EFTA01713827

TANT STATES ATTORNEY 50 EFTA01713827 3 Vitc, 15 c . 16 1-i at C < scite0- ock: OA/ EFTA01713828 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 18 U.S.C. § 371 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 1591(a)(2) 18 U.S.C. § 2422(b) 18 U.S.C. § 2423(b) 18 U.S.C. § 1591(a)(1) UNITED STATES OF AMERICA, vs. JEFFREY EPSTEIN, anda and Defendants. INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defendant JEFFREY EPSTEIN employed defendants alida and to perform, among other things, services as personal assistants. EFTA01713829 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 EFTA01713830 8. Beginning in 2002, pursuant to Florida Statutes Section 796.07(2)(a), it was unlawful for a person to "offer, or to offer or agree to secure, another for the purpose of prostitution or for any other lewd or indecent act." 9. Beginning in 2002, pursuant to Florida Statutes Section 796.07(2)(e), it was unlawful for a person to "offer to commit, or to commit, or to engage in, prostitution, r lewdness, or assignation." 10. Beginning in 2002, pursuant to Florida Statutes Section 96.07(21(f), it was unlawful fbr a person to "solicit, induce, entice, or procure another to comma prostitution, lewdness, or assignation." 11. Beginning in 2002, pursuant to Florida Statutes Section 796.07(2)(i), it was unlawful for a person to "purchase the services of any person engaged in prostitution." 12. For purposes of Florida Statutes Section 796.07, "prostitution" is defined as "the giving or receiving of the body for sexual activity for hire but excludes sexual activity between spouses"; "sexual activity" is defined as "oral, anal, or vaginal penetration by, or union with, the sexual organ of another; anal or vaginal penetration of another by any other object; or the handling or fondling of the sexual organ of another for the purpose of masturbation; however, the term does not include acts done for bona fide medical purposes." Fl. Stat. 796.07(1)(a), 796.07(1)(d). 3 EFTA01713831 13. For purposes of Florida Statutes Section 796.07, "lewdness" is defined as "any indecent or obscene act;" and "assignation" is defined as "the making of any appointment or engagement for prostitution or lewdness, or any act in furtherance of such appointment or engagement." Fl. Stat. 796.01(b), 796.01(c). 14. Pursuant to Florida Statutes Section 800.04(4)(a), a person who "[e]ngages in sexual activity with a person 12 years of age or older but less than 16 years of age" commits lewd or lascivious battery, which is a felony of the second degree. 15. Pursuant to Florida Statutes Section 800.04(4)(b), a person who "[e]ncourages, forces, or entices any person less than 16 years of age to engage in . . . prostitution, or any other act involving sexual activity commits lewd or lascivious battery, a felony of the second degree." 16. 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. 17. 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 4 EFTA01713832 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. 18. 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. 19. 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]." 20. 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]." 21. Pursuant to Florida Statutes Section 800.02, a "person who commits any unnatural and lascivious act with another person commits a misdemeanor of the second degree." 5 EFTA01713833 i.v 22. Defendants JEFFREY EPSTEIN and ere over the age of 24 and did not have any medical training or licensure. 23. During the periods of their involvement with the Defendants, Jane Does # c -attended in Palm Beach County. 24. During the period of her involvement with the Defendants, Jane Doe # attended in Palm Beach County. 25. During the period of her involvement with the Defendants, Jane Doe # attended of in Palm Beach County. 26. During the period of their involvement with the Defendants, Jane Does # attended in Palm Beach County. 27. During the periods of their involvement with the Defendants, Jane Does # attended in Palm Beach County. COUNT 1, (Conspiracy: 18 U.S.C. § 371) 28. Paragraphs 1 through of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 29. From at least as early as 2001, 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, 6 EFTA01713834 JEFFREY EPSTEIN, Ira/k/E=MI' 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 30. 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 31. 