EFTA02731082

PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) MEMORANDUM TO: Geoffrey S. Berman. U.S. Attorn FROM: AUSAs DATE: December 19, 2019 RE: Investigation into Potential Co-Conspirators of Jeffrey Epstein This memorandum details the investigative steps taken since the indictment of Jeffrey Epstein in this District on July 2, 2019 and analyzes the extent to which certain of Epstein's associates and employees may or may not be criminally liable for their conduct during their employment with Epstein. I. Background On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging Jeffrey Epstein with one count of sex trafficking of minors, in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371. The prosecution memorandum in support of that indictment detailed the evidence gathered regarding Epstein and his associates during our Office's pre-indictment investigation. That evidence revealed that beginning in at least 2002, Epstein enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash. He undertook this activity in at least two different locations, including his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence"). In both New York and Florida. Epstein perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to Epstein, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. Epstein paid his victims hundreds of dollars in cash for each separate encounter. Moreover, Epstein actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion. Epstein created a vast network of underage victims — as young as 14 — in locations including New York and Palm Beach. In creating and maintaining a network of minor victims whom he 1 EFTA 00022461 EFTA02731082 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) abused, Epstein worked with others, including employees and associates who facilitated his exploitation of minors by, among other things, contacting victims and scheduling their sexual encounters with Epstein, both in New Yorlc and in Florida. Epstein was arrested on July 6, 2019, and the Indictment against him was unsealed on July 8, 2019. That same day, our Office held a press conference asking anyone with information, including any victims, to come forward and meet with investigators. In the wake of the press conference, numerous victims and witnesses came forward and were interviewed by the FBI and ow Office. On or about August 10, 2019, Epstein committed suicide while in custody at the Metropolitan Correctional Center. Since his death, we have continued the investigation that remained ongoing following the return of the Indictment against Epstein into tential co- conspirators. In particular, that investigation focused on Ghislaine Maxwell, and Leslie Groff. This memo details the steps taken in this investigation since July 2019, summarizes the potential charges for the conduct at issue, and analyzes the evidence against certain of Epstein's associates and employees: Leslie Groff, and Ghislaine Maxwell. The potential charges against Maxwell will be further analyzed in a separate prosecution memorandum, which is expected to seek authorization to charge Maxwell with federal offenses for her role in facilitating the transport of minors for illegal sex acts. II. Investigative Steps Taken Since the Indictment was unsealed on July 5, 2019, our Office and the FBI have been contacted by numerous potential witnesses—both directly and through their attorneys. Every unrepresented person who contacted the investigative team—either through the FBI tip line or by calling our Office—was contacted in the first instance by an FBI agent for an initial screening interview. The FBI then provided our Office with the names and contact information of individuals who appeared to have information pertinent to our investigation. The AUSAs and case agents then conducted follow up interviews of those identified individuals. In addition, the investigative team initiated contact with numerous witnesses about whom we learned both through our investigation and through press reporting. Although some individuals declined to be interviewed, we ultimately conducted dozens of witness interviews and proffers. At the same time, following the unsealing of the Indictment, ow Office and the FBI took numerous additional investigative steps, including the execution of search warrants, the review of financial records and other documents, and meetings with attorneys for numerous subjects of the investigation. This section walks through the information gathered during our continuing investigation since Epstein's arrest in July 2019. First, we summarize interviews conducted with victims who were abused as minors. Second, we summarize interviews conducted with victims who were abused as adults. Third, we summarize interviews conducted with victims who were not abused. Fourth, we summarize interviews with individuals who are subjects of the investigation. Fifth, we summarize ow interview with one victim, 2 EFTA_ 00022462 EFTA02731083 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Finally, we walk through other investigative steps, such as attorney proffers, search warrants, and document review. A. Interviews of Victims Who Were Abused As Minors 1. Since the unsealing of the Indictment, we have been in regular contact with attorneys who represent Over the course of multiple proffers, all conducted between March 2019 and July 2019, has described how she was recruited to engage in sexual contact with Epstein in approximately , at the age of approximately 14. While at a New York City club, met another teenager who described having worked for a rich man, giving topless massages— and recruiting other girls to do the same—and invited to make money this way. At the time, was living by herself and supporting herself financially, having moved away from a difficult home life. ultimately visited Epstein's New York residence to engage in sexual massages and other sex acts at least dozens of times between approximately , all while she was a minor.' During these visits, performed erotic massages on Epstein, including being partially or fully nude while she massaged him. Most or all of the massages performed by would end with Epstein masturbating and ejaculating; during some of the massages, Epstein touched the genitals o with his hand or with a vibrator or sex toy. also reported a hazy memory of participating in an incident in which was nude with Epstein in his bed. could not recall the details of any sex acts that occurred during that interaction with Epstein ordinarily paid $300 in cash after a massage was completed. During an earlier visit, recalls Epstein asking her how old she was and her truthfully telling Epstein that she was 14 years old. After initial meetings with Epstein, he asked her, in sum and substance, to recruit other girls for the same activity. Over approximately the next two years, estimates that she brought dozens of girls to Epstein to provide massages at his New York residence, starting with girls she knew from her community and eventually strangers whom met at bars, clubs, or other locations. would describe to the girls what was expected, i.e., that they would provide erotic massages to Epstein, while nude, and that Epstein might touch them or ask them to touch him. would schedule appointments for the provided a detailed description of Epstein's New York residence, which was corroborated by photographs taken by the FBI during the execution of a search warrant there in July 2019. 3 EFTA_00022463 EFTA02731084 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) girls by phone with Leslie Groff.2 Although recalls meeting Groff on at least one occasion at her office to pick up some money, she did not have extensive interactions with Groff and did not tell Groff her age. Each time brought a girl to Epstein, was paid $300. and the other girl would also receive $300, alwa in cash. After brought a girl to Epstein, he would sometimes either tell to bring the girl again, if he liked her, or tell not to bring the girl again. noticed that the girls Epstein liked were generally younger and more petite. Epstein would tell "you know what I like." which she took to mean underage, petite girls. Epstein would occasionally indicate his displeasure with for bringing a particular irl, including expressing to that he did not like dark-skinned girls. Later on, as grew older and knew fewer oung girls to bring, she brought older girls, which Epstein expressed displeasure about. recalls at least one occasion when she saw a girl show Epstein an ID to prove she was under 18. 2. During interviews conducted between March and July 2019, described how she was recruited to provide Epstein with sexualized massages at his Palm Beach residence when she was approximately 14 years old. estimates that she herself performed more than ten sexualized massages and that she also recruited approximately 20 to 30 additional girls who were similarly abused by Epstein in Florida. When first encountered Epstein, she was a high school dropout, living away from home and supporting herself financial) . She recalls being recruited b a young girl named at a party who told and her friend that they could make agreed to go to Epstein's Palm Beach $200 by giving a massage to an older man. residence, and she ultimately participated in at least ten massages, which became increasingly sexual over time. She recalled that Epstein would instruct her to pinch his nipples while he masturbated, and that she was often instructed to take her clothes off and perform the massage while nude. During the massages, Epstein would touch her genitals with a vibrator or his hand. She recounted that Epstein would frequently push thin further to see how far he could go. On at least one occasion, Epstein brought another woman, into a sexualized massage with During this encounter, who was an adult at the time, engaged in sex acts with at Epstein's direction. 2 A message slip recovered from a trash pull from E tein's Palm Beach residence during the first Florida investigation included a message from' The phone number associated with that message appears on toll records for one o friends from the same period. I 4 EFTA_00022464 EFTA02731085 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Epstein asked to bring other girls for massages, which she did. Initially, Epstein simply asked her to "bring a friend" and told her he would pay her to bring other girls. Later, after a few experiences of bringing victims who balked at the sexual nature of the massages, Epstein told her not to bring girls unless they knew what to expect. understood this to mean she should warn girls to expect they would need to take off their clothes, and that Epstein would touch them and masturbate. She then conveyed as much in recruiting new victims. estimates that over the course of several years, she recruited approximately 20 to 30 girls for Epstein, all of whom were approximately 15 to 20 years old.4 believes that most of the girls she recruited were minors. Epstein would occasionally indicate to which girls he liked and which girls he disliked, and she noticed he preferred the younger minors she brought, and that he referred petite blonde girls. usually coordinated these appointments with or specifically recalls that would occasionally call and say that she was in New York, that Epstein would be arriving in Florida soon, and that she wanted to know it could "work" when he arrived.. also recalled- personally taking her to the massage room on some occasions, where she would set up the massage table. also recalls paying her after some of these encounters. When'. first met Epstein, she told him she was 18 because her friend had told her to lie about her age. In truth, she was approximately 14 or 15 at the time, and was wearing braces, and recalls that it would have been obvious that she was very young. Initially, similarly told other girls she brought to Epstein to say they were older because her friend had given her that instruction. Over time, however, based on her observations of the girls that Epstein seemed to prefer—and the sheer number of minors she brought to the house without issue—M came to believe that Epstein wanted younger girls and did not care if the girls told him their true ages. For this reason, stopped telling the girls she recruited to lie about their ages. She stated that the girls she recruited looked very young, and she believes it would have been obvious to anyone that they were underage. When the Florida investigations became public, after had stopped visiting Epstein, she recalls having a phone conversation with in which stated, in sum and substance, that would be taken care of if she didn't say anything. 4 Message pads recovered from Epstein's Palm Beach residence during the first Florida I. investigation include messages with full name and phone number. The messages appear to refer to scheduling appointments an recruiting other girls, e.g.: "She has a female friend for you, please call back as soon as possible." Additionally, the message pads include messages with names of individuals- identified as other victims. 