EFTA Document EFTA01713627

JANE S1 jjaa COUNT/O.A. DATE DEFENDANT(S) CHARGE O.A. 2 • 3/12/04 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 3 3/12/04 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 95 2/6/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 96 2/6/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 97 2/6/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 117 3/30/05 Conspiracy to entice a minor to engage in prostitution O.A. 120 3/31/05 Conspiracy to entice a minor to engage in prostitution O.A. 122 3/31/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 123 4/1/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution Ct 5 3/7/04 - 3/11/04 EPSTEIN Enticement of a minor to engage in prostitution CONFIDENTIAL GRAND JURY MATERIAL PAGE 1 OF 1 JANE DOE #1 EFTA01713627 JANE DOE #2 COUNT/O.A. DATE DEFENDANT(S) CHARGE O.A. 95 2/6/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 96 2/6/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 97 2/6/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 122 3/31/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 123 4/1/05 EPSTEIN Conspiracy to entice a minor to engage in prostitution Ct 6 2/5/05 - EPSTEIN Enticement of a minor to engage in 2/6/05 prostitution Ct. 43 3/31/05 EPSTEIN Travel to engage in illicit sexual conduct .J . Ct 60 3/30/05 - EPSTEIN Attempted enticement of a minor to 4/1/05 engage in prostitution • CONFIDENTIAL GRAND JURY MATERIAL PAGE 1 OF 1 SANE Dos #2 EFTA01713628 JANE DOE #3 COUNT/O.A. DATE DEFENDANT(S) CHARGE O.A. 59 12/6/04 Conspiracy to entice a minor to engage in prostitution O.A. 60 12/12/04 Conspiracy to entice a minor to engage in prostitution • O.A. 64 12/14/04 Conspiracy to entice a minor to engage in prostitution O.A. 71 12/20/04 IMMI Conspiracy to entice a minor to engage in prostitution O.A. 79 1/6/05 Conspiracy to entice a minor to engage in prostitution O.A. 83 1/14/05 Conspiracy to entice a minor to engage in prostitution O.A. 94 2/4/05 Conspiracy to entice a minor to engage in prostitution O.A. 100 2/10/05 Conspiracy to entice a minor to engage in prostitution O.A. 102 2/21/05 Conspiracy to entice a minor to engage in prostitution O.A. 104 2/24/05 Conspiracy to entice a minor to engage in prostitution O.A. 112 3/17/05 Conspiracy to entice a minor to engage in prostitution O.A. 118 3/30/05 Conspiracy to entice a minor to engage in prostitution O.A. 125 4/8/05 Conspiracy to entice a minor to engage in prostitution O.A. 129 4/26/05 Conspiracy to entice a minor to engage in prostitution O.A. 132 5/19/05 Conspiracy to entice a minor to engage in prostitution CONFIDENTIAL GRAND JURY MATERIAL PAGE 1 OF 3 JANE DoE #3 EFTA01713629 COUNT/O.A. DATE DEFENDANT(S) CHARGE Ct 7 12/6/04 - 6/29/05 EPSTEIN Enticement of a minor to engage in prostitution Ct. 32 12/13/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 35 1/6/05 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 36 1/14/05 EPSTEIN .. JEGE Travel to engage in illicit sexual conduct Ct. 37 2/3/05 EPSTEIN JEGE Travel to engage in illicit sexual conduct Ct. 38 2/10/05 EPSTEIN ERI N Travel to engage in illicit sexual conduct Ct. 39 2/21/05 EPSTEIN JEGE Travel to engage in illicit sexual conduct Ct. 40 2/24/05 EPSTEIN JEGE Travel to engage in illicit sexual conduct Ct. 42 3/18/05 EPSTEIN JEGE Travel to engage in illicit sexual conduct Ct. 43 3/31/05 EPSTEIN JEGE . Travel to engage in illicit sexual conduct CONFIDENTIAL GRAND JURY MATERIAL PAGE 2 OF 3 JANE DOE #3 EFTA01713630 COUNT/OA. DATE DEFENDANT(S) CHARGE Ct. 44 4/8/05 EPSTEIN WON Travel to engage in illicit sexual conduct Ct 45 4/27/05 EPSTEIN WON Travel to engage in illicit sexual conduct Ct. 46 • 5/6/05 EPSTEIN Ur HYPERION Travel to engage in illicit sexual conduct Ct. 47 5/19/05 EPSTEIN WON Travel to engage in illicit sexual conduct Ct. 51 12/6/04 - EPSTEIN Recruiting, enticing, providing, or 6/2/05 in obtaining a person, knowing that she is a minor and will be caused to engage in a commercial sex act CONFIDENTIAL GRAND JURY MATERIAL PAGE 3 OF 3 JANE DOE #3 EFTA01713631 DOE #4 COUNT/O.A. DATE DEFENDANT(S) CHARGE O.A. 4 4/25/04 Conspiracy to entice a minor to engage in prostitution O.A. 6 5/3/04 Conspiracy to entice a minor to engage in prostitution O.A. 8 5/14/04 Conspiracy to entice a minor to engage in prostitution O.A. 9 5/20/04 Conspiracy to entice a minor to engage in prostitution O.A. 11 6/3/04 Conspiracy to entice a minor to engage in prostitution O.A. 14 6/11/04 Conspiracy to entice a minor to engage in prostitution O.A. 15 6/20/04 Conspiracy to entice a minor to engage in prostitution O.A. 19 7/10/04 Conspiracy to entice a minor to engage in prostitution O.A. 24 7/18/04 Conspiracy to entice a minor to engage in prostitution O.A. 25 7/22/04 Conspiracy to entice a minor to engage in prostitution O.A. 29 7/22/04 Conspiracy to entice a minor to engage in prostitution O.A. 30 8/4/04 Conspiracy to entice a minor to engage in prostitution O.A. 37 8/25/04 . Conspiracy to entice a minor to engage in prostitution O.A. 43 10/3/04 Conspiracy to entice a minor to engage in prostitution O.A. 47 10/30/04 Conspiracy to entice a minor to engage in prostitution 'CONFIDENTIAL GRAND JURY MATERIAL PAGE I OF 3 JANE DOE #4 EFTA01713632 COUNT/O.A. DATE DEFENDANT(S) CHARGE O.A. 48 11/4/04 Conspiracy to entice a minor to engage in prostitution O.A. 77 1/4/05 Conspiracy to entice a minor to engage in prostitution O.A. 87 1/22/05 Conspiracy to entice a minor to engage in prostitution O.A. 101 2/14/05 Conspiracy to entice a minor to engage in prostitution O.A. 106 2/24/05 Conspiracy to entice a minor to engage in prostitution O.A. 114 3/18/05 Conspiracy to entice a minor to engage in prostitution O.A. 116 3/29/05 i Conspiracy to entice a minor to engage in prostitution O.A. 127 • 4/11/05 = Conspiracy to entice a minor to engage in prostitution Ct. 8 4/25/04 - 6/29/05 EPSTEIN Enticement of a minor to engage in prostitution Ct. 17 5/21/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 18 6/4/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 19 6/20/04 EPSTEIN Travel to engage in illicit sexual PIM conduct CONFIDENTIAL GRAND JURY MATERIAL PAGE 2 OF 3 JANE DOE #4 EFTA01713633 COUNT/O.A. DATE DEFENDANT(S) CHARGE • Ct. 22 7/22/04 EPSTEIN it i l l . Travel to engage in illicit sexual conduct Ct. 23 8/6/04 EPSTEIN i. Travel to engage in illicit sexual conduct Ct. 28 11/5/04 EPSTEIN PM. conduct Travel to engage in illicit sexual Ct. 35 1/6/05 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 40 2/24/05 EPSTEIN JEGE Travel to engage in illicit sexual conduct Ct. 43 3/31/05 EPSTEIN !W Travel to engage in illicit sexual conduct Ct 52 4/25/05 - 6/29/05 EPSTEIN En Recruiting, enticing, providing, or obtaining a person, knowing that she is a minor. and will be caused to engage in a commercial sex act CONFIDENTIAL GRAND JURY MATERIAL PAGE 3 OF 3 JANE DOE #4 EFTA01713634 JANE DOE #5 COUNT/O.A. DATE DEFENDANT(S) CHARGE O.A. 53 11/17/04 Conspiracy to entice a minor to engage in prostitution O.A. 58 12/5/04 Conspiracy to entice a minor to engage in prostitution O.A. 61 12/13/04 Conspiracy to entice a minor to engage in prostitution O.A. 65 12/14/04 Conspiracy to entice a minor to engage in-prostitution O.A. 69 12/18/04 Conspiracy to entice a minor to engage in prostitution. O.A. 72 12/23/04 EPSTEIN Conspiracy to entice a minor to engage in prostitution O.A. 74 1/1/05 Conspiracy to entice a minor to engage in prostitution O.A. 81 1/8/05 Conspiracy to entice a minor to engage in prostitution O.A. 82 1/9/05 a Conspiracy to entice a minor to engage in prostitution O.A. 88 1/26/05 a Conspiracy to entice a minor to engage in prostitution O.A. 91 2/1/05 Conspiracy to entice a minor to engage in prostitution O.A. 98 2/10/05 Conspiracy to entice a minor to engage in prostitution O.A. 107 2/25/05 Conspiracy to entice a minor to engage in prostitution O.A. 108 3/1/05 Conspiracy to entice a minor to engage in prostitution O.A. 111 3/16/05 Conspiracy to entice a minor to engage in prostitution CONFIDENTIAL GRAND JURY MATERIAL PAGE I OF 3 JANE DOE #5 EFTA01713635 COUNT/O.A. DATE DEFENDANT(S) CHARGE O.A. 115 3/21/05 = Conspiracy to entice a minor to engage in prostitution Ct. 9 11/14/04 - 3/29/05 EPSTEIN Enticement of a minor to engage in prostitution Ct. 30 11/18/04 EPSTEIN igia conduct Travel to engage in illicit sexual Ct. 31 12/3/04 EPSTEIN JEGE Travel to engage in illicit sexual conduct Ct. 32 12/13/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct CL 34 1/1/05 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 