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 ailda ana would contact minor females via the use of cellular and other telephones to arrange appointments for minor 7 EFTA01713835 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/k/a 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 afk/a 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. (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 Acts EFTA01713836 32. In furtherance of this conspiracy and to effect die 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 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 Doe #2, who was then a fourteen-year-old girl. (2) In 2001, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (3) In 2001, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a fourteen-year-old girl. (4) In 2001, 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. (5) In 2002, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a fifteen-year-old girl. (6) In 2002, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a fifteen-year-old girl. 9 EFTA01713837 (7) In 2002, 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. (8) In 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a sixteen-year-old girl. (9) In 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a sixteen-year-old girl. (10) In 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. (11) In or around 2003, Defendant JEFFREY EPSTEIN made a payment to Jane Doe #2, who was then a sixteen-year-old girl, to induce her to engage in a sexual performance with an adult female in his presence. (12) On or about March 11, 2004, Defendants JEFFREY EPSTEIN,= and traveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 10 EFTA01713838 (13) In or around March 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe # 7= who was then a seventeen-year-old girl, to travel to 358 El Brillo Way, Palm Beach, Florida. (14) In or around March 2004, Defendant JEFFREY EPSTEB' in the presence of Jane Doe #5. I who was then a seventeen-year-old girl. (15) In or around March 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe # 5. EMI (16) On or about May 1, 2004, Defendants JEFFREY EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (17) On or about May 14, 2004, Defendants JEFFREY EPSTEIN, I= and traveled from Canada to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (18) On or about May 14, 2004, Defendant placed a telephone call to a telephone used by Jane Doe # (19) In or around May 2004, Defendant led Jane Doe # 161M to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (20) In or around May 2004, Defendant JEFFREY EPSTEIN- in the presence of Jane Doe # (47° I= who was then a sixteen-year-old girl. 11 EFTA01713839 (21) In or around May 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe # La (22) On or about June 11, 2004, Defendants JEFFREY EPSTEIN and traveled from Chicago, Illinois to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (23) On or about June 11, 2004, Defendant aide one or more telephone calls to a telephone used by Jane Doe # T im (24) On or about June 20, 2004, Defendant =made one or more telephone calls to a telephone used by Jane Doe # (25) On or about June 20, 2004, Defendants JEFFREY EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. • (26) 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. (27) On or about July 4, 2004, Defendant made one or more telephone calls to a telephone used by Jane Doe # (28) In or around July 2004, Defendant JEFFREY EPSTEIN led Jane Doe #3_m who was then a fifteen-year-old girl, and Jane Doe #411 , 12 EFTA01713840 who was then a sixteen-years-old girl, from the kitchen of 358 El Brillo Way, upstairs to the master bedroom of 358 El Brillo Way. (29) In or around July 2004, Defendant JEFFREY EPSTEen the presence of Jane Doe # 11 11M, who was then a sixteen-year-old girl. (30) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe # , who was then a sixteen-year-old girl, to (31) In or around July 2004, Defendant JEFFREY EPSTEIN )f Jane Doe #e[17 , who was then a sixteen-year-old girl. (32) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe # (33) In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe 1 # that if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN's home, bad things could happen to her. (34) On or about July 15, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (35) On or about July 15, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe # [SM. (36) On or about July 16, 2004, Defendant placed one or MS more telephone calls to a telephone used by Jane Doe # 13 EFTA01713841 (37) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, a and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (38) On or about July 16, 2004, Defendant WoeI #1 to make one or more telephone calls to a telephone used by JanecaDusoeed i Jan a n. (39) On or about July 17, 2004, Defendant aplaced one or more telephone calls to a telephone used by Jane Doe # [MS. (40) On or about July 18, 2004, Defendant elaced one or more telephone calls to a telephone used by Jane Doe # (41) On or about July 18, 2004, Defendant laced one or more telephone calls to a telephone used by Jane Doe # (42) On or about July 22, 2004, Defendant •laced one or more telephone calls to a telephone used by Jane Doe # (43) On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe # (44) On or about July 22, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe # DS 14 EFTA01713842 (45) On or about July 22, 2004, Defendants JEFFREY EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (46) 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. (47) 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. (48) On or about September 16, 2004, Defendants JEFFREY EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (49) On or about October 2, 