5 Contemporaneous phone records reflect numerous calls between- and 5 EFTA_00022465 EFTA02731086 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) On August 27, 2019, we met with in New York. 3. During During prior interviews conducted between April and July 2019 • described how between approximately-, she went to Epstein's Florida residence approximately 20 times to participate in sexualized massages. receiving ayments of $200 for each visit. recalled that she told Epstein her true age, which was 17. Specifically, explained that she would typically deposit cash from Epstein in her bank account right away. provided a notebook in which she noted sits she made: based on her dates of deposits. it appears the abuse began in approximately , weeks past her sixteenth birthday. The records also appear to show that cash payments from Epstein continued through- several months before her eighteenth birthday. Similar to other victims.. was recruited by a high school friend, who told her she could make money by giving a massage. She recalls Epstein telling her that they could travel together after she turned 18, and that once she turned 18 he would be able to help her with a modeling career. She ultimately stopped going to Epstein's residence because she felt disgusted by her interactions with him. . generally scheduled the massages through . recalled that would sometimes call from New York to schedule massages in advance of Epstein's arrival in Florida. and ifically rec mentioning on calls that was in New York at the time. also recalled pe rsonally taking her to the massage room on some occasions. . specifically recalled telling that she was in high school and could not provide massages at certain times due to school conflicts. She also reported that Epstein asked her to bring girls who looked like her, which she took to mean blonde girls her age.. brought two seventeen-year-old girls to Epstein's house for massages, for which. was also paid.. has reported that the massages became increasingly sexual over time, and included Epstein 6 Contemporaneous phone records reflect numerous contacts between and A comparison of call records against logs of Epstein's flights on his private Jet reflects several sets of calls during times when example, on afternoon: later t t West Palm Beach. appears to have been in New York City with Epstein. For and recc.reflect at had three calls spread throughout the and Epstein flew from - 6 to EFTA_00022466 EFTA02731087 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) touching her genitals and using a vibrator on her genital area, including under her underwear. also recalled that Epstein asked her for intercourse, but she refused. On Au t 27, 2019, we met with in New York. 4. We have interviewed on three occasions. First, on S tember 19, 2019, was interviewed in During this interview, described how she met Epstein and Ghislaine Maxwell and described in general terms how her relationship with them evolved. She did not want to discuss specific incidents of abuse in detail during this interview. In When was about 13 years old Maxwell and Epstehaoached her while she was sitting outside at apicnic table with her friends.' ifiin told asked about back ound. When told Epstein that she live that he gives scholarships and Epstein asked for her phone number so that they could connect. About six weeks later, after had returned home and had turned 14, someone called from Epstein's office askin to have tea with Epstein. They accepted the invitation, and both had tea with Epstein at his Palm Beach residence, during which he explained that he likes to mentor and give scholarships.° After that meetin be an spending more time with Epstein and Maxwell. , Maxwell or an assistant would regularly call house phone to invite to visit with Epstein. recalls Epstein having a number of different assistants, including Leslie Groff and When she was still 14 years old, travelled to New York to visit with Epstein and Maxwell. During that trip, Epstein and Maxwell took shopping and picked out clothing for her, including white underwear. does not recall any sexual contact occurring until after that trip to New York. After that tri frequently went to Epstein's Palm Beach residence. While there. Epstein would Between approximatel I I 9 worked as Maxwell's assistant in 7 EFTA 00022467 EFTA02731088 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) have rub his feet, and he often gave her cash, which he claimed was for her to use for voice lessons. Epstein first sexually abused when she was 14 years old at his Palm Beach residence. The two were discussing desire to be , and Epstein told that she needed to be comfortable in her underwear. Epstein then pulled his pants down, pulledi into his lap and began masturbating. Epstein told a photographer might do this to her, so she needed to be prepared. After that first incident, Epstein increasingly sexually abused After a few months of abusing on his own, Epstein began abusing with Maxwell present. Eventually, Epstein also had other young girls or women participate in sex acts with-could not recall the names of all of these other females, but she vaguely remembers meeting once. She also recalled Epstein's assistant, being involved in sexual contact. Many of these instances occurred in the context of massages, during which would be present when other girls would provide sexualized massages to Epstein. For the next approximately two years, Epstein continued sexually abusing by, among other things, fondling her genitals and using vibrators to touch her genitals. During that period, Epstein also photographed while wearing only underwear.' recalled travelling to New York and New Mexico with both Epstein and Maxwell during this period. She indicated that both Epstein and Maxwell participated in sexual encounters with her during this period, but she was not at that point prepared to go into more details regarding the specifics of the contact. recalled that either Groff or Maxwell would arrange her travel. When was a senior in high school, Epstein paid for her to move to continued abusing there, and eventually raped her in his New York residence. recalled meeting famous friends of Epstein's, including Prince Andrew, but she never had any sexual encounters with any of Epstein's friends. remained in contact with Epstein until , when she was 21 years old. e Second, on November 14, 2019, was re-interviewed in During this interview, clarified her memory of the timing of her interactions with Epstein and Maxwell. She recalled when she was 13 years old, shortly before she turned 14 . She recalled first travelling on Epstein's private jet when she was 14 years old, when she travelled to New York. Epstein first engaged in sexual contact with when she was 14 years old. began her senior year in New York in., so she moved to New York in when she was about 17 years old, then began attending school in New York in the fall after turning 18 years old. Given that timing, she believes she may have been 18 when Epstein raped her in New York. 10 Multiple photographs of were recovered from Epstein's Palm Beach residence during the first Florida investigation. 8 EFTA_00022468 EFTA02731089 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) recalled travelling to New Mexico with Epstein approximately three times. Maxwell was present for each of those trips. She went more frequently to New York, but Maxwell was not around as often during the New York trips because Epstein and Maxwell did not live in the same residence in New York. could not recall whether Maxwell would call her to make appointments to see Epstein while in New York. She generally recalled assistants calling to invite her to see Epstein. recalled that Maxwell was much more present when she first met Epstein and that Maxwell made travel arrangements for during her earlier trips with Epstein. also recalled at least one incident of sexual abuse in New York when she was a minor during which Maxwell was present, but she explained that Maxwell was present for more instances of abuse in Florida. did not wish to discuss the details of incidents of abuse during this meeting. Third, on December 17, 2019, was interviewed for a third time in She recalled that when she was still living in (before she moved to when she was 17 years old), she would speak with Maxwell on the phone about plans to travel with Epstein. She also recalled flying on Epstein's private et with Maxwell. When asked to describe specific instances of abuse before she moved to described sexual assaults ranging from Epstein masturbating in her presence to Epstein touching her genitals with a vibrator to Epstein engaging in oral sex with her to raping her. When asked which specific acts Maxwell was physically present for, indicated that she was not entirely sure. She could only specifically recall instances in which Maxwell was in the room while Epstein masturbated and directed to touch hisinis. She could not recall specifically whether Maxwell was resent when Epstein touched genitals or engaged in other sexual contact with her. did not recall Maxwell ever touching her during an instance of sexual abuse with Epstein. 5. We have interviewed on three occasions. First. on August 27, 2019, met with us in New York. During that interview. described meeting Ghislaine Maxwell lived at the time, when and how much he was oin to like was about 17 ears old. Maxwell talked about her bo end. Jeffrey, One day when Epstein was Maxwell invited to come to Maxwell's residence, where she was introduced to 9 EFTA_00022469 EFTA02731090 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) Epstein. During that fust meeting, Maxwell told that Epstein needed a massage every day and asked to give Epstein a massage. Maxwell then brought- up to a bedroom where Epstein was in a robe. While Maxwell waited outside the room, Epstein removed the robe and got onto the bed. massage. Epstein rolled over, touched then massaged Epstein. During the and put her hand on his penis. After that first sexual assault. Maxwell repeatedl called who was still 17, and invited her to see Epstein at Maxwell's residence During these visits, Epstein engaged in sexual contact with At the time, was not in school but still lived with .11 is confident Maxwell knew her age because Maxwell got her an expensive gift for her 18 birthday. Eventually, Maxwell and Epstein invited to travel with them to Palm Beach, Paris, the Virgin Islands, and New York. Every time travelled with Epstein, he engaged in sexual contact with her. This included sexualized massages during which Epstein used a vibrator to touch her genitals. recalled times that she resisted Epstein's advances, and Maxwell encouraged her to do what Epstein wanted, sayin_• thi ike "don't be silly" to minimize the conduct. On one occasion, Maxwell encouraged to wear a schoolgirl uniform for Epstein. When resisted. Maxwell responded. "don't be so frigid." On one occasion, Maxwell asked if she knew someone who could give Epstein "a blow job" because Maxwell did not feel like doing so that day. Maxwell also made comments about Epstein's sexual preferences, notin that he preferred younger looking females and wanted to constantly have sex. understood that Maxwell was Epstein's girlfriend, but she came to understand that Maxwell allowed Epstein to engage in sexual contact with other ple, as long as it did not include intercourse. Nevertheless, Epstein raped on multiple occasions, and he told not to tell Maxwell about the rapes because it violated their understanding. Maxwell also asked to bring other girls to engage in sex with Epstein and repeatedly asked to engage in sex acts with Epstein. Maxwell continued to ask to enga e in sexualized massages with Epstein into her 20s. Over the years, Leslie Groff would contact to invite her to meet Epstein and would make her travel arrangements. Second. on September 19, 2019. met with us in New York. During this interview, she a ' described meeting Maxwell when she was 17 years old. Maxwell then introduced to Epstein, and during that first meeting, Maxwell encouraged. ■ to give Epstein a full body massage. Maxwell then waited outside the room while. gave Epstein a massage, during which Epstein put her hand on his penis. After the massage was over. Maxwell asked how it went, whether had nu'. and whether Epstein liked it. Maxwell then paid for the massage. 