37 2/3/05 EPSTEIN JEGE Travel to engage in illicit sexual conduct Ct. 38 2/10/05 EPSTEIN ilk IP. link Travel to engage in illicit sexual conduct Ct. 39 • 2/21/05 EPSTEIN JEGE 'Travel to engage in illicit sexual conduct CONFIDENTIAL GRAND JURY MATERIAL PAGE 2 OF 3 JANE DOE #5 EFTA01713636 COUNT/O.A. DATE DEFENDANT(S) CHARGE Ct. 41 3/4/05 EPSTEIN Travel to engage in illicit sexual conduct JEGE Ct. 42 3/18/05 EPSTEIN .W Travel to engage in illicit sexual conduct Ct. 53 11/14/04 - EPSTEIN Recruiting, enticing, providing, or 3/29/05 obtaining a person, knowing that she is a minor and will be caused to engage in a commercial sex act CONFIDENTIAL GRAND JURY MATERIAL PAGE 3 OF 3 JANE DOE #5 EFTA01713637 JANE DOE fSAMIMI COUNT/O.A. DATE DEFENDANT(S) CHARGE O.A. 21 7/15/04 Conspiracy to entice a minor to engage in prostitution O.A. 26 7/22/04 Conspiracy to entice a minor to engage in prostitution O.A. 34 8/19/04 Conspiracy to entice a minor to engage in prostitution O.A. 38 8/25/04 Conspiracy to entice a minor to engage in prostitution O.A. 49 11/7/04 Conspiracy to entice a minor to engage in prostitution O.A. 51 11/10/04 Conspiracy to entice a minor to engage in prostitution O.A. 52 11/17/04 Conspiracy to entice a minor to engage in prostitution O.A. 55 12/1/04 Conspiracy to entice a minor to engage in prostitution O.A. 57 12/4/04 Conspiracy to entice a minor to engage in prostitution O.A. 62 12/13/04 Conspiracy to entice a minor to engage in prostitution O.A. 68 12/17/04 Conspiracy to entice a minor to engage in prostitution O.A. 73 12/29/04 Conspiracy to entice a minor to engage in prostitution Ct. 10 7/15/04 - 12/29/04 EPSTEIN Enticement of a minor to engage in prostitution Ct. 21 7/16/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct CONFIDENTIAL GRAND JURY MATERIAL PAGE 1 OF 3 JANE DOE #6 EFTA01713638 COUNT/O.A. DATE DEFENDANT(S) CHARGE Ct. 22 7/22/04 EPSTEIN an conduct Travel to engage in illicit sexual Ct. 23 8/6/04 EPSTEIN i. Travel to engage in illicit sexual conduct Ct. 24 8/19/04 EPSTEIN JEGE Travel to engage in illicit sexual conduct Ct. 25 8/25/04 EPSTEIN P conduct Travel to engage in illicit sexual Ct. 29 11/10/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 30 11/18/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 31 12/3/04 EPSTEIN W conduct Travel to engage in illicit sexual Ct. 32 12/13/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct Ct. 33 12/17/04 EPSTEIN HYPERION Travel to engage in illicit sexual conduct CONFIDENTIAL GRAND JURY MATERIAL PAGE 2 OF 3 JANE DOE #6 EFTA01713639 COUNT/O.A. DATE DEFENDANT(S) CHARGE Ct. 54 7/15/04 - EPSTEIN Recruiting, enticing, providing, or 12/29/04 obtaining a person, knowing that she is a minor and will be caused to engage in a commercial sex act CONFIDENTIAL GRAND JURY MATERIAL PAGE 3 OF 3 JANE DOE #6 EFTA01713640 r/e2.7., p UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 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) UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, a/k/a and INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defendant JEFFREY EPSTEIN employed defendants ailda ‘1= ' and to perform, among other things, services as personal assistants. EFTA01713641 2. Defendant JEFFREY EPSTEIN employed to perform, among other things, services as a personal assistant. 3. Defendants JEFFREY EPSTEIN and paid ., and ■ to perform, among other things, recruiting services. 4. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brill° Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 5. Defendant JEFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. 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. 7. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 8. Defendant JEFFREY EPSTEIN was the 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-11598 aircraft bearing tail number N909JE. 9. 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. 2 EFTA01713642 10. 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." 11. 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. 12. Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who [i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or lascivious conduct," which is a felony of the second degree. 3 EFTA01713643 13. 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. 14. 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]." 15. 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]." 16. 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." 17. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical license. 4 EFTA01713644 18. During the period of her involvement with the Defendants, Jane Doe #4 attended High School and High School in Palm Beach County. 19. During the period of her involvement with the Defendants, Jane Doe #5 attended a High School in Palm Beach County. 20. During the period of their involvement with the Defendants, Jane Does # 6, 8 and 12 attended High School in Palm Beach County. 21. During the period of her involvement with the Defendants, Jane Doe #7 attended High School in Palm Beach County. 22. During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 17, 18, and 19 attended High School in Palm Beach County. 23. During the period of her involvement with the Defendants, Jane Doe #10 attended High School in Palm Beach County. 24. During the period of her involvement with the Defendants, Jane Doe #11 attended the School, a public high school, located in New York, New York. 25. During the period of her involvement with the Defendants, Jane Doe #13 attended High School in Palm Beach County. 5 EFTA01713645 COUNT 1 (Conspiracy: 18 U.S.C. § 371) 26. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 27. 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, jra JEFFREY EPSTEIN, iz 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 28. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way and the New York residence 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. 6 EFTA01713646 Manner and Means 29. 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 anda " and other participants would contact minor females via the use of cellular and other telephones to arrange appointments for minor females to travel to 358 El Brillo Way and the New York residence to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. (b) EPSTEIN, It was further a part of the conspiracy that Defendants JEFFREY and a 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) EPSTEIN, It was further a part of the conspiracy that Defendants JEFFREY aikia " 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, anda and other participants would make payments to, or cause payments to be made to, the recruiters for 7 EFTA01713647 bringing additional minor females to 358 El Brillo Way and the New York residence 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 30. 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 (1) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity with Jane Doe #1, who was then a •-year-old girl, in the presence of Jane Doe #2, who was then a -year-old girl. (2) In or around 2001, Defendant led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEN's bedroom at 358 El Brill& Way. (3) In or around 2001, Defendant JEFFREYEPSTEIN masturbated in the presence of Jane Doe #2, who was then a =year -old girl. (4) In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, who was then fourteen years' old, to while he masturbated. 8 EFTA01713648 (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 #2 to travel to 358 El Brillo Way. (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 year-old girl. (8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a--year-old girl, for allowing an unidentified female to perform on Jane Doe #2 in EPSTEIN's presence. (9) On or about March 11, 2003, an employee of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's review 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 activities with him. (11) In or around 2003, Defendant took nude photographs of Jane Doe #2,who was then a year-old girl. 9 EFTA01713649 (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 told Jane Doe #2 that Defendant JEFFREY EPSTEIN had askee to take nude photographs of Jane Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a -year-old girl. (15) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a -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 Doe #3 (19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #3, who was then a Myear-old girl. I0 EFTA01713650 (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. (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 or I.