2004, Defendants EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (50) On or about October 29, 2004, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New 15 EFTA01713843 Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, INC. (51) 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. (52) On or about November 18, 2004, Defendants JEFFREY EPSTEIN, a/k/a `Ml . and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (53) 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. (54) On or about December 4, 2004, Defendant :)rovided a written message to Defendant JEFFREY EPSTEIN regarding Jane Doe # and Jane Doe # I stating: "[Jane Doe # I would like to work @ 4:00 pm if possible. [Jane Doe # 1 M is scheduled for 5:00 today.] the movie is @ 7:30". (55) 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. 16 EFTA01713844 (56) On or about December 17, 2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (57) On or about December 18, 2004, Defendant caused Jane Doe #10 to place one or more telephone calls to a telephone used by Jane Doe (58) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe # (59) On or about December 29, 2004, Defendant placed a telephone call to a telephone used by Jane Doe # (60) On or about January 1, 2005, Defendants JEFFREY EPSTEIN,I= anS traveled from Anguilla, British West Indies to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (61) 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. (62) On or about January 8, 2005, Defendant laced one or more telephone calls to a telephone used by Jane Doe # [=. 17 EFTA01713845 (63) On or about January 9, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe # (64) On or about January 14, 2005, Defendants JEFFREY EPSTEIN, afida ' and a traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (65) On or about January 14, 2005, Defendant_Mplaced one or more telephone calls to a telephone used by Jane Doe # [I= (66) On or about January 19, 2005, Defendants JEFFREY EPSTEIN, aAda and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (67) On or about January 27, 2005, Defendant I= a/lc/a placed one or more telephone calls to a telephone used by Jane Doe # [M. (68) On or about January 28, 2005, Defendant= Mlaced one or more telephone calls to a telephone used by Jane Doe # (69) On or about February 1, 2005, DefendantM placed one or more telephone calls to a telephone used by Jane Doe # I 18 EFTA01713846 (70) On or about February 1, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (71) 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. (72) On or about February 4, 2005, Defendant elaced one or more telephone calls to a telephone used by Jane Doe # (73) On or about February 6, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe # I to make one or more telephone calls to Jane Doe # I (74) On or about February 6, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe # I to transport Jane Doe # I to 358 El Brillo Way, Palm Beach, Florida. (75) On or about February 6, 2005, Defendant JEFFREY EPSTEIN in the presence of Jane Doe # who was then a fourteen-year- old girl. (76) On or about February 6, 2005, Defendant JEFFREY EPSTEIN Jane Doe # who was then a fourteen-year-old girl. (77) On or about February 6, 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe # who was then a fourteen- year-old girl. 19 EFTA01713847 (78) On or about February 6, 2005, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe # (79) On or about February 6, 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe # (80) On or about February 10, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (81) On or about February 10, 2005, Defendants JEFFREY EPSTEIN, a/k/a and traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (82) On or about February 10, 2005, Defendant paced one or more telephone calls to a telephone used by Jane Doe # (83) On or abotit February 21, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (84) 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 JEGE, INC. (85) On or about February 24, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (86) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New 20 EFTA01713848 Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (87) On or about March 1, 2005, Defendant I= a/Ida placed one or more telephone calls to a telephone used by Jane Doe # [MI (88) On or about March 4, 2005, Defendants JEFFREY EPSTEIN, a/k/a and NADIA traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (89) On or about March 16, 2005, Defendant laced one or more telephone calls to a telephone used by Jane Doe # (90) On or about March 17, 2005, Defendant laced one or more telephone calls to a telephone used by Jane Doe # (91) 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. (92) On or about March 18, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN regarding Jane Doe # is stating: "Is it ok if [Jane Doe # 1 will come at 5?" 