10 EFTA_00022470 EFTA02731091 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) When turned 18, Maxwell gave her a gift with a card signed by both Epstein and Maxwell. also recalled Maxwell telling someone else at a later date that Maxwell met when she was 17 years old. was not certain whether she began travelling with Epstein and Maxwell before or after her 18 birthday. After she was 18 or 19 years old, recalls Maxwell saying she was getting too old to have a child with Epstein. Maxwell also told that Epstein needed sex three to four times per day. Third, on December 15, 2019, we met with still could not recall whether she first traveled with Epstein and Maxwell when she was 17 or when she was 18. She was certain, however, that she was 17 years old during at least the first two instances when Epstein sexually assaulted her . Both instances occurred at Maxwell's residence had previously described the first instance, which involved Maxwell encouraging her to provide Epstein a massage and waiting outside the bedroom while massaged Epstein, and Epstein first sexually abused- Sometime after leaving Maxwell's residence following that first incident of abuse,. received a call from Maxwell. On the call, Maxwell said was a "clever girl" and that "Jeffrey was very impressed," so Maxwell wanted to schedule a return visit. agreed and sometime later, she returned to Maxwell's London residence. When arrived, Maxwell told her, in substance, that Maxwell was relieved was there because otherwise "it falls to me," which understood to mean that Maxwell had to provide Epstein with sexualized massages if no one else was available. After this conversation, Maxwell walked to a bedroom and opened the door. Inside the room, Epstein was fully nude and standing facing Maxwell and Maxwell said "I'll leave you to it," and left. did not wish to discuss the details of the sexual abuse that occurred during this second massage at this time. After the massage, Maxwell asked if. had a nice time, and then changed the subject to chat about upcoming plans. 6. On September 28, 2019, was interviewed in New York. explained at the outset of the interview that her recollection had been refreshed by reviewing the journal she kept while in high school which we are in the process of obtaining. met Epstein in. and worked in some capacity for Epstein. Between , when was 16 years old and a junior in high school , she took two trips to meet with Epstein. 11 EFTA_00022471 EFTA02731092 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) First. told that Epstein was interested in meeting her and hel • in her with college. Epstein then paid for to fly out to New York . While in New York, stayed saw Epstein twice during this New York trip. During the first meeting, Epstein bought tickets to see the Phantom of the Opera and met with them before the show at his New York residence. During that meeting. Epstein asked about her life and offered to help her with her education. During the second meet' Epstein took , to see the movie 12 Monkeys. Epstein sat between during the movie and touched inappropriately throughout the movie. In particular, Epstein touched leg, stroked her arm, and held her hand. Second, with Epstein and Ghislaine Maxwell. phone about this trip. which made them feel more comfortable about to fly to New Mexico and arranged for a driver to take her to Epstein's New Mexico ranch. background and lifil especifically remembers telling Maxwell that she was a junior in high Once at the ranch, nt time with Maxwell, who expressed interest in school because they discussed her homework, her plans for the upcoming senior year, and her desire to attend college. flew alone to New Mexico, where she spent a weekend recalls that spoke with Epstein on the all knew that Maxwell would be on the trip, traveling alone.' Epstein paid for During this trip to New Mexico, recalls several instances of conduct that made her feel uncomfortable. First, Maxwell encouraged to masse ipstein's feet with her and showed how he liked to have his feet rubbed. Second, i went to the movies with Epstein and Maxwell to see Primal Fear, and outside the theater, Maxwell aiu down Epstein's sweatpants a bit in a joking manner. During the movie. Epstein again held hand and stroked her arm, but he did not to be trying to hide this contact from Maxwell. Third, Maxwell insisted on giving a massage during which was either partially or fully nude. The massage took place in a room with an open door leading to the next room where Epstein was located, such that E stein may have been able to observe- " During the massage. Maxwell rubbed chest, touching the sides of her breasts. Finally, one morning. Epstein came into room, got into bed with her, and said he wanted to cuddle. said she needed to go to the bathroom, and left the room. does not recall having any other contact with Epstein or Maxwell after the New Mexico trip. 12 EFI'A_00022472 EFTA02731093 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 7. was interviewed on July 31, 2019, August 27, 2019 and November 21, 2019. all in New York. Epstein sexuall assaulted her in New Mexico, Florida, and Paris." said that when she was 17 ears old, first First, during the July 31. 2019 interview, met Epstein through who worked as a masseuse for Epstein and introduced Epstein as someone who could help was on the verge of homelessness and had nowhere else to go. first introduced to Epstein at a hotel-. During that first meeting, Epstein expressed interest in background and offered to pay for her to travel and attend school. After that first meetin , Epstein invited to his home in New Mexico. During that first trip. Epstein asked to 'ye him a massage. was present in the massage room, and both and were in swimsuits. At first, Epstein asked to remove her top and began fondling froze as Epstein turned to her and began to fondle her genitals. During this first interview, was too distressed to describe any other details regarding this assault. She explained, however, that after that first incident, when she was still 17, she travelled with Epstein to other residences where he sexually assaulted her. In particular, recalled during this interview that Epstein assaulted her in New Mexico, Florida, and Paris on four occasions when she was 17 years old. Two of the assaults involved Epstein sneaking into her room at night and raping her. asked not to discuss the details of those assaults during this first interview. E stein aid for to travel to for school. In turned 18 . After turning 18, continued to spend time with E stein for approximately two more years. During that two-year period, Epstein paid for to attend school for three months-long periods." When she was not in school, either travelled with Epstein or resided at an apartment he provided for her in New York. During that same period, Epstein continued to engage in sexual Eventually the stress of continued abuse led to develop an eating 10 As indicated below, during a subsequent interview, clarified that she was in fact assaulted in New Mexico, New York, Florida, and the Virgin Islands when she was 17 years old. Although Epstein engaged in sexual contact with her in other locations, including Paris, she was 18 years old when those incidents took place. 15 We have identified message pads recovered during the first Florida investigation referencing instances in which = called for Epstein during this period. 13 EFTA_00022473 EFTA02731094 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) disorder. When confided in Epstein about her eating disorder for her to fly to Arizona and then essentially disowned her, cutting off contact. he paid While travelling with Epstein, became familiar with the people in his world, including Leslie Groff Ghislaine Maxwell. and Jean Luc Brunel. provided us with copies of photoirahe still had from her time with Epstein, including photographs featuring Epstein. Maxwell. and Brunel. recalled that was Epstein's assistant. In that capacity, arranged the scheduling for Epstein's flights on his roximately five years older than and acted as private jet and coordinated with his pilots and house staff to arrange for E stein's travel. As described above, was present when Epstein sexually assaulted in a massage room at Epstein's New Mexico residence. could not recall, however, whether she ever expressly discussed her age with During this first interview, was too distressed to discuss instances of sexual assault in detail, but she indicated that was present for and participated in two assaults before turned 18, and believed that during these assaults. touched 16 also recalled that took photographs of= while at Epstein's Virgin Islands residence. Although could not be completely sure, she believed that those photographs were taken when she was 17 years old. did not recall whether she was clothed in the photos or if anyone else was in the photos.17 As travelled with Epstein . she noticed a lot of ' is coining and going to and from Epstein's residences in New York and Palm Beach. recalled that these girls would stay for about an hour or so. They appear.oung, but but did not know whether any were under the age of 18. recalled saying generally that the girls were there to see Epstein. recalled that became E stein's girlfriend after returning from her first trip knows that was 18 years old when they met. For about two years, was roommate when the travelled with Epstein, and they shared an apartment in New York. As a result, the two became friends. referred to herself as Epstein's girlfriend, but in general, she and did not discuss the details of their sexual activity with Epstein. 16 As descried below, during a subsequent interview, clarified that she onl recalled one instance of sexual abuse when she was a minor for w lc was present. also clarified that she does not have a memory of= touching er during any instances of abuse. 17 When execut search warrant at Epstein's New York residence, the FBI recovered multiple photographs o in which she is nude or partially nude and appears to be in a tropical location. 14 EFTA 00022474 EFTA02731095 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) understood Ghislaine Maxwell to be Epstein's "partner," who also handled scheduling along with Her impression was that Maxwell's relationship with Epstein was more focused on business than personal matters. explained that Leslie Groff arranged payments for schooling and also coordinated her commercial flights. did not see Groff as often as she saw and Maxwell because Groff did not travel with Epstein. Second, during the August 27, 2019 interview, provided additional details regarding her interactions with other people in Epstein's circle during her time travelling with Epstein. First, explained that she understood to be Epstein's assistant. responsibilities included shopping, travel arrangements, and coordinating with Epstein's pilots. During the time was travelling with Epstein went wherever Epstein did. During this same period, when Epstein was in New York, , resided in the same building as did, though in a different apartment. When in New York, would sometimes call and instruct her to come to Epstein's New York residence. again indicated that was present for the first time Epstein assaulted her and was somehow involved in the second time Epstein assaulted her, but she was not emotionally prepared to describe the details of the assaults during this interview. does not recall speaking explicitly with about her age, but she does recall that was present with Epstein and others for 19ih and 20th birthdays. When asked who else attended those birthdays, recalled that Epstein and were present as well. When asked who else she recalled being associated with Epstein mentioned that a female named whose last name could not recall, was present during an instance when Epstein sexually assaulted in Virgin Islands. recalled that was older than Again, though, was not emotionally prepared to describe the details of that assault. recalled that Leslie Groff booked travel for school. also recalled that Ghislaine Maxwell often travelled with Epstein and would sleep in Epstein's room when they travelled. More generally, explained that she did not discuss Epstein's sexual abuse with anyone, including Maxwell, Groff, and because she felt that it was taboo and not something she should mention. recalled two instances when Epstein asked her to provide massages to other men, both of which took place after turned 18. First, massaged Jean Luc Brunel, but the massage did not involve any sexual contact. Second, when was at Epstein's Paris residence, Epstein instructed her to massage Harvey Weinstein there. When went into the massage room, Weinstein directed to remove her shirt. refused, and in response, Weinstein became angry and told to tell or Weinstein's assistant Bonnie 15 EFTA_00022475 EFTA02731096 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) to come instead. left and told Epstein what happened. Epstein apologized to for putting her in that position. Third, during the November 21, 2019 interview, provided additional details regarding certain instances of abuse and clarified her memories of her interactions with Epstein before turning 18. recalled that when she was about 17 years old introduced her to a man named Joseph Alvarez, a/k/a "Gypsy," , who taught both sisters how to give massages. Alvarez then introduced to Epstein, and she began travelling with him. Later introduced to Epstein. That first meeting took place at a hotel , where met both Maxwell and Epstein. During the meeting, massaged Epstein's feet while he asked about her life and background. told him she wanted to go back to school, and Epstein offered to pay for her to attend school . Following that meeting, Epstein called on multiple occasions, sometimes with Leslie Groff connecting the calls. Eventually, Epstein