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U.S. ATTORNEY'S OFFICE
INDICTMENT/INFORMATION/RULE 20 APPROVAL COVER SHEET
LIONS USAO NO. 2006R01181
U
JEFFREY EPSTEIN
Defendants./
AUSA
AUSA Delivered to Supervisor 6/8/09
10:00 p.m.
Date
Time
AF AUSA (if any)
X Indictment (Superseding
)
Information (Indictment Waiver Attached)
SEALED
RULE 20
Operation
FIRREA Case
CORRUPTION Case (Federal/State/Local Official)
PSN Case
PSN Defendant
(Name(s))
X
PSC (Project Safe Childhood) Case
VIOLENT CRIME Case
OTHER (Credit card fraud, money laundering, illegal re-entry)
VICTIM/WITNESS CASE: NO _ YES X (MUST check either yes or no)
ESTIMATED NUMBER OF VICTIMS: Persons 33 Banks/Corps.
Govt.
ESTIMATED NUMBER OF WITNESSES: 40 (Persons subpoenaed)
AUSA KING participated in this case/had supervisory authority over this case
Reactive Case No
Prosecution Memorandum Attached:
X Yes
Asset Forfeiture Count:
X Yes
No (With concurrence of NF AUSA)
N/A
(If yes, copy of indictment to Chief, Asset Forfeiture Division)
Arrest Warrant(s) Attached
X Yes
Not Required
Press Release Attached:
Yes
Not Required
Yes TBut SEALED-DO NOT RELEASE UNTIL AUTHORIZED
Date and Time of Presentation: Tuesday. June 16. 2009
We have reviewed the attached indictment/information with regard to legal sufficiency and find it will withstand
a motion to dismiss for failure to state a crime.
Final Approval
Rtn'd for Revisions
action Deputy Chief
Date/Time
A il/6
Date/Time
Section Chief
Dafetrime
Date/Time
/7
puty Chief, Criminal Division
First Assistant U.S. Attorney in Roctuity0)
Dat
,fr
r
Data/Time
Date/Time
Date/Time
DaWrime
Date/Time
United States Attorney contiowtodi
Date/Time
Date/Time
(lbw VOW
Case No. 08-80736-CV-MARRA
EXHIBIT 86
P-011701
EFTA00224444
CASE NO.
MOTION TO SEAL
NOW COMES the United States of America, by and through its undersigned attorney, and
respectfully requests that the indictment, arrest warrants, this motion, and any resulting Order be
SEALED until the arrest of the defendants or until further order of this Court, excepting the United
States Attorney's Office and federal law enforcement agencies, which may obtain copies of any
indictment, arrest warrant, or other sealed document for purposes of arrest, extradition, or any other
necessary cause, for the reason that the named defendants may flee, evidence may be destroyed, the
integrity of the ongoing investigation might be compromised, and the safety of certain witnesses
could be compromised should knowledge of this indictment become public.
Respectfully submitted,
By:
Florida Bar No.
500 East Broward Boulevard, 7th Floor
Ft Lauderdale. FL 33394
Telephone:
Facsimile:
Case No. 08-80736-CV-MARRA
P-011702
EFTA00224445
CASE NO.
SEALED ORDER
The United States of America, having applied to this Court for an Order sealing the
indictment, arrest warrants, its motion to seal, and this Order and the Court finding good cause:
IT IS HEREBY ORDERED that the indictment, arrest warrants, and this Order shall be filed
under seal until the arrest of the defendants or until further order of this Court, however, the United
States Attorney's Office and any federal law enforcement agency may obtain copies of any
indictment, arrest warrant, or other sealed document for purposcs of arrest, extradition, or any other
necessary cause.
DONE AND ORDERED in chambers at West Palm Beach, Florida, this
day of June.
2009.
cc:
AUSA
Case No. 08-80736-CV-MARRA
P-011703
EFTA00224446
Case No:
18 U.S.C. § 371
18 U.S.C. § 1591(aX1)
18 U.S.C. § 1591(aX2)
18 U.S.C. § 2422(6)
18 U.S.C. § 2423(e)
18 U.S.C. § 2423(d)
18 U.S.C. § 2423(6)
vs.
a/k/a '
and
Defendants.
INDICTMENT
The Grand Jury charges that:
BACKGROUND
At all times relevant to this Indictment:
1.
Defendant JEFFREY EPSTEIN employed defendants
afIcia `1
" and
to perform,
among other things, services as personal assistants.
Case No. 08-80736-CV-MARRA
P-011704
EFTA00224447
2.
Defendants JEFFREY EPSTEIN and
paid
and
■. to perform, among other things, recruiting services.
3.
Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way,
Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El
Brillo Way").
4.
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.
5.
Defendant JEFFREY EPSTEIN served as president, sole director, and sole
shareholder of JEGE, INC., and had the power to direct all of its operations.
6.
Defendant JEFFREY EPSTEIN was the principal owner of I lyperion Air. Inc..
a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation
and ownership of a Gulfstream G-1 159B aircraft bearing tail number N909JE.
7.
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.
8.
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
2
Case No. 08-80736-CV-MARRA
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EFTA00224448
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."
9.
Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5Xc X2), 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.
10.
Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6Xb), an adult
"who [']ntentionally touches a person under 16 years of age in a lewd or lascivious manner
or siolic its 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.
II.
Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c). an adult
"who: (1) [']ntentionally masturbates: (2) [']ntentionally exposes the genitals in a lewd or
lascivious manner: or (3) Intentionally 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
3
Case No. 08-80736-CV-MARRA
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16 years of age, commits lewd or lascivious exhibition." which is a felony of the second
degree.
12.
Pursuant to Florida Statutes Section 800.04(2), "inIcither the victim's lack of
chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.041.-
13.
Pursuant to Florida Statutes Section 800.04(3), "it'll': 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
800.041."
14.
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."
15.
Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any
medical license.
16.
During the period of her involvement with the Defendants. Jane Doe #4
attended
and
in Palm Beach
County.
17.
During the period of her involvement with the Defendants. Jane Doe it 5
attended
in Palm Beach County.
4
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EFTA00224450
18.
During the period of their involvement with the Defendants, Jane Does # 6, 8,
and 12 attended
in Palm Beach County.
19.
During the period of her involvement with the Defendants, Jane Doe #7
attended
in Palm Beach County.
20.
During the periods of their involvement with the Defendants, Jane Does # 9,
14, 15, 16, 17, 18, and 19 attended
in Palm Beach County.
21.
During the period of her involvement with the Defendants, Jane Doe #10
attended
in Palm Beach County.
22.
During the period of her involvement with the Defendants, Jane Doe #11
attended
in Palm Beach County.
23.
During the period of her involvement with the Defendants, Jane Doe #I3
attended
in Palm Beach County.
COUNT 1
(Conspiracy: 18 U.S.C. § 371)
24.
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
25.
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,
5
Case No. 08-80736-CV-MARRA
P-011708
EFTA00224451
SARAH
a/k/Fale
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 IS, United States Code, Section 2422(b).
Purpose and Object of the Conspiracy
26.
It was the purpose and object of the conspiracy to procure females under the
age of 18 to travel to 358 El Brillo Way 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
27.
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 pan of the conspiracy that Defendants
a/k/a '
and other
participants would contact minor females via the use of cellular and other telephones to
6
Case No. 08-80736-CV-MARRA
P-011709
EFTA00224452
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,
a/k/a '
and other participants 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,
a/k/a "
' and other
participants 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,
a/k/a ".1
" and other
participants 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.
7
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EFTA00224453
Overt Act
28.
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, and elsewhere:
Jane Does #1 and #2
(I)
In or around the beginning of 2001, Defendant JEFFREY EPSTEIN
engaged in sexual activity with Jane Doe 14 I. who was then a sev enteen-y ear-old girl,
in the presence of Jane Doe 42, who was then a fourteen-year-old girl.