21 EFTA01713849 (93) On or about March 21, 2005, Defendant S ailda placed one or more telephone calls to a telephone used by Jane Doe # (94) On or about March 29, 2005, Defendant laced one or more telephone calls to a telephone used by Jane Doe # (95) On or about March 29, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # [a (96) On or about March 29, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (97) On or about March 30, 2005, la placed one or more calls to a telephone used by Jane Doe # (98) On or about March 30, 2005, Defendant =placed one or more telephone calls to a telephone used by Jane Doe # (99) On or about March 31, 2005, Defendant aplaced one or more telephone calls to a telephone used by Jane Doe # (100) On or about March 31, 2005, Defendant placed one or more calls to a telephone used by Jane Doe # [a (101) On or about March 31, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (102) On or about March 31, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # 22 EFTA01713850 (103) On or about March 31, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe # (104) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (105) On or about March 31, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe # I to make a call to a telephone used by Jane Doe # (106) On or about 1, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe # to make one or more calls to a telephone used by Jane Doe # [M. (107) On or about April 1, 2005, Defendant elaced one or more telephone calls to a telephone used by Jane Doe # (108) On or about April 2, 2005, Defendant a/lc/a` placed one or more telephone calls to a telephone used by Jane Doe # (109) On or about April 2, 2005, Defendant . a/k/a `= placed one or more telephone calls to a telephone used by Jane Doe # 23 EFTA01713851 (110) On or about May 19, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (111) On or about May 19, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (112) On or about May 19, 2005, Defendants JEFFREY EPSTEIN, and S ailda traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (113) On or about June 30, 2005, Defendant caused one or more telephone calls to a telephone used by Jane Doe # (114) On or about June 30, 2005, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (115) On or about July 2, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (116) On or about July 22, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe. # (117) 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. 24 EFTA01713852 (118) On or about August 18, 2005, Defendants JEFFREY EPSTEIN, a/k/a " anc= traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (119) On or about August 18, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # [M. (120) On or about August 19, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe # [M. (121) On or about August 21, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (122) 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. (123) On or about September 3, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe # • (124) On or about September 18, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # 25 EFTA01713853 (125) On or about September 18, 2005, Defendant- one or more telephone calls to a telephone used by Jane Doe # (126) On or about September 18, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # I (127) On or about September 18, 2005, Defendants JEFFREY EPSTEIN, I placed and = a/k/a ` . traveled from Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (128) On or about September 18, 2005, Defendant sent a text message to a telephone used by Jane Doe # a (129) On or about September 18, 2005, Defendant sent a text message to a telephone used by Jane Doe # I (130) On or about September 29, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # I (131) On or about September 29, 2005, Defendant_ placed one or more telephone calls to a telephone used by Jane Doe # I (132) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, afk/a ' an traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 26 EFTA01713854 (133) On or about September 30, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe #[s (134) On or about September 30, 2005, Defendant a/k/a placed one or more telephone calls to a telephone used by Jane Doe # (135) On or about October 1, 2005, Defendants or more telephone calls to a telephone used by Jane Doe # (136) On or about October 1, 2005, Defendant- message to a telephone used by Jane Doe # (137) On or about October 1, 2005, Defendant placed one sent a text left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe # [la confirmed at 11 AM and [Jane Doe # — 4PM". (138) On or about October 2, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (139) On or about October 2, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (140) On or about October 2, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # [M. (141) On or about October 3, 2005, Defendant caused one or more telephone calls to a telephone used by Jane Doe # 27 EFTA01713855 (142) On or about October 3, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe # I will be 1/4 hour late". (143) On or about October 4, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe # (144) On or about October 4, 2005, Defendant -placed one or more telephone calls to a telephone used by Jane Doe # All in violation of Title 18, United States Code, Sections 371 and 2. COUNT 2 (Conspiracy to Travel: 18 U.S.C. § 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 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, the defendants, JEFFREY EPSTEIN, 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). 