-year-old girl, to Ifln adult female and to the adult female's (24) In or around 2004, Defendant JEFFREY EPSTEIN placed fan adult female in the presence of Jane Doe #3, who was then a or eyear-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 (27) In or around 2004, Defendant JEFFREY EPSTEIN placed a of Jane Doe #3, who was then a or -year-old girl. 11 EFTA01713651 (28) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. (29) On or about November 8, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review 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, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 that read: "I 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 asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. 12 EFTA01713652 (34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #4, who was then a ayear-old-girl, and Jane Doe #5, who was then a IMM-year-old girl. (35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a -year-old girl, to plal (36) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a -year-old girl, to remove her clothing. (37) In or around the first half of 2004, Defendant JEFFREY EPSTEIN of Jane Doe #4, who was then a -year-old girl. (38) In or around the first half of 2004, Defendant JEFFREY EP STEIN paid $200 to Jane Doe #4. (39) In or around the first half of 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. 13 EFTA01713653 (42) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #6, who was then a -year-old girl. (43) In or around the first half of 2004, Defendant JEFFREY EPSTEIN ane Doe #6, who was then a -year-old girl. (44) In or around the first half of 2004, Defendant JEFFREY EPSTEIN placed a of Jane Doe #6, who was then a -year-old girl. (45) In or around the first half of 2004, Defendant JEFFREY EPSTEIN caused a payment of $200 to be paid to Jane Doe #6. Jane Does #7 and #8 (46) In or around July 2004, Defendant JEFFREY EPSTEIN leds who was then a -year-old girl, and Jane Doe #7, who was then a a -years-old girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (47) On or about July 4, 2004, Defendant made one or more telephone calls 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 I4 EFTA01713654 (49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #8, who was then a la -year-old girl. (50) In or around July 2004, Defendant JEFFREY EPSTEIN Hof Jane Doe #8, who was then a -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 for recruiting Jane Doe #8 to travel to 358 El Brillo 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, Defendants placed one or more telephone calls to a telephone used by Jane Doe #7. (55) On or about July 15, 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. 15 EFTA01713655 (58) On or about July 16, 2004, Defendant placed a telephone call to a telephone used by (59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant JEFFREY EPSTEIN's review 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 -year-old girl. (61) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #7, who was then a_ -year-old girl, to (62) In or around July 2004, Defendant JEFFREY EPSTEIN of Jane Doe #7, who was then a -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 to telephone call to a telephone used by Jane Doe #8. 16 EFTA01713656 Jane Does #9 and #10 (66) On or about July 15, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #9. (67) On or about July 16, 2004, Defendant caused Jane Doe #9 to make one or more telephone calls 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 of Jane Doe #9, who was then a eyear-old girl. (72) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #9, who was then a -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. 17 EFTA01713657 (75) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and engaged in In in the presence of Jane Doe #9, who was then a ayear-old girl. (76) In or around the last half of 2004, Defendant JEFFREY EPSTEIN of Jane Doe #9, who was then a year-old girl. (77) In or around the last half of 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 of Jane Doe #10, who was then a ayear-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 #10] 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. 18 EFTA01713658 (83) On or about December 30, 2004, Defendants JEFFREY EPSTEIN and caused the purchase of Broadway tickets as an birthday gift for Jane Doe #9. (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 year-old girl. (85) In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN of Jane Doe #10, who was then a ayear-old girl. (86) On or about January 14, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (87) On or about January 27, 2005, Defendant la 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 $200 to be made to Jane Doe #9 for recruiting Jane Doe #16 to travel to 358 El Brillo Way. 19 EFTA01713659 Jane Doe #11 (91) In or around 2004, Defendant JEFFREY EPSTEIN told Jane Doe #11 that he would pay her to fmd and bring him more girls. (92) In or around 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #11 for recruiting a minor female to travel to his New York home. (93) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #11 when she would be getting more girls. (94) On or about April 5, 2005, one of Defendant JEFFREY EPSTEIN's employees prepared a written message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #11 that read: "Re does she have any new friends you can meet — I was away over the weekend so I have not spoken to anyone new. But, [unidentified Jane Doe] will be around later today and I know she really wants to work. The others should be back around Thursday. Let me know about [unidentified Jane Doe]." (95) On or about June 22, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #11. Jane Does #12 and #13 (96) On or about August 2, 2004, an employee of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #13] too". 20 EFTA01713660 (97) On or about August 21, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #13. (98) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #12, who was then a -year-old girl. (99) In or around the last half of 2004, Defendant JEFFREY EPSTEIN Jane Doe #12, who was then a year-old girl. • (100) In or around the last half of 2004, Defendant JEFFREY EPSTEIN flane Doe #12, who was then a seventeen-year-old girl. (101) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #12. (102) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #12, who was then a eyear-old girl, about her age. (103) 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 (104) 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. (105) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #13, who was then a eyear-old girl. 21 EFTA01713661 (106) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed a of Jane Doe #13, who was then a nyear- old girl. (107) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #13. (108) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #13, who was then a la -year-old girl. (109) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13, who was then a nyear-old girl, about her age. (110) In or around the last half 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 years old. (111) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13 to bring her friends to his home, especially "girls who looked like [Jane Doe #13]." Jane Doe #14 (112) 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. (113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #14 to provide her telephone number. 22 EFTA01713662 (114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #14, who was then a -year-old girl, to (115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #14, who was then a -year old girl. (1 I 6) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #14. (117) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN Jane Doe #14, who was then a year-old girl. (118) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #14, who was then a ayear-old girl, whether she had any plans for her birthday and acknowledged that she had not yet turned (119) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #14. (120) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a of Jane Doe #14, who was then a year-old girl. (121) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged in with Jane Doe #14, who was then an -year-old girl. 23 EFTA01713663 (122) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN performed on Jane Doe #14, who was then a -year-old girl. (123) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $600 to Jane Doe #14. (124) On or about January 8, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. (125) On or about January 9, 2005, Defendant a/k/a placed a telephone call to a telephone used by Jane Doe #14. (126) On or about January 26, 2005, one of Defendant JEFFREY EPSTEIN's employees prepared a written telephone message for Defendant review regarding a call received from Jane Doe #14 that read: "She is confirming for 5:30". (127) On or about January 26, 2005, Defendant S S a/k/a 41 placed a telephone call to a telephone used by Jane Doe #14. (128) On or about February 1, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. (129) On or about March 1, 2005, Defendant a/k/a placed a telephone call to a telephone used by Jane Doe #14. (130) On or about March 21, 2005, Defendant a/k/a placed a telephone calls to a telephone used by Jane Doe #14. 