CO
In or around 2001. Defendant
led Jane Doe #2 from the
kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358
El Brillo Way.
(3)
In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the
presence of Jane Doe #2, who was then a fourteen-year-old girl.
(4)
In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2,
who was then a fourteen-years-old girl, to pinch his nipples while he masturbated.
(5)
In or around 2001, Defendant JEFFREY EPSTEIN made a payment of
$300 to Jane Doe #2.
(6)
In or around 2001, Defendant
placed a telephone call
to a telephone used by Jane Doe #2 to make an appointment for Jane Doe 42 to travel
to 358 El Brillo Way.
8
Case No. 08-80736-CV-MARRA
P-011711
EFTA00224454
(7)
In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse
with an unidentified female in the presence of Jane Doe #2, who was then a fourteen-
year-old girl.
(8)
In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane
Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female
to perform oral sex on Jane Doe #2 in EPSTEIN's presence.
(9)
On or about March 11, 2003, Defendant JEFFREY EPSTEIN reviewed
a written telephone message prepared by one of his employees regarding a telephone
call received from Jane Doe #2.
(10) In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2
if she had any younger friends who would be interested in engaging in similar sexual
activities with him.
(11) In or around 2003, Defendant -took
nude photographs
of Jane Doe #2, who was then a sixteen-year-old girl.
(12) In or around 2003, Defendant
made a payment of
$500 to Jane Doe #2 in exchange for posing for nude photographs.
(13) In or around 2003, Defendant
Defendant JEFFREY EPSTEIN had asked
Doe #2.
9
told Jane Doe #2 that
to take nude photographs ofJane
Case No. 08-80736-CV-MARRA
P-011712
EFTA00224455
(14)
In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
presence of Jane Doe #2, who was then a sixteen-year-old girl.
(15)
In or around 2003, Defendant JEFFREY EPSTEIN made a payment of
$200 to Jane Doe #2, who was then a sixteen-year-old girl.
(16)
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.
(17) On or about April 23, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #2.
(18) On or about May 2, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #2.
Jane Poe #3
(19)
In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the
presence of Jane Doe #3, who was then a fifteen-year-old girl.
(20)
In or around 2003, Defendant JEFFREY EPSTEIN made a payment of
$200 to Jane Doe #3.
(21) On or about October 26, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #3.
10
Case No. 08-80736-CV-MARRA
P-011713
EFTA00224456
(22) On or about October 30, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #3.
(23)
In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe
#3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and
to touch the adult female's breasts.
(24)
In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging
device on the vagina of an adult female in the presence ofJane Doe #3, who was then
a sixteen- or seventeen-year-old girl.
(25)
In or around 2004, Defendant JEFFREY EPSTEIN made a payment of
$200 to Jane Doe #3.
(26) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe
#3 to rub his nipples.
(27) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging
device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old
girl.
(28)
In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3
to recruit additional females to come to 358 El Brillo Way.
II
Case No. 08-80736-CV-MARRA
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EFTA00224457
(29) On or about November 8, 2004, Defendant JEFFREY EPSTEIN
reviewed a written telephone message prepared by one of his employees regarding a
telephone call received from Jane Doe #3 that read: "I have a female for him."
(30) On or about January 14, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe #3.
(31) On or about January 29,2005, Defendant JEFFREY EPSTEIN reviewed
a written telephone message prepared by one of his employees regarding a telephone
call received from Jane Doe #3 that read: "1 have a female for him."
Jane Does #4. #5. and #6
(32) In or around the first half of 2004, Defendant
led
Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El
Brillo Way.
(33) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
learned that Jane Doe #4 was seventeen years old when he asked Jane Doe #4 about
her age, and Jane Doe #4 responded with her true age.
(34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl,
and Jane Doe #5, who was then a seventeen-year-old girl.
12
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EFTA00224458
(35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
instructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his
nipples.
(36) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
instructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her
clothing.
(37) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
stroked the vagina of Jane Doc N4, who was then a seventeen-year-old girl.
(38) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid
$200 to Jane Doe #4.
(39) In or around the first hal for 2004, Defendant JEFFREY EPSTEIN paid
$200 to Jane Doe #5.
(40) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
asked Jane Doe #6 what high school she attended.
(41) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone.
(42) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
masturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl.
13
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(43) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
digitally penetrated Jane Doe #6, who was then a sixteen-year-old girl.
(44) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
placed a large vibrating massager on the vagina of Jane Doe #6, who was then a
sixteen-year-old girl.
(45) In or around the first half of 2004, Defendant JEFFREY EPSTEIN
caused a payment of $200 to be made to Jane Doe #6.
Jane Does #7 and #8
(46) In or around July 2004, Defendant JEFFREY EPSTEIN led.., who
was then a fifteen-year-old girl, and Jane Doc #7, who was then a sixteen-year-old
girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY
EPSTEIN's bedroom.
(47) On or about July 4, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #7.
(48) On or about July 5, 2004, Defendant
placed a
telephone call to a telephone used by..
(49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in
the presence of Jane Doe #8, who was then a seventeen-year-old girl.
14
Case No. 08-80736-CV-MARRA
P-011717
EFTA00224460
(50) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the
vagina of Jane Doe #8, who was then a seventeen-year-old girl.
(51) In or around July 2004, Defendant JEFFREY EPSTEIN paid
approximately $200 to Jane Doe #8.
(52) In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to
M. for recruiting Jane Doc #8 to travel to 358 El Brill° Way.
(53) In or around July 2004, Defendant
told Jane Doe #8
that Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a
friend.
(54) On or about July 15, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #7.
(55) On or about July IS, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #8.
(56) On or about July 15, 2004, Defendant
placed a
telephone call to a telephone used by
(57) On or about July 16. 2004. Defendant
placed one or
more telephone calls to a telephone used by Jane Doe #7.
(58) On or about July 16, 2004, Defendant
placed a
telephone call to a telephone used by
15
Case No. 08-80736-CV-MARRA
P-011718
EFTA00224461
(59) On or about July 17, 2004, Defendant JEFFREY EPSTEIN reviewed
a written telephone message prepared by one of his employees regarding a telephone
call received from.. that read: "Me & [Jane Doe #7] can come tomorrow any time
or I
] alone".
(60) In or around July 2004. Defendant JEFFREY EPSTEIN masturbated in
the presence of Jane Doe #7, who was then a sixteen-year-old girl.
(61) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane
Doe #7, who was then a sixteen-year-old girl, to rub his nipples.
(62) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the
vagina of Jane Doe #7, who was then a sixteen-year-old girl.
(63) In or around July 2004, Defendant JEFFREY EPSTEIN made a
payment of $200 to Jane Doe #7.
(64) 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.
(65) On or about July 24, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #8.
Jane Does #9 and #1Q
(66) On or about July 15, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #9.
16
Case No. 08-80736-CV-MARRA
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EFTA00224462
(67) On or about July 16, 2004, Defendant
caused Jane
Doe #9 to make a telephone call to a telephone used by Jane Doe #10.
(68) On or about July 17, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #9.
(69) On or about July 18, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #9.
(70) On or about July 22, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #9.
(71)
In or around July 2004, Defendant JEFFREY EPSTEIN fondled the
breasts of Jane Doe #9, who was then a seventeen-year-old girl.
(72)
In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in
the presence of Jane Doe #9, who was then a seventeen-year-old girl.
(73)
In or around July 2004, Defendant JEFFREY EPSTEIN made a
payment of $200 to Jane Doe #9.
(74) On or about July 22, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #10.
(75)
In or around the last half of 2004, Defendants JEFFREY EPSTEIN and
engaged in oral sex and sexual intercourse in the presence
of Jane Doe #9, who was then a seventeen-year-old girl.
17
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EFTA00224463
(76) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
forcibly inserted his penis into the vagina of Jane Doe #9, who was then a seventeen-
year-old girl.