28 EFTA01713856 COUNT 3 (Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d)) 14. Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 15. 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, 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 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(0(2)) 16. Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 17. 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 29 EFTA01713857 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, or 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. COUNT 5 (Enticement of a Minor: 18 U.S.C. § 2422(b)) #. Paragraphs 1 through of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. #. 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, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce or entice Jane Doe # 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. 30 EFTA01713858 COUNTS 5 THROUGH16 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 18. Paragraphs 1 through of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 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 3/7/2004 - 3/11/2004 Jane Doe # I JEFFREY EPSTEIN 6 2/5/2005 - 2/6/2005 Jane Doe tt I JEFFREY EPSTEIN 7 12/6/2004 - 6/2/2005 Jane Doe # I ► JEFFREY EPSTEIN ME 8 4/25/2004 - 6/29/2005 Jane Doe # MI JEFFREY EPSTEIN =. 1 9 11/14/04 - 3/29/05 Jane Doe # I JEFFREY EPSTEIN 31 EFTA01713859 COUNT DATE(S) MINOR INVOLVED DEFENDANT(S) 10 7/15/04 - 12/29/04 Jane Doe # I JEFFREY EPSTEIN 11 7/22/04 - 1/31/05 Jane Doe # [ I ' JEFFREY EPSTEIN I 12 2/13/05 - 10/3/05 Jane Doe # = JEFFREY EPSTEIN I 13 2/05 - 4/05 Jane Doe # [I= I JEFFREY EPSTEIN I 14 12/18/04 Jane Doe # [IM I JEFFREY EPSTEIN 15 7/4/04 - 7/19/04 Jane Doe ii I JEFFREY EPSTEIN 16 8/21/04 - 5/27/05 Jane Doe # I JEFFREY EPSTEIN I 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 U.S.C. § 2423(b)) 20. Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 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 32 EFTA01713860 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: FOUNT DATE(S) MINOR(S) INVOLVED DEFENDANT(S) 7/16/2004 Jane Doe # Jane Doe # Jane Doe # JEFFREY EPSTEIN 3/31/2005 Jane Doe # Jane Doe # Jane Doe # JEFFREY EPSTEIN afla 9/18/2005 Jane Doe # JEFFREY EPSTEIN alla 9/29/05 le JEFFREY EPSTEIN a/lc/ All in violation of Title 18, United States Code, Sections 2423(b) and 2. COUNTS 51 THROUGH 58 (Sex Trafficking: 18 U.S.C. § 1591(a)(1) 22. Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 33 EFTA01713861 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 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) 51 12/6/2004 - Jane Doe # I JhF1'REY EPSTEIN 6/2/2005 a 52 4/25/2004 - Jane Doe # I JEFFREY EPSTEIN 6/29/2005 i a/k/a 53 11/14/2004 - Jane Doe V JEFFREY EPSTEIN 3/29/2005 I a/c/ 54 7/15/2004 - Jane Doe # [... JEFFREY EPSTEIN 12/29/2004 55 7/22/2004 - Jane Doe # I JEFFREY EPSTEIN 1/31/2005 I a/lcia EFTA01713862 COUNT DATE(S) MINOR(S) INVOLVED DEFENDANT(S) 56 2/13/2005 - 10/3/2005 Jane Doe # [IM JEFFREY EPSTEIN i a• 57 7/4/2004 - 7/19/2004 Jane Doe # I JEFFREY EPSTEIN 58 8/21/2004 - 5/27/2005 Jane Doe # I JEFFREY EPSTEIN a/k/a ' All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2. 35 EFTA01713863 COUNT 60 (Attempted Enticement of a Minor: 18 U.S.C. § 2422(b)) 26. Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 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 if I 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. FORFEITURE 1 Upon conviction of the violation alleged in Count 1 of this indictment, the defendants, JEFFREY EPSTEIN, a/k/a and shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. 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 36 EFTA01713864 omission of the defendants, JEFFREY EPSTEIN, anda "==ni and==M' (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, 5-50, 59, 60, of this indictment, the defendants, JEFFREY EPSTEIN, a/Ida ,,, and shall forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other proceeds 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: 37 EFTA01713865 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, a/k/a 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) has been substantially diminished in value; or (e) has been coriuningled with other property which cannot be divided without difficulty; 38 EFTA01713866 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, 51-58, of this indictment, the defendants, JEFFREY EPSTEIN, 1=1=5 a/lc/a 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 Brill° 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 Biavo 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 39 EFTA01713867 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). A TRUE BILL FOREPERSON R. ALEXANDER ACOSTA UNITED STATES ATTORNEY ASSISTANT UNITED STATES ATTORNEY 40 EFTA01713868