24 EFTA01713664 (131) On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. Jane Doe #15 (132) On or about December 6, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. (133) On or about December 14, 2004, Defendant la placed a telephone call to a telephone used by Jane Doe #15. (134) In or around the first half of 2005, Defendant led Jane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (135) In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #15, who was then a -year-old girl, to while he masturbated. (136) In or around the first half of 2005, Defendant JEFFREY EPSTEIN of Jane Doe #15. (137) In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #15. (138) On or about January 7, 2005, Defendant a/k/a placed a telephone call to a telephone used by Jane Doe #15. 25 EFTA01713665 (139) On or about February 4, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (140) On or about February 10, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (141) On or about February 21; 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (142) On or about February 24, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (143) On or about March 17, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (144) On or about March 30, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (145) On or about March 31, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (146) On or about March 31, 2005, Defendant S alicht placed a telephone call to a telephone used by Jane Doe #15. (147) On or about April 1, 2005, one of Defendant JEFFREY EPSTEIN's employees prepared a note for Defendant JEFFREY EPSTEIN's review that read: "10:30 [Jane Doe #15]/[Jane Doe #10] on Fri around 2'Oclock". (148) In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane Doe #15 with a gift of Victoria's Secret lingerie for her birthday. 26 EFTA01713666 Jane Does #16 & #17 (149) In or around February 2005, Defendant JEFFREY EPSTEIN . masturbated in the presence of Jane Doe #16, who was then a -year-old girl. (150) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #16 to place a telephone call to Jane Doe #17 to ask her to travel to 358 El Brillo Way. (151) 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 Brillo Way. (152) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #17, who was then a -year-old girl. (153) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #17, who was then a -year-old girl, to remove all of her clothing. (154) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a of Jane Doe #17, who was then a year-old girl. (155) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #17, who was then a -year-old girl. 27 EFTA01713667 (156) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN placed a of Jane Doe #16, who was then a n -year-old girl. (157) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a -year-old girl, how old she was, and she responded that she was n years old. (158) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN engaged in sexual activity with Defendan in the presence of Jane Doe #16, who was then a -year-old girl. (159) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, ton of Defendant (160) On or about April 11, 2005, Defendant S a/k/a 'fl placed a telephone call to a telephone used by Jane Doe #16. (161) On or about April 11, 2005, Defendant telephone call to a telephone used by Jane Doe #16. (162) On or about April 11, 2005, Defendant placed a . left a message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] can work tomorrow at 4pm." (163) On or about May 19, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 28 EFTA01713668 (164) On or about June 30, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (165) On or about July 2, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (166) On or about July 22, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (167) On or about August 18, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (168) On or about August 19, 2005, Defendant S a/Ida placed a telephone call to a telephone used by Jane Doe #16. (169) On or about August 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (170) On or about September 3, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (171) On or about September 18, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (172) On or about September 19, 2005, Defendant sent a text message to a telephone used by Jane Doe #16. (173) On or about September 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 29 EFTA01713669 (174) On or about September 30, 2005, Defendant a/k/a placed a telephone call to a telephone used by Jane Doe #16. (175) On or about October 1, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #15] confirmed at 11 AM and [Jane Doe #16] — 4PM". (176) On or about October 2, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (177) On or about October 3, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. (178) On or about October 3, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] will be 1/2 hour late". (179) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN engaged in with Jane Doe #16, who was then a -year-old girl. (180) 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 year-old girl. (181) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN provided a gift of Victoria's Secret lingerie to Jane Doe #16 for her birthday. 30 EFTA01713670 Jane Does #18 and #19 (182) 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. (183) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to provide her telephone number. (184) On or around August 27, 2003, Defendant placed a telephone call to a telephone used by Jane Doe #18. (185) In or around the last half of 2003, Defendant JEFFREY EPSTEIN masturbated in the presence ofJane Doe #18, who was then a ayear-old-girl. (186) On or around November 16, 2003, Defendant placed a telephone call to a telephone used by Jane Doe #18. (187) In or around the last half of 2003, Defendant JEFFREY EPSTEIN. Jane Doe #18, who was then a nyear-old-girl. (188) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to recruit other females to travel to 358 El Brillo Way. (189) On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #19, who was then a eyear-old girl, to leave when she refused to remove her shirt. 31 EFTA01713671 (190) 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 (191) On or about March 11, 2004, Defendants JEFFREY EPSTEIN,la and traveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (192) On or about May 1, 2004, Defendants JEFFREY EPSTEIN, traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (193) On or about May 14, 2004, Defendants JEFFREY EPSTEIN, and traveled from Canada to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (194) 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. (195) 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. 32 EFTA01713672 (196) 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. (197.) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (198) 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. (199) 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. (200) 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. (201) On or about October 2, 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. 33 EFTA01713673 (202) 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. (203) 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. (204) On or about November 18, 2004, Defendants JEFFREY EPSTEIN, anda and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (205) 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. (206) 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. (207) 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. 