committed to paying for to attend school . In response, gave up the room in the apartment where she was living, gave notice to her job, and prepared to travelME. A few weeks before left she accepted the invitation. then travelled to Epstein's New Mexico residence in when she was still 17 years old. She recalls Epstein, Maxwell, and other females whose names she does not remember being at the residence when she arrived. remained at the New Mexico residence for a couple of days before returning . Early on in the visit, Maxwell took horseback riding, and told Maxwell about her life and background. Although does not specifically recall saying her age, she believes Maxwell would have had strong indications of her age based on that conversation. Later during that same trip, went swimming in the pool with As they got out of the pool in their swimsuits, Epstein called them over to give him a massage in a nearby massage room. Once inside the massage room, Epstein removed top, began masturbating, and touched breasts and genitals. Epstein then touched genitals. froze and began crying, but Epstein continued to touch her genitals and masturbate until he ejaculated. recalled that- seemed at ease, as though this was a normal occurrence. never spoke about the incident with Epstein invited to New Mexico, and After returned , Epstein called her multiple times, both to discuss her plans to attend school and to invite her on another trip. agreed to go on another trip with Epstein , when she was still 17. In or arounc , she flew o New York, where she visited Epstein at his New York residence. Once there, Epstein brought alone into the dining room where he reached down her pants and fondled her. From New York, flew with Epstein, Maxwell, and another female to Palm Beach, where the group stayed at Epstein's Palm Beach residence for a few days. One of the nights in Palm Beach, Epstein came into the room where was sleeping and raped her. The same group then flew from Palm Beach to the Virgin Islands, where they stayed on at Epstein's Virgin Islands residence. One of the nights on the island, Epstein again came into the 16 EFTA_00022476 EFTA02731097 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) room where was sleeping and raped her. The same group then flew back to Palm Beach.' From there. believes she flew back to After that trip. Epstein paid for to travel to Spain in approximately and attend school there. While in Spain, turned 18 in . At the end of the semester in the spring ofM, Epstein paid for her to fly back to the Virgin Islands and rejoin him at his Virgin Islands residence." Over the next approximately two years. Epstein periodically paid for to travel to attend school for months at a time. When- was not attending school, she travelled with Epstein to his various residences. During the periods she was with Epstein, her understanding was that either or Maxwell scheduled Epstein's massages. She recalled thinking that the masseuses she saw were about her age (18 or 19 years old). 8. On Se tember 10. 2019. we met with when On November 4, 2019, we interviewed in Mlin or around , was approximately 16 years old, a friend of hers named asked if 1° We have identified flight records for E stein'sprivate 'et corroborating account of this trip. In particular, flight records 19 The metadata for some of the nude photogra hs o recovered from Epstein's New York residence suggest that the photos were created , w ch would be consistent with 1 I second trip to the Virgin Islands. 17 EFTA_00022477 EFTA02731098 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) she wanted to make money by giving a massage to a billionaire. said yes, and connected her with a your man named 21 who gave a ride to Epstein's Palm Beach residence. told to lie and say she was 18 years old. Once at the residence, met then brought to the massage room while waited downstairs. then gave Epstein a massage, during which Epstein masturbated and o ed genitals and buttocks. At the end of the massage, Epstein offered to a if she brought other girls to engage in similar acts. During that initial meeting, lied and said she was 18 years old and in college. then went her phone number. downstairs and gave After that first encounter, be an bringing other girls to massage E stein. To coordinate the massage appointments, spoke on the phone with continued bringing girls to Epstein's Palm Beach residence for approximately two more years until she was 18 years old and the police began investigating Epstein. In total, estimates she went to Epstein's Palm Beach residence once or twice a month. She recalled that Epstein often went weeks without coming to Florida. When brought a new girl. Epstein always paid 5200 himself. Sometimes would bring girls up to the massage room, and down, then would go up to talk with Epstein and get paid by him. d not recall would wait downstairs for about an hour until the came back di sometimes did. any of the is she brought being upset after a massage, as she always warned them what to expect. only recalls dealing with and never met or spoke with Maxwell, or Groff. In total, brought about six different girls to give sexualized massages to E stein. All except one were minors. At one time, brought someone in her 20s, and told not to bring her again, though he did not say why. All the other girls brought were oun er looking, thinner girls. told everyone she brought to say they were 18 years old. did not recall having any personal conversations with and does not know whether knew how old she or any of the girls she recruited were. recalled that occasionally asked to bring a specific girl. recalls referring to the girls she recruited as her "friends" to Eventually, some of the girls brought began recruiting other girls themselves. recalled walking into the massage room with a recruit at some point and seeing and Epstein leaving the shower/steam room together, which led her to believe they had a sexual relationship. The police approached in 2006, after which she never spoke with Epstein or again. 9. was interviewed on July 14, 2019 in 18 When she was EFTA_00022478 EFTA02731099 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) approximately 13 or 14, a friend of hers named recruited to give massages to Epstein at his Palm Beach residence. Over a period of approximately two years, frequently went to his residence and engaged in massage sessions with Epstein, during which he touched her breasts and genitals, used a vibrator on her genital area, and masturbated in front of her. also became a prolific recruiter and estimates that she may have brought as many as one hundred underage girls to Epstein's Palm Beach residence for massages massa became pregnant at the age of 15, after which Epstein no longer wanted to see her, but he allowed to continue recruiting other girls for massages. received $200 for each massage she performed and for each massage performed by a girl she brought to Epstein's Palm Beach residence. recalled that the first time a new girl gave Epstein a massage, Epstein would often ask to stay in the massage room with the new girl. remembered that would sometimes bring girls up to the massage room, but would then leave before the massage began. would sometimes pay following massages. also provided with gifts from Epstein, including a bikini, and baby shower gifts when became pregnant. recalled that she primarily scheduled massages through over the phone. When scheduling an appointment for a new girl, would call, say she had "someone" for Epstein and would describe what the girl looked like. Occasionally would pick up and drive her to Epstein's Palm Beach residence. recalled saying things like, "you know what Jeffrey likes." also believed that knew was in high school, but she could not recall a specific conversation in which told her age or that she was in high school. recalled lying and telling Epstein that she was 16 years old when they met. She also told Epstein that the girls she recruited were all 16 or older. recalled one incident, however, when Epstein was angry with her for bringing an older girl who was about 18. As a result, understood that Epstein wanted younger girls. recalled bringing girls to Epstein's residence approximately twice per week, most of whom were between the ages of 14 and 16. ultimately stopped recruiting girls to massage Epstein after she was approached by the FB During the initial Florida investigation, spoke with Epstein's attorneys. Although could not recall the names of any of these attorneys, she recalled that they pressured her to lie and tell investigators that she had told Epstein she was 18 years old. recalled Epstein's lawyers suggesting that if she told the truth, her child would be taken away 22 We have identified message pads recovered during the first Florida investigation referencing 'M At least one of these messages indicates that is bringing another female to Epstein's residence. 19 EFTA_00022479 EFTA02731100 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) from her because she engaged in recruiting activities. 10. • . was interviewed on September 12, 2019 in New York. regularly visited Epstein's Palm Beach residence from approximate' , when she between 16 and 18 ears old. When■ was about 16 years old and a sophomore in hi school , she was recruited by a friend named 23 explained that could make money by giving nude massages to an older man. and went with to Epstein's Palm Beach residence, where she believes she met While waited in the kitchen.. went up to the massage room, where she engaged in a paid sexualized massage with Epstein. Over the ensuing months,. returned to Epstein's Palm Beach residence many times to engage in paid sexualized massages. The sexual abuse escalated to include oral sex and rape. . stopped going to Epstein's residence when she was in college and the police approached her. ■ described Epstein giving her cash and gifts, includin a rental car. She also recalled that Epstein helped with her college essays. Epstein also sent flowers in connection with her performance in a high school p lay—.24 ■ indicated that Epstein took multiple nude photographs of her in his Palm Beach residence. . generally described as being frequently present at the Palm Beach house. would frequently call to tell her when Epstein would be in town and to schedule massages. Durin at least some of these conversations, told■ that she was callin from New York. also recalled being paid primarily by Epstein. but sometimes b or someone named Alfredo.' . indicated that she believes knew she was unc.a e: however, did not recall any specific conversations or discussions of her age with Nor could remember any discussions she had with I of details of her life that would have been suggestive of age, such as high school classes or extracurricular activities. . explained, though, that she openly talked with Epstein about taking the SATs and applying for college and would work on her college application essays at Epstein's home. She 23 was interviewed during the Florida investigation and reported engaging in multiple ai sexualized massages with Epstein at his Palm Beach residence when she was a minor. also admitted to bringing two other minor girls, including. to provide Epstein with sex 'zed massages. 24 We have identified messages recovered from Epstein's Palm Beach residence during the first Florida investigation referencing'- which appear to corroborates contact with Epstein. zs The FBI has identified this individual as a housekeeper who is now deceased. 20 EFTA_00022480 EFTA02731101 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) also recalled that organized drivers to pick■ up from lived. where she . also recalled instances in which walked to the massage room and set up the table while there were sex toys visible in the room. also recalled one instance in which came into the massage room when■ was still naked after a sexualized massage. However, did not recall any specific conversations she had with about sex. remember asking her to bring other girls that looked like over to Epstein's home. ■ recalled seeing Maxwell at the house only a few times, and did not have any substantive conversations or interactions with her. referred to as Epstein's "sex slave" and believed that Epstein had "bought" told that was one of Epstein's girlfriends. When ■ was 16 years old, engaged in sex acts with. at Epstein's direction. After the police began investigating Epstein in 2005,■ received a call from a • I named who also went to Epstein's Palm Beach residence for massages. asked if■ if she had spoken with law enforcement and added that■ would be "taken care of if she did not talk. 11. On September 18, 2019 ■ was interviewed in was either 16 or 17 years old, a friend of hers named could make $200 by giving a massage in her underwear to an older man. to Epstein's Palm Beach residence with on one occasion. When arrived at Epstein's Palm Beach residence, a woman named greeted had them wait downstairs. At some point said Epstein was ready. and both girls went up to the massage room. Both girls got undressed, Epstein came into the room, both girls started massaging him, and then Epstein told to leave. E stein then masturbated and touched enitals with a vibrator. At the end of the massage, went back downstairs to where was waiting. E stein came down and paid both and Sometime later, told. that reached out to ask whether would come back. refused and never saw Epstein again. When■ told■ she agreed and went and and and 26 We have identified this individual as summarized below. ' 7 The FBI is still trying to identify this individual. 