC,,.) (166) On or about February 24, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #14. (167) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New 28 EFTA01703082 (136) On or about January 8. 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #13. (137) On or about January 9, 2005, Defendant aqua 'placed one or more telephone calls to a telephone used by Jane Doe #13. (138) On or about January 14, 2005, Defendant placed telephone call to a telephone used by Jane Doe #4. (139) On or about January 14, 2005, Defendants JEFFREY EPSTEIN, a/k/a " and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE. INC. (140) On or about January 14, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #9. (141) On or about January 19, 2005, Defendants JEFFREY EPSTEIN, a/k/a "I and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (142) On or about January 27, 2005, Defendant a/k/a ' placed one or more telephone calls to a telephone used by Jane Doe #9. 25 EFTA01703083 (175) On or about March 21, 2005, Defendant a/kJa placed one or more telephone calls to a telephone used by Jane Doe #13. (176) On or about March 29, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #6. (177) On or about March 29, 2005, Defendantl or more telephone calls to a telephone used by Jane Doe #5. (178) On or about March 29, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #13. (179) On or about March 30, 2005, Defendant or more calls to a telephone used by Jane Doe #5. (180) On or about March 30, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #14. (181) On or about March 31, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #14. (182) On or about March 31, 2005, Defendant or more calls to a telephone used by Jane Doe #5. (183) On or about March 31, 2005, Defendant Doe #14. placed one placed one placed one placed one placed one , placed one iplaced one a/k/a placed one or more telephone calls to a telephone used by Jane 30 EFTA01703084 (184) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled t".. .....„„ from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (1 (185) On or about March 31, 2005, Defendants JEFFREY EPSTEIN and .> b Urd 16. caused Jane Doe #5 to make a call to a telephone used by Jane Doe SVit(186) On or about April 1, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #5 to make one or more calls to a telephone used  by Jane Doe #16. (187) On or about April 2,2005, Defendant a/k/a "= placed one or more telephone calls to a telephone used by Jane Doe #17. (188) On or about May 19, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #17. (189) On or about May 19, 2005, Defendants JEFFREY EPSTEIN, a and a/kila " traveled from "Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (190) On or about June 30, 2005, Defendant caused one or more telephone calls to a telephone used by Jane Doe #17. 31 EFTA01703085 (191) On or about June 30, 2005, Defendants JEFFREY EPSTEIN and 4./ traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. .-0-a-- (192) In or around July 2 tefendant led Jane Doe /) from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (193) On or about July 2, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe it17. (194) On or about July 22, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #17. (195) On or about July 22, 2005, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (196) On or about August 18, 2005, Defendants JEFFREY EPSTEIN, a/k/a and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (197) On or about August 18, 2005, Defendant Placed one or more telephone calls to a telephone used by Jane Doe #17. 32 EFTA01703086 (198) On or about August 19, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe #17. (199) On or about August 21, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #17. (200) On or about September 3, 2005, Defendants JEFFREY EPSTEIN and a/k/a traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (201) On or about September 3, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe #17. (202) On or about September 18, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #17. (203) On or about September 18, 2005, Defendants JEFFREY EPSTEIN, and a/k/a traveled from Westchester County, New York to Palm Beach.County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (204) On or about Septembe 2005, Defendant sent a text message to a telephone used by Jane Doe #17. t/ 33 EFTA01703087 (205) On or about September 29, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #17. (206) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, a/k/a an traveled from Teterbbro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (207) On or about September 30, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe #17. (208) On or about October 1, 2005, Defendant telephone message for Defendant JEFFREY EPSTEIN stating: confirmed at 11 AM and [Jane Doe #17] — 4PM". (209) On or about October 2, 2005, Defendant or more telephone calls to a telephone used by Jane Doe #17. (210) On or about October 3, 2005, Defendant- or more telephone calls to a telephone used by Jane Doe #17. (211) On or about October 3, 2005, Defendant left a "[Jane Doe #14] placed one caused one left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #17] will be'''/ hour late". 34 L EFTA01703088 EPSTEIN engaged in seventeen-year-old girl. (213) In or around the first week of October of 2005, Defendant JEFFREY EPSTEIN made a payment of $350.00 to Jane Doe #17, who was then a seventeen- year-old girl. All in violation of Title 18, United States Code, Sections 371 and 2. (212) In or around the first week of October of 2005, Defendant JEFFREY with Jane Doe #17, who was then a 35 EFTA01703089 COUNT 2 (Conspiracy to Travel: 18 U.S.C. § 2423(e)) 24. Paragraphs 1 through 19 of this indictment are re-alleged and incorporated by reference as fully set for the herein. 