(77) In or around the last hal f o f 2004, Defendant JEFFREY EPSTEIN made
a payment of $300 to Jane Doe #9.
(78) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
rubbed the vagina of Jane Doe #10, who was then a seventeen-year-old girl.
(79) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made
a payment of $200 to Jane Doe #10.
(80) On or about November 28, 2004, Defendant JEFFREY EPSTEIN
arranged for one of his employees to provide an envelope filled with cash to Jane Doe
#9.
(81) On or about December 4, 2004, Defendant
provided
a written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 9 and 10.
stating: "[Jane Doe #101 would like to work ® 4:00 pm if possible. [[Jane Doe #9)
is scheduled for 5:00 today.) the movie is ® 7:30".
(82) On or about December 29, 2004, Defendant
placed
a telephone call to a telephone used by Jane Doe #9.
(83) On or about December 30, 2004. Defendants JEFFREY EPSTEIN and
caused the purchase of Broadway tickets as an eighteenth birthday
gift for Jane Doe #9.
18
Case No. 08-80736-CV-MARRA
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(84)
In or around the last half of 2004 or January 2005, Defendant JEFFREY
EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen-
year-old girl.
(85)
In or around the last half of 2004 orJanuary 2005, Defendant JEFFREY
EPSTEIN fondled the breasts of Jane Doe #10, who was then a seventeen-year-old
girl.
(86) On or about January 14, 2005, Defendant
or more telephone calls to a telephone used by Jane Doe #10.
(87) On or about January 27, 2005, Defendant
placed one
a/k/a
" placed one or more telephone calls to a telephone used by Jane
Doe #10.
(88) On or about January 28, 2005, Defendant
placed one
or more telephone calls to a telephone used by Jane Doe #10.
(89) On or about February 1, 2005, Defendant
placed one or more telephone calls to a telephone used by Jane Doe #10.
(90)
In or around February 2005, Defendant JEFFREY EPSTEIN caused a
payment of S200 to be made to Jane Doe #9 for recruiting Jane Doe #I6 to travel to
358 El Brillo Way.
19
Case No. 08-80736-CV-MARRA
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Jane Doe #11
(91) In or around the summer of 2004, Defendant
led
Jane Doe # II and ■. from the kitchen of 358 El Brillo Way upstairs to Defendant
JEFFREY EPSTEIN's master bedroom suite.
(92) In or around the summer of 2004, Defendant JEFFREY EPSTEIN paid
$200 to M. for bringing Jane Doe #Il to 358 El Brillo Way.
(93) In or around the summer of 2004, Defendant JEFFREY EPSTEIN
masturbated in the presence of Jane Doe #11, who was then a fifteen- or sixteen-year-
old girl.
(94) In or around the summer of 2004, Defendant JEFFREY EPSTEIN
instructed Jane Doc #11 to rub his chest and pinch his nipples while he masturbated.
(95) In or around the summer of 2004, Defendant JEFFREY EPSTEIN
instructed Jane Doc #11 to write her telephone number on a notepad in his master
bedroom suite.
(96) In or around the summer of 2004, Defendant JEFFREY EPSTEIN
learned Jane Doe #11's true age when he asked Jane Doe #11 how old she was and
she responded truthfully.
(97) In or around the summer of 2004, Defendant JEFFREY EPSTEIN told
Jane Doc #11 that he did not care how old she was and that he did not like girls older
than eighteen.
20
Case No. 08-80736-CV-MARRA
P-011723
EFTA00224466
(98) In or around the second half of 2004. Defendant JEFFREY EPSTEIN
placed a vibrating massager on the vagina of Jane Doe #11, who was then a sixteen-
year-old girl.
(99) In or around the second half of 2004, Defendant JEFFREY EPSTEIN
digitally penetrated the vagina of Janc Doc #11, who was then a sixteen-year-old girl.
(100) On or about August 6, 2004, Defendant
placed a
telephone call to a telephone used by Janc Doe #11.
(101) On or about August 18, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #11.
(102) On or about October 29, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #11.
(103) On or about November 5, 2004, Defendant
placed
a telephone call to a telephone used by Janc Doe # 11.
(104) On or about February 14, 2005, Defendant JEFFREY EPSTEIN
reviewed a written telephone message prepared by one of his employees regarding a
telephone call received from Jane Doc #11 that read: "Please! Call her back".
(105) On or about February 14, 2005, Defendant
a telephone call to a telephone used by Jane Doe #11.
(106) On or about February 21, 2005, Defendant
a telephone call to a telephone used by Jane Doe # I I.
21
placed
placed
Case No. 08-80736-CV-MARRA
P-011724
EFTA00224467
(107) On or about March 29, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe N11.
(108) In or around the second half of 2005 or the first quarter of 2006.
Defendant JEFFREY EPSTEIN offered to pay $400 to Jane Doe #11, who was then
a sixteen-year-old girl, if she would engage in oral sex, or $500 or more if she would
engage in sexual intercourse.
(109) In or around the second half of 2005, Defendant JEFFREY EPSTEIN
offered to pay $100 to Jane Doe #11 if she would bring other girls to 358 El Brillo
Way.
Jane Does #12 and #13
(110) On or about August 2, 2004, Defendant JEFFREY EPSTEIN reviewed
a written telephone message prepared by one of his employees regarding a telephone
call received from M. and Jane Doe #12 that stated: "They are available all
weekend and maybe [Jane Doe #13) too".
(111) On or about August 21, 2004, Defendant
placed a
telephone call to a telephone used by Jane Doe #I3.
(112) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
masturbated in the presence of Jane Doc #I2, who was then a seventeen-year-old girl.
(113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
digitally penetrated Jane Doc #I2, who was then a seventeen-year-old girl.
22
Case No. 08-80736-CV-MARRA
P-011725
EFTA00224468
(114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
attempted to place a massaging device on the vagina of Jane Doe #12, who was then
a seventeen-year-old girl.
(115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made
a payment of $200 to Jane Doe #I2.
(116) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked
Jane Doe #12, who was then a seventeen-year-old girl, about her age.
(117) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told
Jane Doe #12 that he would take her to Los Angeles when she turned eighteen.
(118) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and
caused Jane Doe #12 to recruit Jane Doe #13 to travel to 358 El
Brillo Way.
(119) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
masturbated in the presence of Jane Doe #13, who was then a seventeen-year-old girl.
(120) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed
a massaging device on the vagina of Jane Doe #I3, who was then a seventeen-year-
old girl.
(121) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made
a payment of $200 to Jane Doe #13.
(122) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
digitally penetrated Jane Doe #13, who was then a seventeen-year-old girl.
23
Case No. 08-80736-CV-MARRA
P-011726
EFTA00224469
(123) In or around the last ha I f of 2004, Defendant JEFFREY EPSTEIN asked
Jane Doe #I3, who was then a seventeen-year-old girl, about her age.
(124) In or around the last hal f of 2004, Defendant JEFFREY EPSTEIN told
Jane Doe #13 that he wanted to take her to Paris but he could not because Jane Doe
#13 was not yet eighteen years old.
(125) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked
Jane Doe #I3 to bring her friends to his home, especially -girls who looked like [Jane
Doe #13]."
Jane Doe #14
(126) In or around the last half of 2004. 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.
(127) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked
Jane Doe #14 to provide her telephone number.
(128) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
instructed Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples.
(129) In or around the last half of 2004, Defendant JEFFREY EPSTEIN
masturbated in the presence of lane Doe #I4, who was then a seventeen-year old girl.
(130) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made
a payment of $300 to Jane Doe N14.
24
Case No. 08-80736-CV-MARRA
P-011727
EFTA00224470
(131) In or around the end of 2004 and the beginning of 2005, Defendant
JEFFREY EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeen-
year-old girl.
(132) In or around the end of 2004 and the beginning of 2005. Defendant
JEFFREY EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl,
whether she had any plans for her eighteenth birthday and acknowledged that she had
not yet turned eighteen.