21 who participated in an interview, which is EF1A_00022481 EFTA02731102 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 12. On October 15, 2019, was interviewed in when was approximately 16 years old and living in Palm Beach, her friend her to give a back massage to a nice older for $200. agreed and went with Epstein's Palm Beach residence, where engaged in a sexualized massage with E For about the next two years. until she was about 18 years old paid sexualized massages to E stein approximately once per week. At some point, Epstein began bringing his girlfriend with at Epstein's direction. show for her 18th birthday. friend only went to Epstein's Palm Beach residence once. invited to stein. provided into the room during these massages to engage in sex acts recalled that Epstein sent her to a David Copperfield also brought one of her friends to massage Epstein, but the Epstein's assistant would often call to schedule massage appointments. Althou discussed her a e with Epstein, she does not recall explicitly discussing her age with Occasionally, walked to after each massage. Around the time to the massage room, but she was never involved ab i nr sexual contact. Either Epstein or turned 18, she stopped receiving calls inviting her to massage Epstein. was contacted by the FBI and interviewed. did not recall or anyone else connected to Epstein contacting her during that investigation. 13. On October 16, 2019, was interviewed in When was about 15 or 16 years old and living in Florida, a girl from her hi i school named r asked if she wanted to give a man a massage for $200. a eed and went with to Epstein's Palm Beach residence. Once there, Epstein met in the kitchen and brought her to the macsage room while waited downstairs. While in the massage room, Epstein asked to remove her clothes. then massaged Epstein while undressed. Epstein then paid and she left. When returned for a second massage, Epstein used a vibrator to touch her genitals, after which he paid her $200. Over the next few months, returned to Epstein's Palm Beach residence about ten more times toprovide Epstein with paid sexualized massages. After that first massage, called to schedule each of her subsequent massages. also brought a friend of hers to massage Epstein once and was paid $200 for bringing her. never told Epstein or her age, but she did recall telling Epstein that she was in high school and a cheerleader. 211 We believe this individual to be 22 EFTA 00022482 EFTA02731103 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 14. = On October 16, 2019, was interviewed in When was about 15 years old , her friends and asked if she wanted to give a man a massage for money. agreed and later went with to Epstein's Palm Beach residence. Upon arriving, an Asian woman directed and to go up to the massage room. When they got to the room, a tall woman with short brown hair, whom now believes to be Maxwell, walked out of the shower in a towel, handed lotion, and said "I think you'll be needing this more than me," then left. Epstein then entered in a robe and got on the massage table. and began massaging Epstein, then left, at which point, removed her clothes, and Epstein touched her genitals. During the massage, told Epstein that she was 16 because had told her to lie and say she was 16, when she was in fact 15 years old. After the massage, gave $200 and said that she was also paid $150. They then left together. never returned and never saw Epstein again. 15. M was interviewed on July 11, 2019 in Florida. when was 14 years old, some of her friends, including recruited her to give Epstein a massage at his Palm Beach residence, during which Epstein touched breasts and genitals. recalled a "lady" with black hair meeting her and in Epstein's kitchen before the massage, but did not speak with the lady or learn her name. Rather, spoke exclusively with the lady. did not participate in any other massages with Epstein, but she subsequently recruited one other minor girl to give Epstein a paid sexualized massage. 16. was interviewed on July 11, 2019 in , when was about 16 years old, her friend recruited her to give Epstein massages at his Palm Beach house. provided Epstein with two massages and was sexually abused during both. During the first, Epstein touched breasts and genitals. The second involved more extensive abuse, which did not want to describe during our interview. recalled that a petite blonde woman named who appeared to be in her early 20s, took upstairs to the massage room before both massages. After both massages, paid $200. After the first massage, took phone number, and, subsequently, called to invite her back. After the second massage, did not want to return, but called four or five times and pressured her to return. ultimately did not return. 29 We have identified these individuals as ME and whose interviews are described above. 23 EFTA_00022483 EFTA02731104 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) 17. was interviewed on July 12, 2019 in was 17 years old and working as a model her friend , when invited her to Epstein's Palm Beach residence. Epstein's girlfriend. Epstein gave was Aiear-old model and told that she was and cash to go shopping, and they purchased underwear together at the mall. They returned to Epstein's house, and Epstein asked to try on the underwear for him. felt as though she could not say no, and complied. That same weekend, invited to come to Epstein's Palm Beach residence to receive a massage from a masseuse. She was told Epstein would not be present, and so she agreed. Shortly after undressed for the massage, the masseuse left the room, and Epstein entered. He insisted that flip onto her back (thereby exposing her breasts). so that he could show her what he had learned from a chiropractor about "adjustments." E•nthen rotated her shoulders and hips, but did not touch her chest. After this experience, refused to return to the house and never saw or spoke with Epstein again. 18. was interviewed on July 12, 2019 in when was about 16 years old, a friend of hers named recruited ivri e Epstein a sexualized masse e at his Palm Beach residence. Durin the first massage, was in the room with Approximately one month later, told that "they" asked for to come back. returned for a second massage, this time by herself. During both massages, Epstein instructed to remove her clothes and used a vibrator to touch genitals while he masturbated. recalled telling Epstein that she was in high school. She recalled another woman inside the house when she arrived, but she did not recall the woman's name or appearance. 19. was interviewed on July 13, 2019, in New York. , when was approximately 14 years old, another young woman befriended outside her school described the young woman as white and slim with mid-length brown hair, but could not recall the young woman's name or any other identifying details 3r After woman invited to and the young woman became friends, the your Epstein's Manhattan residence. Over approximately the next year, i provided Epstein with 30 was interviewed during the Florida investigation and reported engaging in multiple paid sexualized massages with Epstein at his Palm Beach residence when she was a minor. also admitted to bringing two other minor girls, including to provide Epstein with sexualized massages. 31 We have not identified this individual. 24 EFTA_00022484 EFTA02731105 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) nude massages at the Manhattan residence, during which Epstein touched her breasts and masturbated. was paid $300 in cash following each massage. • while was massaging Epstein, he asked her to get on, him, which she did, and he then raped her despite her protests to stop. After the rape, stopped going to Epstein's residence and did not see him again. recalled that either Epstein himself or a secretary would schedule massage appointments. also recalled that the secretary would be near the entrance to the house when arrived for massages and sometimes paid after the massages. cannot recall the secretary's name or appearance. also remembered that a maid would sometimes bring her to the massage room, but again she did not recall the name or appearance of any particular maid. 20. was interviewed on Jul 17, 2019 in , when- was 16 years old, a friend of hers named recruited to give Epstein a massage at his New York residence. went to Epstein's New York residence and provided him with massages on two occasions. During both masse es, Epstein masturbated, touched and used a vibrator on her genitals. recalled Epstein telling her: "you look so young." brought a 19-year-old friend to E stein's New York residence to give Epstein a massage, after which Epstein paid her $200. recalls that she was given the phone number of a woman to call to schedule massage appointments. That same woman contacted to tell her not to bring that friend again because she was too old, but could not recall the woman's name and could not provide a description of the woman. 21. was interviewed on July 26, 2019 in New York. was recruited by three of her friends—named and to perform a massage fialtein at his New York residence , when was about 17 years old. only met E stein once and was accompanied by on that visit. When and arrived at Epstein's New York residence, an older woman in her 40s or 50s, who appeared to be a secretary, answered the door, but does not recall the woman's name or any other identifying characteristics. The secretary directed and to the massage room, where they met Epstein. During the massage, Epstein touched enitals and directed her to touch his genitals. After the massage. the same secretary provided 32 We have identified as Mr who, together with recruited minor girls ed massages wit stein in New York 25 EFTA_00022485 EFTA02731106 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) and with a white envelope containing cash. never saw or spoke with Epstein again. 22. was first interviewed on August 1, 2019 in New York. M , when was 16 and working as a model in New York, she was introduced to Epstein. On multiple occasions went to Epstein's Manhattan residence to engage in sexualized massages in exchange for money. During these sessions, Epstein masturbated and touched genitals with a vibrator. The abuse escalated over time to include oral sex, and during her last meeting with Epstein, he raped her. Epstein knew age, because she told him during their first meeting that she was 16. Shortly after met Epstein, he offered her an apartment in his building Mi nd accepted. Upon moving into the building, met a woman named (whom we believe to be who lived in a different apartment in the same building. recalled asking when they first met whether she i should be scared or concerned about Epstein. In response, brushed the concerns off, saying something like "you're fine." They did not otherwise interact much. recalled that on one occasion, purchased white lace underwear for at Epstein's direction. Epstein subsequently took pictures of wearing the underwear. On another occasions, recalled Epstein telling that was his "best little cocksucker." Additionally, was and wired money so that she and could travel to Paris and stay at Epstein's home there (though Epstein was not in Paris at the time they visited). also recalled at least one instance when called her to schedule a massage appointment with Epstein. After Epstein raped she decided to return home, and Epstein agreed to pay for her flight home. recalled that someone named Ghislaine, whom believed to be Epstein's assistant, emailed the plane ticket to her. On September 18, 2019, was re-interviewed addition to confirming the information she provided during her prior interview, provided additional details regarding her interactions with Epstein's employees. again stated that worked for Epstein as an assistant. At some point, Epstein said something about having put on his schedule. Both Epstein and would call and/or text to schedule massages with Epstein at his New York residence. also sent money via Western Union from Epstein when was travelling in Europe. In addition, recalled an instance in which Epstein forced her to perform oral sex on him while he sat on a cushion in a hallway inside his New York residence. 