34 EFTA01713674 (208) On or about January 1, 2005, Defendants JEFFREY EPSTEIN, ancMI traveled from Anguilla, British West Indies to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (209) 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. (210) On or about January 14, 2005, Defendants JEFFREY EPSTEIN, anda and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (211) On or about January 19, 2005, Defendants JEFFREY EPSTEIN, anda ' and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (212) 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. (213) On or about February 10, 2005, Defendants JEFFREY EPSTEIN, ailda 35 and EFTA01713675 traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (214) On or about February 21, 2005, 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. (215) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (216) On or about March 4, 2005, Defendants JEFFREY EPSTEIN, anda (=MM . anc .traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (217) 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. (218) 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. 36 EFTA01713676 (219) On or about May 19, 2005, Defendants JEFFREY EPSTEIN, and a a ailda traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (220) 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. (221) 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. (222) On or about August 18, 2005, Defendants JEFFREY EPSTEIN, anda an traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (223) On or about September 3, 2005, Defendants JEFFREY EPSTEIN and a .= te a' traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (224) On or about September 18, 2005, Defendants JEFFREY EPSTEIN, and 37 a/k/a traveled from EFTA01713677 Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (225) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, a/Ida =a anc li 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 10 (Sex Trafficking: 18 U.S.C. § 1591(a)(1)) 31. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 32. 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): LCount Date(s) Minor Involved Defendant(s) 2 2001 - 2004 Jane Doe #2 JEFFREY EPSTEIN 38 EFTA01713678 Count Date(s) Minor Involved Defendant(s) 3 January 2004 through July 2004 Jane Doe #4 JEFFREY EPSTEIN 4 July 2004 through December 29, 2004 Jane Doe #9 JEFFREY EPSTEIN 5 July 2004 through January 31, 2005 Jane Doe #10 JEFFREY EPSTEIN 6 Mid-2004 through ' April 22, 2005 Jane Doe #12 JEFFREY EPSTEIN 7 August 2004 through May 27, 2005 Jane Doe #13 JEFFREY EPSTEIN 8 November 2004 through March 2005 Jane Doe #14 JEFFREY EPSTEIN 9 December 2004 through June 5, 2005 Jane Doe #15 JEFFREY EPSTEIN a/l a 10 February 2005 through first week of October 2005 Jane Doe #16 JEFFREY EPSTEIN a All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2. 39 EFTA01713679 COUNT 11 (Sex Trafficking: 18 U.S.C. § 1591(a)(2)) 33. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 34. 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 taniand did knowingly benefit, financially or by receiving anything of value, from participation in a venture, as defined in 18 U.S.C. § 1591(c)(3), which had engaged in an act described in violation of 18 U.S.C. § 1591(a)(1), that is, the recruiting, enticing, providing, and obtaining by any means a person, in or affecting interstate commerce, knowing that the person or persons had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, Sections 1591(a)(2), 1591(b)(2), and 2. COUNT 12 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 35. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 40 EFTA01713680 36. 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 43, 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 13 (Enticement of a Minor: 18 U.S.C. § 2422(6)) 37. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 38. From in or around January 2004 through 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 41 EFTA01713681 did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #4, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 14 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 39. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 40. 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 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 15 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 41. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 42 EFTA01713682 42. From in or around July 2004 through on or around December 29, 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and 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 18, United States Code, Sections 2422(b) and 2. COUNT 16 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 43. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 44. 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 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 43 EFTA01713683 of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 17 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 45. Paragraphs 1 through 25 of this Indictment are 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 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 18 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 47. Paragraphs 1 through 25 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, 44 EFTA01713684 JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #13, who was a person who had not attained the age • of 18 years, to engage in prostitution; 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)) 49. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 50. From in or around November 2004 through in or around March 2005, the exact dates being unknown to the Grand July, 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 #14, 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. 45 EFTA01713685 COUNT 20 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 51. Paragraphs 1 through 25 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, JEFFREY EPSTEIN, and a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #15, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 21 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 53. Paragraphs I through 25 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 Beach County, in the Southern District of Florida, and elsewhere, the defendants, 46 EFTA01713686 JEFFREY EPSTEIN, and 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 22 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 55. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 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, JEFFREY EPSTEIN, and a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #17, 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. 47 EFTA01713687 COUNT 23 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 57. Paragraphs 1 through 25 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, JEFFREY EPSTEIN, 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 of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 24 (Conspiracy to Travel: 18 U.S.C. § 2423(e)) 59. Paragraphs 1 through 25 of this indictment are re-alleged and incorporated by reference as fully set for the 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, JEFFREY EPSTEIN, asal and 48 EFTA01713688 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 25 (Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d)) 61. Paragraphs 1 through 25 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, did, for the purpose of commercial advantage or private financial gain, arrange and facilitate the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d). COUNTS 26 THROUGH 29 (Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b)) 63. Paragraphs 1 through 25 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 49 EFTA01713689 Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in 18 U.S.C. § 2423(f), with a person under 18 years of age, that is, the person(s) listed in each count below: Count Date(s) Minor(s) Involved Defendant(s) 26 7/16/2004 Jane Doe #7 Jane Doe #8 Jane Doe #9 Jane Doe #10 JEFFREY EPSTEIN 27 3/31/2005 Jane Doe #14 Jane Doe #15 Jane Doe #16 JEFFREY EPSTEIN I a 28 9/18/2005 Jane Doe #16 JEFFREY EPSTEIN a. a 29 9/29/05 Jane Doe #16 JEFFREY EPSTEIN I a/k/ ' All in violation of Title 18, United States Code, Sections 2423(b) and 2. FORFEITURE 1 Upon conviction of the violation alleged in Count 1 of this indictment, the defendants, JEFFREY EPSTEINI ailda and shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. 