(133) On or about December 23, 2004, Defendant JEFFREY EPSTEIN
caused a Western Union wire transfer order to be sent to Jane Doe #I4.
(134) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
placed a massaging device on the vagina of Jane Doe #14, who was then a seventeen-
year-old girl.
(135) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
engaged in sexual intercourse with Jane Doc #14, who was then a seventeen-year-old
girl.
(136) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl.
(137) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
made a payment of $600 to Jane Doe #14.
(138) On or about January 8, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe #I4.
25
Case No. 08-80736-CV-MARRA
P-011728
EFTA00224471
(139) On or about January 9, 2005, Defendant
a/k/a
" placed a telephone call to a telephone used by Jane Doe #I4.
(140) On or about January 26, 2005, Defendant
a/k/a
" reviewed a written telephone message prepared by one of
Defendant JEFFREY EPSTEIN's employees regarding a call received from Jane Doe
#14 that read: "She is confirming for 5:30".
(141) On or about January 26, 2005, Defendant
a/k/a
" placed a telephone call to a telephone used by Jane Doe #14.
(142) On or about February 1, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe #14.
(143) On or about March 1, 2005, Defendant
a/k/a
" placed a telephone call to a telephone used by Jane Doe #I4.
(144) On or about March 21, 2005, Defendant
a/k/a
" placed a telephone call to a telephone used by Jane Doe #I4.
(145) On or about March 29, 2005, Defendant
telephone call to a telephone used by Jane Doe #14.
Jane Doe NS
(146) On or about December 6, 2004, Defendant
a telephone call to a telephone used by Jane Doe #15.
(147) On or about December 14, 2004, Defendant
a telephone call to a telephone used by Jane Doe #15.
26
placed a
placed
placed
Case No. 08-80736-CV-MARRA
P-011729
EFTA00224472
(148) In or around the first half of 2005, 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.
(149) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
instructed Jane Doe #I5, who was then a seventeen-year-old girl, to pinch his nipples
while he masturbated.
(ISO) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
fondled the breasts of Jane Doc #I5.
(151) In or around the first half of 2005, Defendant JEFFREY EPSTEIN
made a payment of $200 to Jane Doc #15.
(152) On or about January 7, 2005, Defendant
a/k/a
' placed a telephone call to a telephone used by Jane Doe #15.
(153) On or about February 4, 2005, Defendant
telephone call to a telephone used by Jane Doe #15.
(154) On or about February 10, 2005, Defendant
a telephone call to a telephone used by Janc Doc #I5.
(155) On or about February 21, 2005, Defendant
a telephone call to a telephone used by Jane Doc #15.
(156) On or about February 24. 2005, Defendant
a telephone call to a telephone used by Jane Doe #15.
27
placed a
placed
placed
placed
Case No. 08-80736-CV-MARRA
P-011730
EFTA00224473
(157) On or about March 17, 2005. Defendant
telephone call to a telephone used by Jane Doe #I5.
(158) On or about March 30, 2005. Defendant
telephone call to a telephone used by Jane Doe #I5.
(159) On or about March 31, 2005, Defendant
telephone call to a telephone used by Jane Doe #I5.
(160) On or about March 31, 2005, Defendant
placed a
placed a
placed a
ailda
" placed a telephone call to a telephone used by Jane Doe #15.
(161) On or about April 1, 2005, Defendant JEFFREY EPSTEIN reviewed
a note prepared by one of his employees that read: "10:30 [Jane Doe #15]/Pane Doe
#10j on Fri around 2Oclock".
(162) In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane
Doe #15 with a gift of
Secret lingerie for her eighteenth birthday.
Jane Does #16 & #17
(163) In or around February 2005, Defendant JEFFREY EPSTEIN
masturbated in the presence of Jane Doe #I6, who was then a seventeen-year-old girl.
(164) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN
and
caused Jane Doe #16 to place a telephone call to Jane Doe #I7
to ask her to travel to 358 El Brillo Way.
28
Case No. 08-80736-CV-MARRA
P-011731
EFTA00224474
(165) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
caused a payment to be made to Jane Doe #16 for recruiting Jane Doe #17 to travel
to 358 El Brill° Way.
(166) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
masturbated in the presence of Jane Doe #I7, who was then a sixteen-year-old girl.
(167) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her
clothing.
(168) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
placed a massaging device on the vagina of Jane Doe #I7, who was then a sixteen-
year-old girl.
(169) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN
made a payment of $200 to Jane Doe #17, who was then a sixteen-year-old girl.
(170) In or around the first nine months of 2005, Defendant JEFFREY
EPSTEIN placed a massaging device on the vagina of Janc Doe #16, who was then
a seventeen-year-old girl.
(171) In or around the first nine months of 2005, Defendant JEFFREY
EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, how old she
was, and she responded that she was seventeen years old.
29
Case No. 08-80736-CV-MARRA
P-011732
EFTA00224475
(172) In or around the first nine months of 2005, Defendant JEFFREY
EPSTEIN engaged in sexual activity with Defendant
in the
presence of Jane Doc #16, who was then a seventeen-year-old girl.
(173) In or around the first nine months of 2005, Defendant JEFFREY
EPSTEIN asked Jane Doe #I6, who was then a seventeen-year-old girl, to touch the
breast of Defendant
(174) On or about April II, 2005, Defendant
placed a telephone call to a telephone used by Jane Doe #16.
(175) On or about April II, 2005, Defendant
telephone call to a telephone used by Jane Doe #I6.
(176) On or about April II, 2005, Defendant
placed a
left a
message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] can work
tomorrow at 4pm."
(177) On or about May 19, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doc #I6.
(178) On or about June 30, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe #16.
(179) On or about July 2, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe #16.
(180) On or about July 22, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe #16.
30
Case No. 08-80736-CV-MARRA
P-011733
EFTA00224476
(181) On or about August 18, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe #16.
(182) On or about August 19, 2005, Defendant
, a/k/a
41
' placed a telephone call to a telephone used by Jane Doe #16.
(183) On or about August 21, 2005, Defendant
placed a telephone call to a telephone used by Jane Doc #I6.
(184) On or about September 3. 2005, Defendant
a/k/a
' placed a telephone call to a telephone used by Jane Doe #16.
(185) On or about September 18. 2005, Defendant
a telephone call to a telephone used by Jane Doe #16.
(186) On or about September 19. 2005, Defendant
text message to a telephone used by Jane Doc #I6.
(187) On or about September 29, 2005, Defendant
a telephone call to a telephone used by Jane Doc #16.
(188) On or about September 30, 2005, Defendant
placed
sent a
placed
a/k/a
" placed a telephone call to a telephone used by Jane Doe #16.
(189) On or about October I. 2005, Defendant
left a
telephone message for Defendant JEFFREY EPSTEIN stating: "Pane Doe #15J
confirmed at II AM and Pane Doc #16I — 4PM".
(190) On or about October 2, 2005, Defendant
placed a
telephone call to a telephone used by Jane Doe #I6.
31
Case No. 08-80736-CV-MARRA
P-011734
EFTA00224477
(191) On or about October 3, 2005, Defendant
telephone call to a telephone used by Jane Doe #16.
(192) On or about October 3, 2005, Defendant
placed a
left a
telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] will
be 1/2 how late".
(193) In or around the first week of October, 2005, Defendant JEFFREY
EPSTEIN engaged in sexual intercourse with Jane Doe #16, who was then a
seventeen-year-old girl.
(194) In or around the first week of October, 2005, Defendant JEFFREY
EPSTEIN made a payment of $350.00 to Jane Doe #16, who was then a seventeen-
year-old girl.
(195) In or around the first week of October, 2005, Defendant JEFFREY
EPSTEIN provided a gift of
Secret lingerie to Jane Doe #16 for her
eighteenth birthday.