26 EFTA_00022486 EFTA02731107 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) As pulled away from Epstein's crotch, she saw standing the hallway. said "oh." then laughed. and walked away. Following that incident. Epstein bra ed to in front ofM that was his "best little cocksucker." In response, said something like. "oh, good to know." recalled hearing Epstein make this comment about her to on more than one occasion. She also recalled that Epstein would refer to her as "one of my girls" to On a separate occasion, Epstein directed to purchase new underwear for He specified that should go to Victoria's Secret and buy white underwear. Sometime later, gave a pair of white underwear. Epstein later photo phed in the underwear, but was not present for those hotographs. could not recall whether ever paid her for massages. did not recall ever talking about her own life, background, or age with After moved away from New York and stopped seeing Epstein, an assistant named reached out to her on E stein's behalf to schedule a return trip to visit Sn. Following that call, sent recalled that Ghislaine Maxwell was the name associated with the Expedia account that a round-trip plane ticket to visit Epstein. booked the ticket. did not end up using the tickets. never met or Maxwell in person. explained that her only interaction with was when first moved into theient building on East 66th Street. knocked on door to check on her. asked whether she • was safe here, and reassured her that she was fine and safe. 23. was interviewed on August 6, 2019 in New York. when was about 14 years old and attend hi shh school named invited her to give a rich guy a massage. to Epstein's New York residence. Upon arriving. massage room, where the massaged Epstein together. During the massage, Epstein masturbated and touched genitals with a vibrator. Afterwards. Epstein paid both and , a friend agreed and accompanied went with to the " We have identified as who, together with recruited minor ' is for sexuahz massa es wt E stein in New York. 27 EFTA 00022487 EFTA02731108 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Epstein subsequently invited to return, and over the next month, engaged in paid sexual massages with Epstein at his New York residence approximately twice per week. also knew that a girl named was bringing girls to Epstein. After about a month, began bringing other minor girls to massage Epstein, and Epstein paid for each girl she brought. She recalled bringing as many as three or four minor girls to Epstein in a single week. continued bringing girls to Epstein until she was 17 years old-Sometimes would participate in the massages, and sometimes she would wait outside the massage room. also recalled a few occasions when Epstein directed her to engage in sex acts with a tall blonde girl, whose name she did not recall, but who we believe to be did not recall whether she explicitly discussed her age or the ages of the girls she brought with Epstein. She stopped seeing Epstein after learning from the news that he was in trouble with law enforcement. Other than Epstein, recalled speaking with Leslie Groff on the phone when scheduling massages. Primarily, though, recalled that Groff would answer the phone and then transfer her call to Epstein. 24. On September 18, 2019, about 15 years old New York, where Epstein's New York residence, and went there to visit her. While there, an assistant, whose name does not recall, showed her around the mansion and took a clothed photograph of At some point, mentioned to the assistant that she was on a high school field trip. The assistant took down contact information, and then- left to go shopping. was interviewed in . When was she was living and went on a field trip to was living at the time. was staying at A few weeks after returned to from the field trip, Epstein's assistant called her to say that Epstein wanted to meet her and invited to see a David Copperfield show in Las Vegas. accepted the invitation, and her mother coordinated with Epstein's assistant to arrange the logistics. met up with Epstein, and a few other females whose names she does not recall in Las Vegas, where they all saw the show. From there, the group went to Epstein's private jet and flew to New Mexico. During the flight, Epstein asked her age, and she truthfully said she was 15 years old. and then stayed on Epstein's New Mexico ranch for a few days. One day, a redheaded female on the trip asked to give a massage.' believes she saw a camera in the corner of the massage room. The redhead directed to take off her clothes and then massaged her genital area. The next day, a middle-aged woman whose name 35 We have not been able to identify this individual. 28 EFTA_00022488 EFTA02731109 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) does not recall (but who is not Ghislaine Maxwell), told that Epstein wanted to see her. Epstein then took up to his bedroom, where he asked her to give him a massage. Epstein then used a vibrator to touch genitals. The next day, Epstein gave anal cash to go shopping. Later in the trip, Epstein bought white underwear from Victoria's Secret and photographed her wearing them. At some point during this trip, Ghislaine Maxwell arrived on the property, but did not interact with her. At the end of the trip, Epstein asked what she wanted for her future. said she wanted to go to college, and Epstein wrote her a $5,000 check, which did eventually use to help pay for college. After returned home, someone reached out and invited her to Epstein's island, but declined and never saw Epstein again. B. Interviews of Victims Who Were Abused As Adults was interviewed on August 27, 2019 in New York. reported being sexually abused by Epstein as an adult. is . When was over the age of 18, she met Ghislaine Maxwell in California through a man named Gypsy, who was teaching to be a professional masseuse. Maxwell eventuall recruited to fly to Palm Beach to provide massages both Maxwell and Epstein. When first arrived at Epstein's Palm Beach residence, Maxwell told her she would be fine and just to do whatever Epstein likes. Over the next approximately three years, travelled with Epstein and Maxwell as their masseuse, including on their trip to Africa with President Clinton. provided normal massages to Maxwell multiple times. also massaged Epstein, who forced her to engage in an escalating series of sexual acts with him. recalled that Epstein raped her approximately a dozen times over the three years she travelled with him. She never discussed the abuse with anyone else in Epstein's circle, including Maxwell. recalled that Leslie Groff and Maxwell coordinated the travel logistics for her and Epstein. She recalls that Groff was right outside the closed door to Epstein's office on one occasion when Epstein forced to perform oral sex on him, but she does not know whether Groff knew what was happening inside the office. believed Epstein was going behind Maxwell's back when he abused her and did not think Maxwell knew anything about Epstein's sexual advances toward her. Throughout her time with Epstein, felt very isolated and was not aware that Epstein was abusing any other victims, including 29 EFTA_00022489 EFTA02731110 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRAM. P. 6(e) 2. n On September 18, 2019, was interviewed in reported at sexually abused by Epstein as an adult. When was about 18 years old in or around she travelled to New York to work as a model. While in New York, met David Blau at a nightclub. Blane subsequently introduced to Epstein and brought her to Epstein's New York residence for a dinner arty, where gave Epstein her phone number. Subsequently, contacted to invite her to E stein's private island. accepted the invitation, and arranged her travel. subsequently had dozens of interactions with Epstein over the next year, during which she travelled to both the Vii islands and Palm Beach with him. During these tri s, met and Ghislaine Maxwell. understood that was Epstein's girlfriend. At some point, Epstein offered to pay $200 if she massaged him. agreed, and ended up giving Epstein multiple massages, during which Epstein engaged in sexual contact with her. did not feel comfortable discussing the details of the sexual contact during this interview. recalled telling her that Epstein wanted a massage on at least some occasions, and noticed that there were often numerous girls around Epstein's residences. did not know if any of those girls were minors. Epstein told though. that everyone. including was over the age of 18. also recalled taking one trip with during which they travelled to Las Vegas and then to New Mexico with Epstein. Before the trip, told Epstein that. E r was underage, and Epstein said that was fine. During that trip, recalled Maxwell engaging in sexual conversations, such as discussions of masturbation, but she did not recall Epstein being discussed during those conversations. 3 .= . was interviewed on Jul 17, 2019 in New York. reported being sexually abused b E stein as an adult. knew and interacted with Epstein between a oximatel In , when was 17 years old, she met Epstein through who had been previous) introduced to Epstein by a mutual . friend. At their first meeting, Epstein specifically asked her age and told her, in substance, that the could not interact until she turned 18. Atter her 18th birthday, Epstein began having give him masse es, Burin he used a vibrator to touch her genitals. A short time later, Epstein took and on a trip to his Virgin Islands residence. During directed Between, Epstein had intercourse with to give him a masse e, during which he raped her. on multiple occasions. 30 By 2007, Epstein knew he was under investigation for sexualized massages with minors. He pled guilty to a state solicitation of a minor charge in 2008. 30 EFTA_00022490 EFTA02731111 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) described the first few of these instances as forcible and explained that eventually she stopped resisting. recalled that Leslie Groff would schedule her massage appointments with Epstein and make her travel arrangements. Groff worked in an office inside Epstein's New York residence during the times visited, and met her many times. also recalled that an assistant named would sometimes cover for Groff and run errands for Epstein. also knew that worked as Epstein's assistant until she got married in or around 2011, and that was Epstein's girlfriend. When Epstein was serving his jail sentence, visited him while he was on work release at his office and engaged in sexual conduct with him there. After Epstein completed his sentence, did not have any other sexual encounters with him, but she occasionally worked for him by running errands or cleaning his house. In or around , Epstein paid $10,000 to many a young woman who was a foreign national and whom Epstein wanted to be able to stay in the United Sates. The two were married for about four years, then divorced in-. ceased all communication with Epstein after the divorce in-. 4. On October 24, 2019, was interviewed in New York. reported being sexually abused by Epstein as an adult. is met Epstein in New York in approximately when she was about 20 years old. At the time, was and had limited financial resources. A friend of from named suggested that could provide massages to a man who paid really well. agreed and began providing Epstein with paid massages at his New York Residence. During either the first or second massage, Epstein engaged in sexual contact with After that, began providing Epstein with paid sexualized massages multiple times per week. The appointments were scheduled at first by and then by either Leslie Groff or recalls being paid for the massages by Epstein, Groff, and Bella Klein. Within a few months of meeting Epstein, moved into Epstein's apartment building on 66th Street in New York. In or around travelled with Epstein to his residences in the Virgin Islands, New Mexico, and Palm Beach. At some point, Epstein escalated his sexual contact with by raping her. As she spent more time with Epstein, he became more controlling about her appearance. For example, Epstein limited food intake, bought her white underwear to wear, and made cut her hair short and die it blonde. During this same period, Maxwell was present for trips took with Epstein to the Virgin Islands. specifically recalls participating in conversations during which Maxwell provided and others, including with tips on how to please Epstein sexually. She recalled Maxwell describing Epstein as needing a lot of sex, and Maxwell encouraged and other girls to engage in sexual activity with Epstein. 