50 EFTA01713690 Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21, United States Code, Section 853. If the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, ailda 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 12-29 of this indictment, the defendants, JEFFREY EPSTEIN, alida shall forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other proceeds obtained from such 51 EFTA01713691 offense; and any property, real or personal, used or intended to be used to commit or to promote the commission of such offense, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 2253. If any of the forfeitable property described in the forfeiture section of this indictment, as a result of any act or omission of the defendants JEFFREY EPSTEIN, 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 52 EFTA01713692 (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 2-11 of this indictment, the defendants, JEFFREY EPSTEIN, and a/k/a 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 froth 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 53 EFTA01713693 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' orth 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 A. MARIE VILLAFARA ASSISTANT UNITED STATES ATTORNEY 54 EFTA01713694 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, JEGE, INCA HYPERION AIR, INC., Defendants. INDICTMENT The Grand Jury charges that: BACKGROUND !LW among other things, services as personal assistants.. At all times relevant to this Indictment: 1. Defendant JEFFREY EPSTEIN employed defendants olok, ailda and to perform, EFTA01713695 Y • 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 Defendant 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. kw' -L.M..v4-)Pj as \Oa-6 r3-127 4. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of Defendant JEGE, INC., and had the power to direct all of its operations. 5. Defendant JEFFREY EPSTEIN was a principal owner of Defendant HYPERION AIR, INC., a Delaware corporation. HYPERION AIR, INC.'s sole business activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. 6. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of Defendant HYPERION AIR, INC., and had the power to direct all of its operations. COUNT 1 (Conspiracy: 18 U.S.C. § 371) 7. Paragraphs 1 through 6 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 8. From at least as early as March 2004, the exact date being unknown to the Grand Jury, through in or about October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, 2 EFTA01713696 C • JEFFREY EPSTEIN, JE INC., an HYPERION AIR, INC., did knowingly and willfully combine, conspire, confederate and agree with each other and with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate ot=foreign commerce to knowingly persuade, induce, or entice individuals who had not attained the age of 18 years to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense, in violation of Title 18, United States Code, Section 2422(b). Purpose and Object of the Conspiracy 9. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way, Palm Beach, Florida so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. Manner and Means 10. The manner and means by which the defendants and other participants sought to accomplish the purpose and object of the conspiracy included the following: (a) It was part of the conspiracy that Defendants = a/Ida ` ancOM M, would contact 3 EFTA01713697 minor females via the use of cellular and other telephones to arrange appointments for minor females to travel to 358 El Brillo Way to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, afk/a and 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, S S a/k/a and 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, anda and would make payments to, or cause payments to be made to, the recruiters for bringing additional minor females to 358 El Brillo Way to engage in lewd conduct with Defendant JEFFREY EPSTEIN. 4 EFTA01713698 t Overt Acts 11. In furtherance of this conspiracy and to effect the objects thereof, there was committed by at least one of the co-conspirators herein, at least one of the following overt acts, among others in the Southern District of Florida: (1) On March 11, 2004, Defendants JEFFREY EPSTEIN, a and traveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (2) On or about March 12, 2004, Defendants JEFFREY EPSTEIN and i Raz,' •€AA, Florida t'20-4g-re-c-P 1 t.,,,..... 1:/,1,•5„.,k1- lvvArcir-t- i-t...- a st i......6 ejt: caused Jane Doe #1 to travel to , Palm Beach Ø. C. t _Lk la `• <N zre caYWKA W• rt3"-- * Ma ' VatA4Z4,41. A- - tos o sli-g„.L v.......,„ % e v..._ Ai...... so 4 ,....."-A.., Prfl `..sh -'-fit fi 1 %.•%/l .08 Loll #) (.. (3 ,n or about taE.211.12, 2004, Defendant JEFFREY EPSTE e a St—te-r—s-sl m ,,Os. 01 4-1.13t.ik kt-tA 0 -Act .. v-ec.‘tel payment of $200 to Jane Doe #1. ( ,•>240.,-ei .CP t P . A..) 7:. C. tri vi-- $- 4tr•-7., 4. • (4) On April 25, 2004, Defend-ant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (5) On May 1, 2004, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. 5 EFTA01713699 (6) On May 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (7) On May 14, 2004, Defendants EPSTEIN, and• traveled from Canada to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (8) On May 14, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (9) On May 20, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (10) On May 21, 2004, Defendants EPSTEIN and -traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (11) On June 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (12) On June 4, 2004, Defendants EPSTEIN and traveled from New Haven, Connecticut to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 6 EFTA01713700 I , • (13) On June 11, 2004, Defendants EPSTEIN and traveled from Chicago, Illinois to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On June 11, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. On June 20, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (16) On June 20, 2004, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (17) On. July 4, 2004, Defendants EPSTEIN, S and traveled from Aspen, Colorado to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (18) On July 4, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #12. (19) On July 10, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (20) On July 10, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #12. 7 EFTA01713701 I r (21) On July 15, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. (22) On July 16, 2004, Defendants EPSTEIN, a and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (23) On July 16, 2004, Defendant caused Jane Doe # 6 to make one or more telephone calls to a telephone used by Jane Doe # 7. (24) On July 18, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. ) On July 22, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (26) On July 22, 2004, Defendant la caused a telephone call to be made to a telephone used by Jane Doe #6. (27) On July 22, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (28) On July 22, 2004, Defendants EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. 8 EFTA01713702 (29) On July 22, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (30) On August 4, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (31) On August 6,2004, DefendantS EPSTEIN andl traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (32) On August 17, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (33) On August 19, 2004, Defendants EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (34) On August 19, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. (35) On August 21, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe # 13. (36) On August 25, 2004, Defendants EPSTEIN, and traveled from Ecuador to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. EFTA01713703 (37) On August 25, 2004, Defendant telephone calls to be made to a telephone used by Jane Doe #4. (38) On August 25, 2004, Defendant■ made to a telephone used by Jane Doe #6. (39) On August 25, 2004, Defendant caused one or more caused a telephone call to be caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (40) On September 16, 2004, Defendants EPSTEIN, S and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant, JEGE, INC. (41) On September 16, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (42) On October 2, 2004, Defendants EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (43) On October 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (44) On October 3, 2004, Defendant caused one or more telephone calls lo be made to a telephone used by Jane Doe #7. 