Jane Does #18 and #19
(196) In or around the last half of 2003, Jane Doe #18 was approached by.
and was asked whether she would be willing to provide a massage to Defendant
JEFFREY EPSTEIN in exchange for $200.
(197) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked
Jane Doe #18 to provide her telephone number.
32
Case No. 08-80736-CV-MARRA
P-011735
EFTA00224478
(198) On or around August 27, 2003, Defendant
placed
a telephone call to a telephone used by Jane Doe #18.
(199) In or around the last half of 2003, Defendant JEFFREY EPSTEIN
masturbated in the presence of Jane Doe #I8, who was then a seventeen-year-old-girl.
(200) On or around November 16, 2003, Defendant
placed
a telephone call to a telephone used by Jane Doe N18.
(201) In or around the last half of 2003, Defendant JEFFREY EPSTEIN
digitally penetrated Jane Doc 018. who was then a seventeen-year-old-girl.
(202) In or around the last hal f of 2003, Defendant JEFFREY EPSTEIN asked
Jane Doe # 18 to recruit other females to travel to 358 El Brillo Way.
(203) On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane
Doe #19, who was then a seventeen-year-old girl, to leave when she refused to
remove her shirt.
(204) On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally
reprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she
was not willing to undress for him.
The Defendants' Travel
(205) On or about July 16. 2004. Defendants JEFFREY EPSTEIN,
NM,
and
traveled from Teterboro, New Jersey to
Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air,
Inc.
33
Case No. 08-80736-CV-MARRA
P-011736
EFTA00224479
(206) On or about August 6, 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.
(207) 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.
(208) On or about October 29, 2004, Defendants JEFFREY EPSTEIN and
traveled from Teterboro, New Jersey to Palm Beach
County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.
(209) On or about February 21, 2005, Defendants JEFFREY EPSTEIN,
, and
traveled from the U.S. Virgin
Islands to Palm Beach County, Florida, aboard the 13oeing 727 aircraft owned by
JEGE, INC.
(210) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled
from New York, New York to Palm 13each County, Florida, aboard the Boeing 727
aircraft owned by JEGE, INC.
(211) On or about September 18, 2005, Defendants JEFFREY EPSTEIN,
and
a/lcia
," traveled from
Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream
aircraft owned by Hyperion Air, Inc.
34
Case No. 08-80736-CV-MARRA
P-011737
EFTA00224480
(s
On or about September 29, 2005, Defendants JEFFREY EPSTEIN,
afk/a
"and
traveled
from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream
aircraft owned by Hyperion Air, Inc.
All in violation of Title 18, United States Code, Section 371.
COUNTS 2 THROUGH 11
(Sex Trafficking: 18 U.S.C. § 1591(a)(1))
29.
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
30.
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
Dates
Minor Involved
Defendants
2
2001 - 2004
Jane Doc #2
JEFFREY EPSTEIN
3
January 2004
through
July 2004
Jane Doe #4
JEFFREY EPSTEIN
35
Case No. 08-80736-CV-MARRA
P-011738
EFTA00224481
Count
Dates
Minor Involved
Defendants
4
July 2004
through
December 29,
2004
Jane Doe #9
JEFFREY EPSTEIN
5
July 2004
through
January 31, 2005
Jane Doe #I0
JEFFREY EPSTEIN
6
Mid-2004
through
March 2005
Jane Doe #11
JEFFREY EPSTEIN
Mid-2004
through
April 22, 2005
Jane Doe NI2
JEFFREY EPSTEIN
S
August 2004
through
May 27, 2005
Jane Doe #13
JEFFREY EPSTEIN
9
November 2004
through
March 2005
Jane Doe #14
JEFFREY EPSTEIN
a/k/a
10
December 2004
through
June 5, 2005
Jane Doe #15
JEFFREY EPSTEIN
ark/a'
11
February 2005
through
first week of
October 2005
Jane Doe #16
JEFFREY EPSTEIN
All in violation of Title 18. United States Code, Sections 1591(aX I) and 2.
36
Case No. 08-80736-CV-MARRA
P-011739
EFTA00224482
COUNT 12
(Sex Trafficking: 18 U.S.C. § 1591(a)(2))
31.
Paragraphs I through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
32.
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.
a/k/a
and
did knowingly benefit, financially or by receiving anything of value, from participation in a
venture, as defined in 18 U.S.C. § 1591(cX3), which had engaged in an act described in
violation of 18 U.S.C. § 1591(aX1), 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 159 1( aX2), 1591(b)(2), and 2.
COUNT 13
(Enticement of a Minor: 18 U.S.C. § 2422(b))
33.
Paragraphs 1 through 23 of this Indictment arc re-alleged and incorporated by
reference as though fully set forth herein.
37
Case No. 08-80736-CV-MARRA
P-011740
EFTA00224483
34.
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 #3. 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 of Title 18, United States Code, Sections 2422(b)
and 2.
COUNT 14
(Enticement of a Minor: 18 U.S.C. § 2422(6))
35.
Paragraphs I through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
36.
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 commerce, that is. the telephone, to knowingly
persuade, induce and entice Jane Doe #7, who was a person who had not attained the age of
38
Case No. 08-80736-CV-MARRA
P-011741
EFTA00224484
I8 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))
37.
Paragraphs 1 through 23 of this Indictment arc re-alleged and incorporated by
reference as though fully set forth herein.
38.
From in or around July 2004 through in or around October 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 #8, 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 16
(Enticement of a Minor: 18 U.S.C. § 2422(b))
39.
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
40.
From in or around July 2004 through on or around December 29, 2004, the
exact dates being unknown to the Grand Jury, in Palm I3each County, in the Southern District
of Florida, and elsewhere, the defendants,
39
Case No. 08-80736-CV-MARRA
P-011742
EFTA00224485
JEFFREY EPSTEIN
and
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 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 IS, United States Code, Sections 2422(b) and 2.
COUNT 17
(Enticement of a Minor: 18 U.S.C. § 2422(b))
41.
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
42.
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
and
SARAH
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(6) and 2.
40
Case No. 08-80736-CV-MARRA
P-011743
EFTA00224486
COUNT 18
(Enticement of a Minor: 18 U.S.C. § 2422(6))
43.
Paragraphs 1 through 23 of this Indictment arc re-alleged and incorporated by
reference as though fully set forth herein.
44.
From in or around the middle of 2004 through in or about 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
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 19
(Enticement of a Minor 18 U.S.C. § 2422(b))
45.
Paragraphs 1 through 23 of this Indictment arc re-alleged and incorporated by
reference as though fully set forth herein.
46.
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
41
Case No. 08-80736-CV-MARRA
P-011744
EFTA00224487
did use a facility or means of interstate commerce, that is, the telephone, to knowingly
persuade, induce and entice Jane Doe #12, 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 20
(Enticement of a Minor: 18 U.S.C. § 2422(b))
47.
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
48.
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
did use a facility or means of interstate commerce, that is, the telephone, to knowingly
persuade, induce and entice Jane Doc #I3, 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 21
(Enticement of a Minor: 18 U.S.C. § 2422(b))
49.
Paragraphs I through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
42
Case No. 08-80736-CV-MARRA
P-011745
EFTA00224488
50.
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,
and
ailc/a '
'PM
did use a facility or means of interstate commerce, that is, the telephone, to knowingly
persuade, induce and entice Jane Doe #I4, 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 I8. United States Code. Sections 2422(b) and 2.
COUNT 22
(Enticement of a Minor: 18 U.S.C. § 2422(b))
51.
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
52.
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,
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 #15. who was a person who had not attained the age
43
Case No. 08-80736-CV-MARRA
P-011746
EFTA00224489
of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
2422(b) and 2.
COUNT 23
(Enticement of a Minor: 18 U.S.C. § 2422(6))
53.
Paragraphs I through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
54.