31 EFTA_00022491 EFTA02731112 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Eventually, became aware that Epstein's actual girlfriend was On different occasions, Epstein directed to engage in sexual activity with other women in the contexts of masse es, including and as well as women named ". and■ also recalled introducing to stein, but she was not present when Epstein sexually abused. also recalled seeing Jean Luc Brunel. and at Epstein U.S. Virgin Islands home during 2007. On at least one occasion, took shopping and mentioned Burin the trip that Epstein liked white underwear. When travelling to the Virgin Islands, would collect everyone's passports and hold them until the end of the trip. At some point, heard about a news article saying Epstein was a child molester. confronted Epstein about the article, and he denied any knowing contact with minors. Epstein explained the situation by claiming that someone had shown him a fake ID suggesting she was 18 years old. About a year after meeting Epstein, during a trip to the Virgin Islands. posted a message on her MySpace a e co laining about being stuck on an island with a horrible girl named referencing Epstein learned of the post and became enraged. He sent back to New York and directed her to move out of the 66th Street building. Following this incident, continued to have contact with Epstein, but she spent less time with him.lpaein subsequently paid for to attend massage school, which she completed in around= Eipistein and Maxwell both asked to find other young women to massage Epstein, but= never actual( recruited anyone to do so. Epstein in particular said the younger a girl looked the better. recalled a conversation during which Epstein referred to Maxwell as too old, and Maxwell responded that Epstein liked girls too young. also recalled that would go to night clubs to pick up new girls to provide sexualized massages. recalled girls bringing other girls to massage Epstein. never asked how old these girls were, but they looked young. recalled that Brunel would bring girls to meet Epstein, but she does not know whether any engaged in sexual activity. She does recall, however. Brunel commenting that Epstein liked "them young." Around the time Epstein went to jail, asked to meet her at Epstein's New York Residence to go through stuff in the basement. Once arrived, directed her to throw away vibrators and nude photographs of young women. then paid for 37 We believe this woman to be who recruited other adult victims for Epstein in New York. The FBI made contact with in earlier this month. She provided contact information for an attorney w o represents er, and we are attempting to contact the attorney to request an interview. 32 EFTA_00022492 EFTA02731113 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) % helping with that task. also recalled and Epstein both telling her that if anyone in the press approached her, should not say anything. recalled two instances in which Epstein directed her to provide massages to other men, both of which occurred in or around 2011 or 2012. First, Epstein instructed to massage Leon Black at Epstein's New York residence. attempted to give Black an ordinary massage, but Black began initiating sexual contact, at which point ran out of the room. complained to Epstein, who laughed it off as a funny incident. also recalled a woman named being directed to massage Black, and afterwards, told that she had provided Black with oral sex during the massage. Second, Epstein instructed to provide a massage to Jes Staley in E stein's New York residence. attem tec Sve him an ordinary massage, but he forced raped Afterwards, complained to Epstein, who said he left it to to touch his genitals and then and Staley to decide whether to engage in sex. After this incident, began to distance herself from Epstein. Epstein did not pay for providing these massages to Black or Staley, but Epstein was paying for to finish her massage school at the time, so she felt indebted to him. 5. On August 26, 2019, was interviewed in New York. reported being sexually abused by Epstein as an adult. When was 19 years old in she was working at a coffee shop where a blonde Eastern European woman named approached her and recruited her to give a wealthy man a massage. told that she made money for each woman she recruited and assured that it would just be a massage and nothing more. agreed and later went to Epstein's New York residence to perform a massage. During the massage, Epstein directed to remove her clothes, and after she complied, he masturbated and touched her breasts and genitals. asked Epstein to stop, but he continued to assault her until he ejaculated. Aftenvards, Epstein paid in cash. recalled that a maid walked her up to the massage room and walked her out of the residence after the massage, but she did not know the maid's name or recall any identifying characteristics. attempted to get to return for another massage with Epstein, but never returned. 6. On August 28, 2019, was interviewed in New York. sexually abused by Epstein as an adult. In approximately when old, she met a woman named who appeared to be in her mid-20s, in time, was studying to be a massage therapist, and Maxwell, was looking for someone to replace was interested, so took a picture of face to show to her bosses. Shortly thereafter, someone called and arranged to fly her from to New York. Once in New York, provided a massage reported being was about 22 years At the said that her boss, Ghislaine 33 EFTA_00022493 EFTA02731114 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) to Maxwell at her residence. At the end of the massage, Maxwell told to give her partner, Jeffrey, "what he wants" and added "Jeffrey always gets what he wants." Maxwell then paid $100. Later that same day, went to Epstein's New York residence to massage him. He asked for a foot massage, and during the massage, he used his foot to touch her breasts and crotch through her clothing. At the end of the massage, Epstein fondled her genitals and buttocks through her clothing as was leaving. then left and never heard from Epstein or Maxwell again. 7. •=1 On August 28, 2019, was interviewed in New York. reported being sexually abused by E stem as an adult. explained that she previously did not recall who recruited her, but helped her remember that it was a woman named who was a woman with long dark hair.38 When was about 20 years' old living in New York in or around 2000, she met at a club. eventually invited her to meet a friend on the Upper East Side, and agreed.. then brought to Epstein's New York Residence. Once there, a woman who appeared to be Epstein's personal assistant, but whose name cannot recall, greeted them and had them wait. Epstein then invited. and into the massage room, where and gave Epstein a massage. During the massage, Epstein directed. and to engage in sexual contact with each other and also engaged in sexual contact with The encounter ended when someone knocked on the door and called for Epstein, who left in a rush.. and then left. The next day,. invited to return, but declined and never saw Epstein again. 8. On August 28, 2019, was interviewed in New York. generally reported being "sexually trafficked" by Epstein as an adult; however, was emotional throughout the meeting and unable to provide details regarding her experiences. She stated generally that Epstein, Maxwell, and Groff all mined her life, but she was too distressed to answer questions about what each of those individuals did. We have repeatedly contacted attorney (she is represented by ) to schedule a follow-up interview, but to date her attorney has not been able to coordinate another interview. 9. was interviewed via VTC on August 29, 2019. reported being sexually abused by Epstein as an adult. In or around when 38 The FBI has tentatively identified this individual as . We believe she resides in , and the FBI is attempting to contact her. 34 EFTA_00022494 EFTA02731115 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) was about 20 years old and living in New York, a young woman named approached her at a coffee shop where she worked. hung out with le times and then asked if she wanted to make money by giving a massage to her boss. said she had done it before and it was easy. agreed and accompanied to Epstein's New York residence. Once there, a maid whose name does not recall let the two into the house and took to the massage room while waited in the kitchen. Once was in the massage room. Epstein entered the room in a towel and laid on the massage table. During the massage, Epstein touched breasts and genitals while masturbating. After the assault, Epstein left, and the maid returned to bring= down to the kitchen, where gave S400. Afterwards, asked it wanted to return, but declined. then told that she made $600 per recruit and asked if she wanted to help recruit. again declined. 10. was interviewed on September 12, 2019 in New York. rs ted being sexually abused by Epstein as an adult. When was in her early 20. she was living in New York and working as a model. A booker recommended that she meet with Epstein because he could help her modeling career. ended up visiting Epstein's New York residence on one • easion. Upon arrival, she was greeted by a female assistant whose name she does not know. then met with Epstein alone in a room with a massage table. At first. Epstein told he could help her find modellithork with Victoria's Secret. Eventually, though, Epstein approached and attempted to touch her genitals. Epstein offered to pay money, but she refused to take anything from him. saw a large vibrator in the room, which she picked up and threw at Epstein before leaving. She never saw him again. 11. On October 23, 2019, was interviewed in New York. reported being sexually abused by Epstein as an adult. In when was 27 years old and working as a model in Los Angeles. a friend of hers introduced her to Epstein as someone who worked for Victoria's Secret and could help with her modeling career. Epstein then wane. meet with in his hotel room in Los Angeles. An assistant named Kimberly called to tell her the time and place of the meeting. During the meeting, Epstein told to undress and then groped her buttocks. resisted and decided to leave. Before left, Epstein handed her $100. never saw Epstein again. " We believe this individual to be 35 described above. EFTA 00022495 EFTA02731116 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 12. On October 23, 2019, was interviewed in New York. reported being sexually abused by Epstein as an adult. In or about when was about 22 years old, she was working as a model in New York and met a young woman named (believed to be at a club. told about a man who liked to help people and had connections in the modelling world. asked if would be willing to give him a massage while only in her undenvear, and agreed. subsequently went with to Epstein's New York residence. Upon arriving, took to the massage room, had her undress, and then left. then provided Epstein a massage during which he attempted to touch her and began masturbating. After the massage, Epstein paid $300, after which went down to the kitchen where was waiting for her. never returned and never saw Epstein again. 13. On October 23, 2019, was interviewed in New York. reported being sexually abused by Epstein as an adult. In or about when =was about 26 years old, she was working as professional masseuse Another professional masseuse connected with Epstein, who hired to massage him and others at his New Mexico ranch for about the next three years. recalls that Epstein would come to his ranch approximately three or four times per year, and during most of those visits, she would be asked to come to the ranch to provide massages. While at the ranch, provided massages to Ghislaine Maxwell and multiple young women who appeared to be models. also provided Epstein with massages, during which he would engage in sexual contact with her. Around saw whom- , at the ranch in Maxwell's office, but did not speak with understood that Maxwell was Epstein's girlfriend and ran the house. Maxwell encouraged to bring friends out to the ranch to provide massages, and emphasized that she wanted pretty, young women. brought one professional masseuse her own age once to the ranch. 