10 EFTA01713704 (45) On October 26, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (46) On October 29, 2004, Defendants EPSTEIN, S and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant, HYPERION, AIR, INC. (47) On October 30, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (48) On November 4, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (49) On November 7, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6. (50) On November 10, 2004, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (51) On November 10, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. (52) On November 17, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6. 11 EFTA01713705 1* IR-C-1/4) .% teM ee•ovv-. (at cord/ .s \Jet c-Seck. 4e\ tet-oefe Govvirmu.4- 104.4-r,tc.eve Via•a‘/S- aru 4r- As tivtAl s s-LA•ttevw.1- s ItstA4 k *153) On or about November 17, 2004, Defendant n caused a Pt k e 3/4 ..ke tr-et-v.-cc" #S taatfrzetrr telepone cail • (54) On or about November 18, 2004, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (55) On December 1, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6. (56) On or about December 3, 2004, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. On December 4, 2004, Defendant provided a written message ess A)1-41._ met:.e.:,,cAQs& "cow(' ( rk to Defendant EPSTEIN regarding Jane Doe #6 and Jane Doe #7. Exe-ekk-eof, gr‘ i siLL 44 14" Se-Oa 3" We tarv1/4- v,, a,‘c Witsior (58) On or about December 5, 2004, rliasetil aA one or more telephone calls to be ma e to a to ep one used by Jane Doe #5. *(59) On or about December 6 2004 Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. %(60) On or about December 12, 2004, Defendant caused one or more telephone calls to be ma e o a eep one used by Jane Doe 3. 12 EFTA01713706 (61) On or about December 13, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (62) On December 13, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. (63) On or about December 13,2004, Defendant EPSTEIN traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (64) On or about December 14, 2004, Defendant made one or more telephone calls to Jane Doe #3. (65) On or about December 14, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (66) On December 16, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (67) On or about December 17, 2004, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (68) On December 17, 2004, Defendants caused a telephone call to be made to a telephone used by Jane Doe #6. 13 EFTA01713707 (69) On or about December 18, 2004, Defendant IMMI caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (70) On or about December 18, 2004, Defendant caused Jane Doe #10 to make one or more telephone calls to a telephone used by Jane Doe #11. (71) On or about December 20, 2004, Defendant EM caused one or more telephone calls to be made to a telephone used by Jane Doe #3. (72) On or about December 23, 2004, Defendant EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #5. (73) On December 29, 2004, Defendants caused a telephone call to be made to a telephone used by Jane Doe #6. (74) On or about January 1, 2005, Defendant MI caused a telephone call to be made to a telephone used by Jane Doe #5. (75) On January 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (76) On or about January 1, 2005, Defendants EPSTEIN, and traveled from Anguilla, British West Indies to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (77) On January 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 14 EFTA01713708 (78) On January 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #13. (79) On or about January 6, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. (80) On or about January 6, 2005, Defendant EPSTEIN traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (81) On or about January 8, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Ja.ne Doe #5. (82) On or about January 9, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (83) On or about January 14, 2005, Defendant made one or more telephone calls to Jane Doe #3. (84) On or about January 14, 2005, Defendants EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (85) On January 14, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. 15 EFTA01713709 (86) On or about January 19, 2005, Defendants EPSTEIN, aM and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. . (87) On January 22, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (88) On or about January 26, 2005, Defendant= reviewed a telephone message from Jane Doe #5. (89) On January 27, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (90) On January 28, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (91) On or about February 1,2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (92) On February 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. (93) On or about February 3, 2005, Defendants EPSTEIN, and traveled from Columbus, Ohio, to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (94) On or about February 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. 16 EFTA01713710 (95) Op or about February 6„2005 EPSTEIN and uGew tinons. ea Cataa %%AL taililt o 44 s 6.e\ n.c -3/4-ca Doe #1 to make one or more telephone cal s o ane oe /6't eveuto-sty (96) On or about February 6, 2005 EPSTEIN and cit., e.o.A Arts...eqtty., C ynAas ino-a-t. to o c.- VaiiirtArt- caused Jane wt-1/4\ c•-• 4in caused Jane Y\ t*t ‘a -t kf] ,rtt ••• kl b, g•S trt J•04.3 , , . ane Doe #2 to 358 El Brillo Way, Pa m eac , orida. (97) On or about February 6, 2005, EP made a payment of $300 to ...M a; tle•—•••)• Jane Doe #2 and a payment of $200 to Jane Doe #1. • (98) On or about February 10, 2005, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (99) On or about February 10, 2005, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (100) On or about February 10, 2005, Defendants caused one or more telephone calls to be made to a telephone used by Jane Doe #3. (101) On February 14, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (102) On or about February 21, 2005, Defendant a caused one or more telephone calls to be made to a telephone used by Jane Doe #3. _ (103) On or about February 21, 2005, Defendants EPSTEIN, S and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. 17 EFTA01713711 (104) On or about February 24, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. (105) On or about February 24, 2005, Defendants EPSTEIN, a and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (106) On February 24, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (107) On or about February 25, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (108) On or about March 1, 2005, Defendant MI caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (109) On or about March 4, 2005, Defendants EPSTEIN, Ing and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (110) On March 7, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (111) On or about March 16, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. (112) On or about March 17, 2007, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. 18 EFTA01713712 (113) On or about March 18, 2005, Defendant EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. (114) On March 18, 2005, Defendant prepared a written message to Defendant EPSTEIN regarding Jane Doe #4. (115) On or about March 21, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. On March 29, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (117) On or about March 30, 200 caused one or more calls to be a-e.vt poo C of d. cScekort cpv\latazA• \-vt_.-41) e•c r.Sk , maYelb a tftplione use yJane oe 1. (118) On or about March 30, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. (119) On or about March 31, 2005, Defendant EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. n (120) On or about March 31, 2005, caused one or more calls to be ttAA.3 arekteksv".c covvkcc.), ntuateIN -*s ioc\O t, made to a telepho e used by J . • • (121) On or about March 31, 2005, EPSTEIN traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. 