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 Heach County, in
the Southern District of Florida, and elsewhere, the defendants,
did use a facility or means of interstate commerce, that is, the telephone, to knowingly
persuade, induce or 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 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 24
(Enticement of a Minor: 18 U.S.C. § 2422(6))
55.
Paragraphs I through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
44
Case No. 08-80736-CV-MARRA
P-011747
EFTA00224490
56.
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,
,and
a/k/a
ff
did use a facility or means of interstate commerce, that is, the telephone, to knowingly
persuade, induce and entice Jane Doe #I7, 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 25
(Enticement of a Minor: 18 U.S.C. § 2422(b))
57.
Paragraphs I through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
58.
From in or around August 2003 through in or around February 2004, 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 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
45
Case No. 08-80736-CV-MARRA
P-011748
EFTA00224491
of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections
2422(6) and 2.
COUNT 26
(Conspiracy to Travel: 18 U.S.C. § 2423(e))
59.
Paragraphs 1 through 23 of this indictment are re-alleged and incorporated by
reference as fully set forth herein.
60.
From at least as early as 2001 through in or around October 2005, the exact
dates being unknown to the Grand Jury, the Defendants,
a/k/a
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 27
(Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d))
61.
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
62.
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,
46
Case No. 08-80736-CV-MARRA
P-011749
EFTA00224492
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 I8 U.S.C. § 2423(0; in violation of Title 18. United States Code, Section 2423(d).
COUNTS 28 THROUGH 35
(Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(6))
63.
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by
reference as though fully set forth herein.
64.
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
Defendants listed below traveled in interstate commerce for the purpose of engaging in illicit
sexual conduct as defined in 18 U.S.C. § 2423(0. with a person under 18 years of age, that
is, the person(s) listed in each count below:
Count
Date
Minor(s) Involved
Defendants
28
7/16/2004
Jane Doe #7
Jane Doe #8
Jane Doe #9
Jane Doe #10
JEFFREY EPSTEIN
SARAH KELLEN
29
8/6,04
Jane Doe #9
Jane Doe #11
JEFFREY EPSTEIN
30
8119/04
Jane Doe #9
Jane Doe #10
Jane Doe #11
JEFFREY EPSTEIN
SARAH KELLEN
47
Case No. 08-80736-CV-MARRA
P-011750
EFTA00224493
(Thant
Date
Minor(s)Involved
I kit:n(14ms
31
10/29/04
Jane Doe #I0
Jane Doe #11
Jane Doe #13
JEFFREY EPSTEIN
32
2/21/05
Jane Doe #11
Jane Doe #I4
Jane Doe #15
JEFFREY EPSTEIN
33
3/31/2005
Jane Doe #11
Jane Doe #I4
Jane Doe #15
Jane Doe #I6
JEFFREY EPSTEIN
a/k/a •
34
9 1$ 2t tf,
Jane Doe #16
JEFFREY EPSTEIN
35
9/29/05
Jane Doe #16
JEFFREY EPSTEIN
SARAH
a/lc/ •
All in violation of Title 18, United States Code, Sections 2423(b) and 2.
FORFEITURE 1
Upon conviction o Ithe violation alleged in Count I of this indictment, the defendants.
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.
48
Case No. 08-80736-CV-MARRA
P-011751
EFTA00224494
Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code,
Section 981(a)( I )(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,
a/k/a
" 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 13-35 of this indictment,
the defendants, JEFFREY EPSTEIN,
"and
, atIcia '
, shall forfeit to the United States any property, real
or personal, constituting or traceable to gross profits or other proceeds obtained from such
49
Case No. 08-80736-CV-MARRA
P-011752
EFTA00224495
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 IS, 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
50
Case No. 08-80736-CV-MARRA
P-011753
EFTA00224496
(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 2-12 of this indictment.
the defendants, JEFFREY EPSTEIN,
S
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
5I
Case No. 08-80736-CV-MARRA
P-011754
EFTA00224497
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(6).
A TRUE BILL.
FOREPERSON
52
Case No. 08-80736-CV-MARRA
P-011755
EFTA00224498
CASE NO.
vs.
CERTIFICATE OF TRIAL ATTORNEY'
a
andante.
Superseding Case Information:
Court Division (sow ow)
New Defendants)
Yes
No
Number of New Defendants
Miami
Key W
FTP
est
Tote' n.mber of counts
FR
_x_
I do hereby certify that
1.
I have carefuily considered the allegations of the indictment, the number of defendants. the number of
probable witnesses and the legal complexities of the Indictment/Information attached hereto.
2.
I am aware that the information supplied on this statement will be relied upon by the Judges of this
Court in setting their calendars and scneduling criminal trials under the mandate of the Speedy Trial Act.
Title 28 U.S.C. Section 3161.
3.
Interpreter
(Yes or No)
—Na_
List language and/or dialect
4
This case wit take
days for Me parties to try
5
Please check appropriate catego-y and type of offense 'sled below
IC's. co* re
I
0 to 5 days
II
6 to 10 days
11 to 20 days
21 to 60 day$
61 days and over
III
(Ch.,. to%) re
Petty
Minor
Misdem
Felony
6.
Has this case been previously filed in this District Court? (Yes or No)
If yes:
Judge'
Case No
(Attach copy Of chspositive order)
Has a complaint been filed in this matter?
(Yes or No)
If yes
Magistrate Case No
Related Miscellaneous numbers
Defendant(s) in federal custody as of
Defendant(s) in state custody as of
Rule 20 from the
Dottrel of
Is this a potential death penalty case? (Yes or No)
Mn_
7
Does this case originatefrom a matter pending in the Northern Region of the U S Attorney's Office pnor
to October 14, 20037
Yes
x No
8.
Does this case originate from a matter pending in the Central Region of the U S Attorney s Office pixy
to September 1, 2007?
Yes
x No
ASSISTANT Ufi
AITtS ATTORNEY
Florida Bar No
'Penalty Sheet(s) attached
Case No. 08-80736-CV-MARRA
P-011756
EFTA00224499
PENALTY SHEET
Defendants Name:
JEFFREY EPSTEIN
Case No.:
Count 1:
18 USC § 371
Conspiracy to entice minors to engage in sexual activity
•Max. Penalty: 5 Years' Imprisonment: 3 years' Supervised Release: 5250.000 Fine
Counts 2-11:
18 USC §1591(aX1)
Sex Trafficking of Minors
*Max. Penalty: 40 Years' Imprisonment: Lifetime Supervised Release; 5250.000 Fine
Counts 13 - 25:
18 USC 6 2422(b)
Enticement of a Minor
•Max. Penalty: 5 to 30 Years' Imprisonment: Lifetime Supervised Release: 5250,000 Fine
Count 26:
18 USC 6 2423(e)
Conspiracy to Travel to Engage in Illicit Sexual Conduct
•Max. Penalty: 5 to 30 Years' Imprisonment: Lifetime Supervised Release: 5250.000 Fine
Counts 28 - 35:
18 USC 6 2423(b)
Travel to Engage in Illicit Sexual Conduct
•Max. Penalty: 30 Years' Imprisonment: Lifetime Supervised Release: 5250.000 Fine
•Refers only to possible term of incarceration, does not include possible fines, restitution, special
assessments, parole terms, or forfeitures that may be applicable.
REV 12/12/96
Case No. 08-80736-CV-MARRA
P-011757
EFTA00224500
PENALTY SHEET
Defendant's Name:
Case No.:
Count I:
18 USC 4371
Conspiracy to entice minors to engage in sexual activity
' Max. Penalty: S Years' Imprisonment: 3 years' Supervised Release: 5250.000 Fine
Counts 2 - I I:
18 USC §1591(agl)
Sex Trafficking of Minors
'Max. Penalty: 40 Years' Imprisonment: Lifetime Supervised Release: $250.000 Fine
Count l2:
18 USC § 1591(aX2)
Benefiting from a Venture Engaged in Sex Trafficking of Minors
•Max. Penalty: 40 Years' Imprisonment: Lifetime Supervised Release: 5250.000 line
Counts I3 - 25:
IS USC 4 2422(b)
Enticement of a Minor
'Max. Penalty: 5 to 30 Years' Imprisonment: Lifetime Supervised Release: $250.000 Fine
Count 26:
18 USC 4 2423(c)
Conspiracy to Travel to Engage in Illicit Sexual Conduct
'Max. Penalty: 5 to 30 Years' Imprisonment Lifetime Supervised Release: 5250.000 Fine
•Refers only to possible term of incarceration, don not include possible fines, restitution, special
assessments, parole terms, or forfeitures that may be applicable.