25. From at least as early as 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, the defendants, JEFFREY EPSTEIN, aus and 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 U.S.C. § 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 U.S.C. § 2423(d)) 26. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 27. From at least as early as in or about 2001 through in or around 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, 36 EFTA01703090 did, for the purpose of commercial advantage or private financial gain, arrange and 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 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d). COUNT 4 (Sex Trafficking: 18 U.S.C. § 1591(a)(2)) 28. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 29. From at least as early as in or about 2001 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, and did knowingly benefit, financially or by receiving anything of value, from participation in a venture, as defined in 18 U.S.C. § 1591(c)(3), which had engaged in an act described in violation of 18 U.S.C. § 1591(a)(1), that is, the recruiting, enticing, providing, and obtaining by any means a person, in or affecting interstate commerce, knowing that the person or persons had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(2), 1591(b)(2), and 2. 37 EFTA01703091 COUNT 5 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 30. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 31. From in or around the spring of 2003 through on or about October 2, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #4, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is violations of Florida Statutes Sections 800.04(5)(a), 800.04(6)(a), and 800.04(7)(a); in violation ofTitle 18, United States Code, Sections 2422(b) and 2. COUNT 6 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 32. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 33. In or around March 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, 38 EFTA01703092 JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #5, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 7 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 34. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 35. From in or around April 2004 through on or around June 29, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a did use a facility or means of intestate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #6, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title .18, United States Code, Sections 2422(b) and 2. COUNT 8 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 39 EFTA01703093 36. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 37. In or around July 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate conunerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #7, who was a person who had not attained .the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 9 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 38. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 39. From in or around July 2004 through on or around December 29, 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and 40 EFTA01703094 did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #8, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 10 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 40. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 41. From in or around July 2004 through on or about January 31, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #9, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. 41 EFTA01703095 COUNT 11 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 42. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 43. From in or around the middle of 2004 through on or about April 22, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #10, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 12 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 44. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 45. From in or around August 2004 through on or about May 27, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a/k/a 42 EFTA01703096 did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #11, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 13 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 46. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 47. From in or around November 2004 through in or around March 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a/k./a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #13, who was a person who had not attained the age of 18 years, to engage in prostitution and• in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 48. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 43 EFTA01703097 49. From in or around December 2004 through on or about June 5, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a/k/a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #14, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 15 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 50. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 51. In or around December 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #15, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. 44 EFTA01703098 COUNT 16 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 52. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 53. In or around February 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #16, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which any person can be charged with a criminal offense, that is violations of Florida Statutes Sections 800.04(5)(a), 800.04(6)(a), and 800.04(7)(a); in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 17 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 54. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 55. From in or around February 2005 through in or around the first week of 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, 45 EFTA01703099 JEFFREY EPSTEIN, and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce or entice Jane Doe #17, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 18 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 56. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 57. From in or around February 2005 through in or around April 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #18, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. 46 EFTA01703100 COUNTS 19 THROUGH 22 (Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b)) 58. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 59. 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 U.S.C. § 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) 19 7/16/2004 Jane Doe #7 Jane Doe #8 Jane Doe #9 aaJEFFREY EPSTEIN 20 3/31/2005 Jane Doe #6 Jane Doe #13 Jane Doe #14 Jane Doe #16 Jane Doe #17 JEFFREY EPSTEIN a/ la 21 9/18/2005 Jane Doe #17 JEFFREY EPSTEIN I a/k/ 22 9/29/05 Jane Doe #17 JEFFREY EPSTEIN a All in violation of Title 18, United States Code, Sections 2423(b) and 2. 47 EFTA01703101 COUNTS 23 THROUGH 32 (Sex Trafficking: 18 U.S.C. § 1591(a)(1)) 60. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 61. 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, recniit, 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 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1): COUNT DATE(S) MINOR(S) INVOLVED DEFENDANT(S) 23 2001 - 2004 Jane Doe #2 JEFFREY EPSTEIN 24 April 2004 through June 29, 2005 Jane Doe #6 JEFFREY EPSTEIN ela 25 —Jittr2e04—_____linenop to JIIFFILEY EPSTEIN 26 July 2004 through December 29, 2004 Jane Doe #8 JEFFREY EPSTEIN a 6/3/0s. Ale -9 At4 48 EFTA01703102 COUNT DATE(S) MINOR(S) INVOLVED DEFENDANT(S) 27 July 2004 through January 31, 2005 Jane Doe #9 JEFFREY EPSTEIN aflo a ' ahtertitItirMSte) 1/26.4 28 Mid-2004 through April 22, 2005 Jane Doe #10 JEFFREY EPSTEIN 29 August 2004 through May 27, 2005 Jane Doe #11 JEFFREY EPSTEIN 30 November 2004 through March 2005 Jane Doc #13 JEFFREY EPSTEIN 31 December 2004 through June 5, 2005 Jane Doe #14 JEFFREY EPSTEIN 32 February 2005 through first week of October 2005 Jane Doe #17 JEFFREY EPSTEIN All in violation of Title 18, United States Code, Sections 1591(a)( 1 ) and 2. FORFEITURE I Upon conviction of the violation alleged in Count 1 of this indictment, the defendants, JEFFREY EPSTEIN, a/Idal nd shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. 49 EFTA01703103 Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21, United States Code, Section 853. If the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, anda clEMIE and (1) cannot be located upon the exercise of due diligence; (2) has been transferred or sold to, or deposited with a third person; (3) has been placed beyond the jurisdiction of the Court; (4) has been substantially diminished in value; or (5) has been commingled with other property which cannot be subdivided without difficulty; . it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendants up to the value of the above forfeitable property. All pursuant to Title 28 United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21 United States Code, Section 853. FORFEITURE 2 Upon conviction of any of the violations alleged in Counts 2, 3, 5-22, of this indictment, the defendants, JEFFREY EPSTEIN, a/k/a and shall forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other proceeds 50 EFTA01703104 obtained from such offense; and any property, real or personal, used or intended to be used to commit or to promote the commission of such offense, inclUding but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and. BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 2253. If any of the forfeitable property described in the forfeiture section of this indictment, as a result of any act or omission of the defendants JEFFREY EPSTEIN, ailda la and (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third person; (c) has been placed beyond the jurisdiction of the Court; (d) his been substantially diminished in value; or 51 EFTA01703105 (e) has been commingled with other property which cannot be divided without difficulty; .it is the intent of the United States, pursuant to Title 18, United States Code, Section 2253(o), to seek forfeiture of any other property of said defendant up to the value of the above forfeitable property. Pursuant to Title 18, United States Code, Section 2253. FORFEITURE 3 Upon conviction of any of the violations alleged in Counts 4, 23-32, of this indictment, the defendants, JEFFREY EPSTEIN, anda and shall forfeit to the United States any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such violation; and any property, real or personal, constituting or derived from any proceeds that such person obtained, directly or indirectly, as a result of such violation, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all. buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the 52 EFTA01703106 West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 1594(b). ATIJE AFT FOREPERSON DRAFT R. ALEXANDER ACOSTA UNITED STATES ATTORNEY DRAFT ASSISTANT UNITED STATES ATTORNEY 53 EFTA01703107