19 EFTA01713713 K SakVati, car ( 3d ' t o Sock•Kv•tav w Gjo- tes7. (122) On or about March 31, 2005, EPSTEIN andacaused Jane Doe ••4 ?kw. re-tAv-i.t d:c4e/ -tch rho he Coniatc picen. noNbt-ef Mita 17) #1 to make a call to a telephone used by Jane Doe #2. =ad iinttim.4 IeP hone_ by caused Jane eity - 119- behril 4 (123) On or about April 1, 2005, EPSTEIN and Re.vitew k ant at , r IAd:CA:tad 4e. fer40/1 I r 4 14-1/4-SO 0 In 4 stews v 4.44.0.1/44. "A-cs or% Ze ericenatjj #1 to one or, more calls to a telephone used Jane Doe #2 ow. r ade." VOIlcati • I e. eittre Lit $44ov.v..1 LS"' eb'S" April c..eco-e-Wr (124) On April 2, 2005, Defendant= caused one or more telep one calls to be made to a telephone used by Jane Doe #8. (125) On or about April 8, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. (126) On or about April 8, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (127) On April 11, 2005, Defendant= caused one or more telephone calls to be made to a telephone used by Jane Doe #4. (128) On April 11, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (129) On or about April 26, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. (130) On or about April 27, 2005, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 20 EFTA01713714 (131) On or about May 6, 2005, Defendants EPSTEIN, a and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (132) On or about May 19, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #3. (133) On May 19, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (134) On or about May19, 2005, Defendants EPSTEIN,a and- traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (135) On June 8, 2005, Defendants EPSTEIN,IMI and= traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 • aircraft owned by Defendant, JEGE, INC. (136) On June 12, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (137) On June 18, 2005, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (138) On June 20, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. 21 EFTA01713715 (139) On June 30, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (140) On June 30, 2005, Defendants EPSTEIN, MM traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (141) On July 2, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (142) On July 22, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (143) On July 22, 2005, Defendants EPSTEIN, traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (144) On August 18, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (145) On August 18, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (146) On August 19, 2005, Defendant= caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (147) On August 21, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. 22 EFTA01713716 (148) On September 3, 2005, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (149) On September 3, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (150) On September 8, 2005, Defendant= received a telephone call from Jane Doe #8. (151) On September 9, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. . (152) On September 18, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (153) On September 18, 2005, Defendants EPSTEIN, I= and- traveled from Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. (154) On September 29, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. (155) On September 29, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 23 EFTA01713717 -(156) On October 3, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. 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 March 2004 through in or around October 2005; the exact dates being unknown to the Grand Jury, the defendants, JEFFREY EP8TEIN, C EM" cr y) IF-GL_Er—rand. did knowingly and willfully conspire with each other arid 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(1), with another person, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e). COUNT 3 (Facilitation of Unlawful Travel of Another: 18 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. 24 EFTA01713718 :5": • From at least as early as in or about March 2004 through in or about October .6; the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendant, did, for the purpose of commercial advantage or private 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). COUNT4 (Sex Trafficking: 18 U.S.C. § 1591(a)(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 March 2004 through in or about October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, and did knowingly benefit, financially or by receiving anything of value, from participation in a venture, as defined in 18 U.S.C. § 1591(c)(3), which had engaged in an act described in violation of 18 U.S.C. § 1591(a)(1), that is, the recruiting, enticing, providing, or obtaining by any means a person, in or affecting interstate conunerce, knowing that the person or 25 EFTA01713719 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. COUNTS 5 THROUGH 16 (Enticement of Minor: 18 U.S.C. § 2422(b)) 18. Paragraphs 1 through 6 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 #1 JEFFREY EPSTEIN 6 2/5/2005 - 2/6/2005 Jane Doe #2 JEFFREY EPSTEIN 7 12/6/2004 - 6/2/2005 Jane Doe #3 JEFFREY EPSTEIN 8 4/25/2004 - 6/29/2005 Jane Doe #4 JEFFREY EPSTEIN 26 EFTA01713720 COUNT DATE(S) MINOR INVOLVED DEFENDANT(S) ' 9 11/14/04 - 3/29/05 Jane Doe #5 JEFFREY EPSTEIN 10 7/15/04 - 12/29/04 Jane Doe #6 JEFFREY EPSTEIN 11 7/22/04 - 1/31/05 Jane Doe #7 JEFFREY EPSTEIN 12 2/13/05 - 10/3/05 Jane Doe #8 JEFFREY EPSTEIN 13 2/05 - 4/05 Jane Doe #9 JER4REY EPSTEIN 14 12/18/04 Jane Doe #11 JEFFREY EPSTEIN 15 7/4/04 - 7/19/04 Jane Doe #12 JEFFREY EPSTEIN 16 8/21/04 - 5/27/05 Jane Doe #13 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. 27 EFTA01713721 21. On or about the dates enumerated as to each count listed below, from a place outside the Southern District of Florida to a place inside the Southern District of Florida, the Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in 18 U.S.C. § 2423(f), with a person under 18 years of age, that is, the person(s) listed in each count below: COUNT DATE(S) MINOR(S) INVOLVED DEFENDANT(S) 17 5/21/2004 Jane Doe #4 JEFFREY EPSTEIN HYPERION AIR, INC. 18 6/4/2004 Jane Doe #4 JEFFREY EPSTEIN HYPERION AIR, INC. 19 6/20/2004 Jane Doe #4 JEFFREY EPSTEIN JEGE, INC. 20 7/4/2004 Jane Doe #12 JEFFREY EPSTEIN IMP. 21 7/16/2004 Jane Doe #6 Jane Doe #7 Jane Doe #12 JEFFREY EPSTEIN HYPERION AIR, INC. 22 7/22/2004 Jane Doe #4 Jane Doe #6 Jane Doe #7 JEFFREY EPSTEIN JE E, IN . 28 5z EFTA01713722 COUNT DATE(S) . MINOR(S) INVOLVED DEFENDANT(S) 31 12/3/2004 Jane Doe #5 Jane Doe ti6 JEFFREY EPSTEIN JEGE, INC. 32 12/13/2004 . Jane Doe #3 Jane Doe #5 Jane Doe #6 JEFFREY EPSTEIN HYPERION AIR, INC. 33 - 12/17/2004 Jane Doe #6 Jane Doe #7 JEFFREY EPSTEIN HYPERION AIR, INC. 34 1/1/2005 Jane Doe #5 Jane Doe #7 Jane Doe #13 JEFFREY EPSTEIN HYPERION AIR, INC. 35 1/6/2005 Jane Doe #3 Jane Doe #4 Jane Doe #13 JEFFREY EPSTEIN HYPERION AIR, INC. 36 1/14/2005 Jane Doe #3 JEFFREY EPSTEIN JEGE, INC. 37 2/3/2005 Jane Doe #3 Jane Doe #5 JEFFREY EPSTEIN JEGE, INC. a38 ( 2/10/2005 Jane Doe #3 Jane Doe #5 JEFFREY EPSTEIN JEGE, INC. 30 EFTA01713723 COUNT DATE(S) MINOR(S) INVOLVED DEFENDANT(S) 23 8/6/04 Jane Doe #4 Jane Doe #6 JEFFREY EPSTEIN ~T . 24 8/19/04 Jane Doe #6 Jane Doe #7 JEFFREY EPSTEIN JE E, IN . 25 8/25/2004 Jane Doe #6 JEFFREY EPSTEIN IIWR IM N. 26 9/16/2004 Jane Doe #7 Jane Doe #13 JEFFREY EPSTEIN JEGE, INC. 27 10/29/2004 Jane Doe #7 Jane Doe #13 JEFFREY EPSTEIN HYPERION AIR, INC. 11/5/2004 Jane Doe #4 JEFFREY EPSTEIN HYPERION AIR, INC. 29 11/10/2004 Jane Doe #6 JEFFREY EPSTEIN INC. 30 11/18/2004 Jane Doe #5 Jane Doe #6 JEFFREY EPSTEIN HYP N AIR, INC. 29 EFTA01713724 COUNT DATE(S) MINOR(S) INVOLVED DEFENDANT(S) 39 2/21/2005 Jane Doe #3 Jane Doe #5 . JEFFREY EPSTEIN JE , INC. 40 2/24/2005 Jane Doe #3 Jane Doe #4 Jane Doe #13 JEFFREY EPSTEIN . ff i la l . 41 3/4/2005 Jane Doe #5 JEFFREY EPSTEIN JEGE, INC. 42 3/18/2005 Jane Doe #3 Jane Doe #5 JEFFREY EPSTEIN JEGE, INC. 43 3/31/2005 Jane Doe #2 Jane Doe #3 Jane Doe #4 JEFFREY EPSTEIN JEGE, INC. 44 I 4/8/2005 Jane Doe #3 JEFFREY EPSTEIN HYPERION AIR, INC. ' 45 4/27/2005 Jane Doe #3 JEFFREY EPSTEIN HYPERION AIR, INC. 5/6/2005 Jane Doe #3 JEFFREY EPSTEIN HYPERION AIR, INC. 31 EFTA01713725 COUNT DATE(S) MINOR(S) INVOLVED DEFENDANT(S) 47 5/19/2005 Jane Doe 43 Jane Doe 48 JEFFREY EPSTEIN HYPERION AIR, INC. 48 6/30/2005 Jane Doe 48 JEFFREY EPSTEIN HYPERION AIR, INC. 49 9/9/2005 Jane Doe €#8 JEFFREY EPSTEIN i HYPERION AIR, INC. s0 9/18/2005 Jane Doe #8 JEFFREY EPSTEIN HYPERION AIR, INC. All in violation of Title 18, United Sta:es 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. 23. On or about the dates enumerated as to each count listed below, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and foreign commerce, recruit, entice, provide, and obtain by any means a person, that is, the person in each count listed below, knowing that the person had not attained the age of 18 32 EFTA01713726