REV 12/12196
Case No. 08-80736-CV-MARRA
P-011758
EFTA00224501
PENALTY SHEET
Defendant's Name:
(continued)
Count 27:
18 USC § 2423(d)
Arranging or Facilitating Travel to Engage in Illicit Sexual Conduct
•Max. Penalty: 5 to 30 Years' Imprisonment: Lifetime Supervised Release: S250.000 Fine
Counts 28 - 35:
18 USC 2423(b)
Travel to Engage in Illicit Sexual Conduct
•Max. Penalty: 30 Years' Imprisonment; I.ifctime Supervised Release; 5250.000 Fine
•Refer only to possible term of incarceration, does not include possible fines, restitution, special
assessments, parole terms, or forfeitures that may be applicable.
REV IVI2'6
Case No. 08-80736-CV-MARRA
P-011759
EFTA00224502
PENALTY SHEET
Defendant's Namc:
Case No.:
Count I:
18 USC § 371
Conspiracy to entice minors to engage in sexual activity
• Max. Penalty: 5 Years' Imprisonment; 3 years' Supervised Release: $250,000 Fine
Counts 9 - 11:
18 USC §1591(aX1)
Sex Trafficking of Minors
*Max. Penalty: 40 Years' Imprisonment: Lifetime Supervised Release: 5250.000 Fine
Count 12:
18 USC § 1591(a)(2)
I3enefitting from a Venture Engaged in Sex Trafficking of Minors
*Max. Penalty: 40 Years' Imprisonment: Lifetime Supervised Release: 5250.000 Fine
Counts 21 - 24:
18 USC § 2422(b)
Enticement of a Minor
•Max. Penalty: 5 to 30 Years' Imprisonment; Lifetime Supervised Release: 5250,000 Fine
Count 26:
18 USC § 2423(e)
Conspiracy to Travel to Engage in Illicit Sexual Conduct
•Max. Penalty: 5 to 30 Years' Imprisonment: Lifetime Supervised Release: 5250.000 Fine
•Refers only to possible term of incarceration, does not include possible fines, restitution, special
assessments, parole terms, or forfeitures that may be applicable.
REV 12/12/96
Case No. 08-80736-CV-MARRA
P-011760
EFTA00224503
PENALTY SHEET
Defendant's Name:
Counts 32 • 35:
18 USC §2423(b)
(continued)
Travel to Engage in Illicit Sexual Conduct
'Max. Penalty: 30 Years' Imprisonment: Lifetime Supervised Release: S250.000 Fine
•Refers only to possible term of incarceration, does not include possible fines, restitution, special
assessments, parole terms, or forfeitures that may be applicable.
REV I VIM.
Case No. 08-80736-CV-MARRA
P-011761
EFTA00224504
PENALTY SHEET
Defendant's Name:
Case No.:
Count I:
18 USC 6 371
Conspiracy to entice minors to en a e in sexual activit
•Max. Penalty: 5 Years' Imprisonment: 3 years' Supervised Release: $250,000 Fine
Count II:
18 USC 6 1591(a)(1)
Sex Trafficking of Minors
*Max. Penalty: 40 Years' Imprisonment: Lifetime Supervised Release: $250,000 Fine
Count 12:
18 USC § 1591(a)(2)
Benefitting from a Venture Engaged in Sex .trafficking of Minors
• Max. Penalty: 40 Years' Imprisonment; Lifetime Supervised Release: $250,000 Fine
Count 23:
18 USC 2422(b)
Enticement of a Minor
•Max. Penalty: 5 to 30 Years' Imprisonment: Lifetime Supervised Release: $250.000 Fine
Count 26:
18 USC 6 2423(e)
Conspiracy to Travel to Engage in Illicit Sexual Conduct
*Max. Penalty: 5 to 30 Years' Imprisonment: Lifetime Supervised Release: $250.000 Fine
*Refers only to possible term of incarceration, does not include possible fines, restitution, special
assessments, parole terms, or forfeitures that may be applicable.
REV 1211296
Case No. 08-80736-CV-MARRA
P-011762
EFTA00224505
PENALTY SHEET
Defendant's Name:
Counts 28, 30-32, 35:
18 USC 4 2423(b)
(continued)
Travel to Engage in Illicit Sexual Conduct
*Max. Penalty: 30 Years' Imprisonment: Lifetime Supervised Release: $250.000 Fine
•Refers only to possible term of incarceration, does not include possible fines. restitution, special
assessments, parole terms, or forfeitures that may be applicable.
REV 12/12/96
Case No. 08-80736-CV-MARRA
P-011763
EFTA00224506
AO 190 (Rev. 0109) Record of the Number of Grand Jurors Concurring in an Indictment
for the
Southern District of Florida
United States of America
EFFREY EPSTEIN,
a/k/a
and
Defendant
) Indictment No.
)
Case No.
As the foreperson of the grand jury of this court at a session held at
West Palm Bead), Florida
on
06/16/2009
, I certify that (speak number)
grand jurors concurred in the indictment in this case.
Under Fed. R. Crim. P. 6(c). this record is being filed with the court clerk and will nor be made public unless the court
orders otherwise.
Date:
FGJ No: 08-703 (WPB)
Foreperson's signature
Case No. 08-80736-CV-MARRA
P-011764
EFTA00224507
AO 442 tRev 01/09) Amu Warts S /A
FBI
for the
Southern District of Florida
United States of A Medal
JEFFREY EPSTEIN. et al.
Defendant
To:
Any authorized law enforcement officer
Case No.
ARREST WARRANT
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested)
JEFFREY EPSTEIN
who is accused of an offense or violation based on the following document filed with the court:
e Indictment
Cl Superseding Indictment
CI Information
Cl Superseding Information
Cl Complaint
Cl Probation Violation Petition
Cl Supervised Release Violation Petition
0 Violation Notice Cl Order of the Court
This offense is briefly described as follows:
Conspiracy-, sex traffideng of minors: enticement of minors; interstate travel to engage in Illicit sexual conduct with minors
Date:
City and state:
West Palm Beath. Florida
Issuing officer 4 spare
Printed none and ink
Rehire
This warrant was received on 4:4240
al too and slab/
C:
, and the person was arrested on 4k:vj
Arresting officer S prawn
Pruned name and hue
Case No. 08-80736-CV-MARRA
P-011765
EFTA00224508
AO 442 ilicv 01/09) Arrest W maw (Pap 2)
This second page contains personal identifiers pros ided for Ian-enforcement use only
and therefore should not he filed in court with the executed warrant unless under seal.
(Vol for Public Disclosure)
Name of defendant/offender:
Jeffrey Epstein
Known aliases:
Last known residence:
Prior addresses to which defendant/offender may still have ties:
Last known employment:
Last known telephone numbers:
Place of birth:
Date of birth:
Social Security number:
Height:
Weight:
Sex•
Male
Race:
White
Hair.
Eyes:
Scars, tattoos, other distinguishing marks:
History of violence, wesPolls, drug use:
Known family. friends. and other associates Ina. rekmort ad as. pkont naber):
FBI number:
Complete description of auto:
Investigative agency and address:
Federal Bureau of Investigation. West Palm Beach, FL
Name and telephone numbers (office and cell) of pretrial services or probation officer riapplicabk):
Date of last contact with pretrial services or probation officer ofoppeeemafr:
Case No. 08-80736-CV-MARRA
P-011766
EFTA00224509
CASE NUMBER:
Pre-Trial Detention
(Personal Surety ) (Corporate Surety ) (Cash) (Pre-Trial Detention)
By
AU A:
Last Known Address:
What Facility:
Palm Beach County Stockade
Agent(s):
(FBI) (SECRET SERVICE) (DEA) (IRS) (ICE) (MUM
Case No. 08-80736-CV-MARRA
P-011767
EFTA00224510
Ao
(KC
EVA
FBI
for the
Southern District of Florida
United States of America
I
)
Case No.
JEFFREY EPSTEIN, el al.
Defendant
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested)
who is accused of an offense or violation based on the following document filed with the court:
ef Indictment
0 Superseding Indictment
CI Information
0 Superseding Information
0 Complaint
0 Probation Violation Petition
CI Supervised Release Violation Petition
0 Violation Notice 0 Order of the Court
This offense is briefly described as follows:
Conspiracy: sex trafficking of minors; enticement of minors; interstate travel to engage in illicit sexual conduct with minors
Date:
City and state:
West Palm Beach. Florida
Issuing officer's stitnann
Printed name and title
Return
This warrant was received on (date)
, and the person was arrested on Owe;
at (ay and slate)
Date:
Arresting officers signature
Printed name and title
Case No. 08-80736-CV-MARRA
P-011768
EFTA00224511
AO 442 (Rev 01/09) Arrest Warrant (Past 2)
This second page contains personal identifiers provided for law-enforcement use only
and therefore should not be filed in court with the executed warrant unless under seal.
(Not for Public Disclosure)
Name of defendant/offender:
Known aliases:
Last known residence:
Prior addresses to which defendant/offender may still have ties:
Last known employment:
Last known telephone numbers:
Place of birth:
Date of birth:
Social Security number:
Height:
Weight:
Sex:
Female
Race:
White
Hair:
Eyes:
Scars. tattoos. other distinguishing marks:
History of violence, weapons, drug use:
Known family, friends, and other associates mom& relation. address. phone number):
FBI number:
Complete description of auto:
Investigative agency and address:
Federal Bureau of Investigation, West Palm Beach. FL
Name and telephone numbers (office and cell) of pretrial services or probation officer afapplicable):
Date of last contact with pretrial services or probation officer Wappiknfrie):
Case No. 08-80736-CV-MARRA
P-011769
EFTA00224512
CASE NUMBER:
DEFENDANT:
Pre-Trial Detention
(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention)
By: i
Last Known Address:
What Facility:
Agent(s):
FBI
(FBI) (SECRET SERVICE) (DEA) (IRS) (ICE) (OTHER)
Case No. 08-80736-CV-MARRA
P-011770
EFTA00224513
AU 442 (Rev Olf09) Attest
VA
FBI
for the
Southern District of Florida
United States of America
I
)
Case No.
JEFFREY EPSTEIN, et al.
ombndani
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be antmed)
ands "
who is accused of an offense or violation based on the following document filed with the court:
II Indictment
0 Superseding Indictment
0 Information
C) Superseding Information
0 Complaint
0 Probation Violation Petition
0 Supervised Release Violation Petition
0 Violation Notice 0 Order of the Court
This offense is briefly described as follows:
Conspiracy; sex trafficking of minors; enticement of minors: interstate travel to engage in illicit sexual conduct with minors
Date:
City and state:
West Palm Beach, Florida
Issuing officer's signori...
Printed name and title
Return
This warrant was received on (dale)
at (city and state)
Date:
, and the person was arrested on (darn
Arresting officer's signature
Printed name and ude
Case No. 08-80736-CV-MARRA
P-011771
EFTA00224514
A0442 (Rev 01.4/9) Arrest Wemini (Page 2)
This second page contains personal identifiers provided for law-enforcement use only
and therefore should not be filed in court with the executed warrant unless under seal.
(Not for Public Disclosure)
Name of defendant/offender
Last known residence:
Prior addresses to which defendant/offender may still have ties:
Last known employment:
Last known telephone numbers:
Place of birth:
Date of birth:
Social Security number.
Height:
Weight:
sex:
Female
Race:
White
Flair:
Eyes:
Scars, tattoos, other distinguishing marks:
History of violence, weapons, drug use:
Known family, friends, and other associates frame. relation. address. phone number):
FBI number:
Complete description of auto:
Investigative agency and address:
Federal Bureau of Investigation. West Palm Beach, FL
Name and telephone numbers (office and cell) of pretrial services or probation officer (Jappircable):
Date of last contact with pretrial services or probation officer ft/applicable):
Case No. 08-80736-CV-MARRA
P-011772
EFTA00224515
CASE NUMBER:
DEFENDANT:
, a/k/a "
Pre-Trial Detention
(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention)
By:
Last Known Address:
What Facility:
Agent(s):
FBI
(FBI) (SECRET SERVICE) (DEA) (IRS) (ICE) (QUM
Case No. 08-80736-CV-MARRA
P411773
EFTA00224516
AO 442 (Rn 01/09) Amu %mat SSA
FBI
for the
Southern District of Florida
United States of America
1.
)
Case No.
JEFFREY EPSTEIN, et al.
Defendant
ARREST WARRANT
To:
Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name of person to be arrested)
who is accused of an offense or violation based on the following document filed with the court:
of Indictment
Cl Superseding Indictment
O Information
Cl Superseding Information
Cl Complaint
Cl Probation Violation Petition
I
Supervised Release Violation Petition
0 Violation Notice 0 Order of the Court
This offense is briefly described as follows:
Conspiracy; sex trafficking of minors; enticement of minors: Interstate travel to engage in illicit sexual conduct with minors
Date:
City and state:
West Patm Beach. Florida
Issuing officer's signature
Printed name and tide
Return
This warrant was received on Ow)
at retry and stater
Date:
and the person was arrested on (mei
.4
ng officer 1 strain
Printed name and title
Case No. 08-80736-CV-MARRA
P-011774
EFTA00224517
A0442 (Rev 01109) Anne wanes (Page 2)
This second page contains personal identifiers provided for law-enforcement use only
and therefore should not be filed in court with the executed warrant unless under seal.
(Not for Public Disclosure)
Name of defendant/offender:
Known aliases:
Last known residence:
Prior addresses to which defendant/offender may still have ties:
Last known employment:
Last known telephone numbers:
Place of birth:
Date of birth:
Social Security number:
Height:
Sex:
Hair:
Female
Scars. tattoos, other distinguishing marks:
Weight:
Race:
Eyes:
White
History of violence, weapons, drug use:
Known family, friends, and other associates !name. relation, address, phone number):
FBI number:
Complete description of auto:
Investigative agency and address:
Federal Bureau of Investigation, West Palm Beach, FL
Name and telephone numbers (office and cell) of pretrial services or probation officer rilapplicable):
Date of last contact with pretrial services or probation officer lifopplkable):
Case No. 08-80736-CV-MARRA
P-011775
EFTA00224518
CASE NUMBER:
DEFENDANT:
Pre-Trial Detention
(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention)
Last Known Address:
What Facility:
By:
Agent(s):
, FBI
(FBI) (SECRET SERVICE) (DEA) (IRS) (ICE) =HEM
Case No. 08-80736-CV-MARRA
P-011776
EFTA00224519
COW MOM
No
cniakERV
Oisinct of
rya.
VS
JEFIREtrara
Mcla
' and
n
Defendants
INDICTMENT
18 U.S.C. §371
18 U.S.C. § 1591(a)(1)
18 U.S.C. § 1591(a)(2)
18 U.S.C. § 2422(b)
18 U.S.C. § 2423(e)
18 U.S.C. § 2423(d)
18 U.S.C. § 2423(b)
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ass
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Case No. 08-80736-CV-MARRA
P-011777
EFTA00224520