14. On October 23, 2019, was interviewed in New York. reported being sexually abused by Epstein as an adult. In when was 18 years old and modeling in New York, she met a young woman named (believed to be massage in her underwear. at a night club. add that she could make easy money by giving a agreed and ended up giving Epstein paid sexualized massages on several occasions at his New York residence. Each massage was scheduled by and a maid whose name does not know would show to the massage room and pay her after each massage. At some point, Epstein connected with Jean Luc Brunel for a modeling interview. also went on one trip to the Virgin Islands with 36 EFTA_00022496 EFTA02731117 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Epstein and other young women. While on the island, provided Epstein with a massage during which he attempted to force her into more sexual activity than she was comfortable with. became upset, and she was sent home. She never saw Epstein again. C. Interviews of Witnesses Who Were Not Sexually Abused 1. Juan Alessi Juan Alessi was interviewed on July 13, 2019 in Florida. Juan Alessi ("Mr. Alessi") worked for Epstein as the house manager at his Palm Beach residence from the early 1990s until the end of 2002. Additionally, his wife, Maria Alessi, ("Ms. Alessi") also worked at Epstein's Palm Beach residence. Mr. Alessi recalled that in or about 1993, Ghislaine Maxwell took charge of managing Epstein's residences in Palm Beach, New York, New Mexico, the Virgin Islands, and Ohio. Around that time, Epstein specifically instructed Mr. Alessi to go to Maxwell for orders. Mr. Alessi described Maxwell as extremely demanding and compared working under her to "slavery." Mr. Alessi recalled that his relationship with Epstein began to deteriorate beginning in approximately 2000, when Maxwell instructed Mr. Alessi and other house staff not to make eye contact or be in the same room with Epstein. Around this same period, Mr. Alessi recalled that Epstein received approximately three massages per day when he was staying at his Palm Beach residence. Mr. Alessi understood most of the masseuses to be professional massage therapists from around the Palm Beach area, several of whom provided massages for Epstein's guests, including business partners and prominent people, at the Palm Beach residence. At first, Mr. Alessi was responsible for scheduling Epstein's frequent massage appointments, but during the last several weeks of his employment, was hired as Epstein's personal assistant and began scheduling the appointments instead. Closer to the end of his tenure, Maxwell asked Mr. Alessi to compile a list of all hotels and spas around the area of Palm Beach. After Mr. Alessi compiled the list, Maxwell instructed him to drive her around to each location. Maxwell would enter each location, then return with business cards of massage therapists. Mr. Alessi recalls one such incident in or around the summer of 2002 when he drove Maxwell to Mar-a-Lago and waited for her to receive a massage there. After Maxwell returned to the car, she observed a young girl, whom Mr. Alessi later learned was named and instructed Mr. Alessi to stop the car. Maxwell got out of the car and went to speak with for about 20 to 25 minutes before returning. Later that same day, Mr. Alessi saw come to Epstein's Palm Beach residence. Over the next several months, returned just about every day to the Palm Beach residence to give Epstein massages. Mr. Alessi recalls learning that was also traveling with Epstein to other locations, and he recalls bringing other girls about her age to the Palm Beach residence to massa ge Epstein. Mr. Alessi understood that was under the age of 18 but did not know what was doing in the "massages" with Epstein. 37 EFTA_00022497 EFTA02731118 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Mr. Alessi also recalled that a young girl named used to come to the Palm Beach residence regularly. He recalled that was and that she and her mother visited Epstein's Palm Beach residence multiple times. Mr. Alessi and his wife both picked up and understood that was a friend of Epstein's. Mr. Alessi recalled that travelled with Epstein at least one time and eventually moved to with Epstein's help. Mr. Alessi observed Epstein kiss on the cheek and pat her on the bottom. In total, Mr. Alessi saw "hundreds" of girls at Epstein's Palm Beach residence, but he believed the majority to be in their 20s. Toward the last few months of his employment, Mr. Alessi began seeing younger girls, most of whom were brought to the residence by Maxwell instructed Mr. Alessi not to ask these girls their ages or speak to them. Mr. Alessi recalls that Maxwell hired younger girls to come to the Palm Beach residence, including two girls whom Mr. Alessi knew to be in high school, but whose names he could not recall. Mr. Alessi believed most of the young women who came to the house to be professional masseuses, but he also recalled cleaning up after massages and finding sex toys in the room, which he then washed. Mr. Alessi also recalled that Maxwell kept a basket filled with sex toys in her room and that Maxwell was occasionally inside the massage room with the young women who came to the house. Mr. Alessi also recalled more generally that many young women would be topless or naked by the pool. At the very end of his tenure, Mr. Alessi told Epstein that he should slow down, that "these girls" would get him in trouble. Epstein remarked that it was fine, and that "these girls only care about money." When Mr. Alessi left Epstein's employment, Epstein told him: "I hope you keep your mouth shut." 2. Maria Alessi Maria Alessi was interviewed on July 13, 2019 in Florida. Ms. Alessi worked for Epstein at his Palm Beach residence from the mid 1990s until the end of 2002. Ms. Alessi primarily worked outside of the house, often shopping and running errands, so she was not able to observe most of the visitors to the house. When asked who, if anyone, she specifically recalls coming to the Palm Beach residence, Ms. Alessi recalled Ghislaine Maxwell frequently visiting the residence with Epstein. Ms. Alessi believed that Maxwell was Epstein's personal assistant. She also recalled seeing at the Palm Beach residence. She also recalled seeing girls in their 20s or 30s around the house. 3. Gregory Bledsoe Dr. Gregory Bledsoe was interviewed by telephone on July 22, 2019. Bledsoe is a doctor who was hired by the Secret Service to provide backup medical services for Bill Clinton during a trip to Africa in 2002 on Epstein's private jet. Bledsoe recalled that Ghislaine Maxwell and four 38 EFTA_00022498 EFTA02731119 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) young women. including a masseuse named and a model named accompanied Epstein on the trip.40 Bledsoe stated that there were no minors on the flight. He did remark, though, that he found it odd that Epstein would bring four women on the it iiind he witnessed Epstein grabbing buttocks on the plane. Bledsoe also noticed that appeared to be intentionally positioning herself in front of the bedroom door so that no one other than Epstein and his entourage could go inside the bedroom on the plane. Otherwise. though. Bledsoe did not recall any suspicious or inappropriate behavior during the trip. 4. Richard Barnett Richard Bamett was interviewed on September 16, 2019 in New York. Barnett was the chief engineer and property manager for Epstein's New York residence from approximately 1995 through approximately 2014. Barnett had never been interviewed previously, and he was fully cooperative in the interview. He explained that he was hired by Maxwell and his job was primarily to keep the property in full working order, which included maintenance of mechanical operations including the elevators, HVAC operations, electrical work, and other structural aspects of the house. He also occasionally visited other Epstein properties for similar purposes. Barnett has formal training as an engineer. He had little day-to-day interaction with Epstein, and primarily reported to Maxwell until around 2007 or 2008. and then to He described having seen many young women at the property, but none with whom he interacted directly; he was instructed not to speak to guests at the house. During the initial Florida investigation, he was told by Epstein's attorneys that Epstein had inadvertently patronized an underage prostitute, and as a result, he did not know the scope of Epstein's misconduct until his arrest in 2019. D. Interviews of Subjects of the Investigation 1. • was first interviewed with her attorney present and pursuant to a proffer agreement on July 12, 2019 in was born in and spent her childhood in graduated high school in and when she was about 18 or 19 years old, she left to travel as a model. , who connected her with a modeling agency in In or around late moved to where she married her first husband in . They ultimately divorced . Before she began workua.br Epstein in husband' and obtainin her continued modeling while also workin her associate's degree from After obtained her bachelor's degree in and . She is currently employed leaving Epstein's employ in early her master's degree in 4° Flight logs for this trip confirm that these individuals were all on E stein's private jet. The FBI has not yet been able to identify contact information for 39 EFTA 00022499 EFTA02731120 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) In or around community. Around assistant. Around early his employee until early Maxwell. was in her early 20s, she met Epstein through the modeling , Epstein offered a job working as an began working as an assistant for Epstein, and she remained reported to who reported to Ghislaine responsibilities included running errands and scheduling appointments. As a result, scheduled numerous massages for Epstein. According to Epstein expected to have two massages every day: one in the morning and one in the afternoon. and- were responsible for ensuring that these massages were confirmed when Epstein was in Palm Beach. Leslie Groff was responsible for scheduling the massages when Epstein was in New York. At some point, Epstein began forcingM to engage in sexual encounters, which were coercive and nonconsensual. was very distressed when discussing these incidents and did not want to describe them in detail during our first meeting. At least some of these encounters involved providing Epstein with his massages while at his Virgin Islands residence. As a result, was aware that Epstein's massages were usually sexual. described how Epstein had two groups of girls who provided massages in his Palm Beach and New York homes: one group was of professional masseuses who gave actual massages to Epstein's friends, and the second group consisted of younger girls who were not professional masseuses and who only gave massages to Epstein.. explained that she implicitly understood at the time, and now realizes fully that Epstein was engaging in sexual contact with the second group of girls. When scheduling massage appointments, either or Epstein would provide with the names of girls to call for massages, but for the most part called to confirm massage appointments. • also recalled that would sometimes ask to call some of the masseuses and ask if they have another girl to bring.. would occasionally show girls to the massage room and set up the massage table. • believed it was possible Epstein had asked to pay the girls, but she cannot recall for certain. typed up a list of girls to call in Palm Beach and printed copies. recalled certain details that signaled to her, in retrospect, that girls in this second group were minors. For example, she was asked to help find SAT prep courses for one girl, and she recalled girls mentioning school and their parents. That said,M was- was not at the time familiar with the SAT or the fact that it is typically taken by high school students. explained that, at the time of the relevant conduct, she never consciously realized that any of the girls involved in sexualized massages were underage. She now realizes in retrospect, that she should have known that at least some of these girls were minors. 40 EFTA_00022500 EFTA02731121 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) also recalled frequently photographing other women, including taking nude photos of understood that Maxwell kept binders of those nude photos in her home in New York. In 2005, Epstein directed. to collect all contact books and computers from his Palm Beach residence and provide them to a man who met. at the residence. was present for the conversation in which Epstein gave. these instructions. Sometime later in 2005, also asked. to take the contact books from the Virgin Islands and shred them. Epstein was under investigation at the time. On September 10, 2019, we met in with_- and her attorney for a second proffer, during which we further discussed her year working for Epstein. During employment for Epstein, she, and all had apartments in Epstein's 66 Street building in New York.. recalled times when photographed. and recalled that Maxwell had binders of nude photos of women posing in Epstein's different residences.' Generally, during her year working for Epstein,M noticed that Epstein received two massages per day. Leslie Groff scheduled the massages in New York, while and. scheduled the massages in Palm Beach. understood that Maxwell was Epstein's ex-girlfriend. Maxwell would give. directions about tasks to carry out, such as errands for the houses. also recalled one instance in New Mexico when Maxwell told. that if she found a pretty girl, she should get the girl's number so that the girl can massage Epstein. Also during this proffer, we reviewed certain documents, such as message pads, recovered from Epstein's Palm Beach residence during the first Florida investigation, with- She confirmed that she wrote one message for Epstein from Jean Luc Brunel that referenced having a teenage girl for Epstein to meet. distinctly recalled Maxwell commenting on how funny that particular message was. also confirmed that at least one message referenced someone who was being scheduled to massage Epstein being in high school. also recalled at least one girl recalls wantin, about college, and another girl named. discussing the SAT. discussing SAT classes with Maxwell at some point and also recalls ordering SAT prep books for her. knew that shared an apartment in New York with She recalls left the apartment and stopped spending time with Epstein after developing an eating disorder. also met believed was over the age of 18 when she met her. also knew that recruited girls for Epstein in 41 description of these binders is consistent with the binders of photographs recovered from Epstein's New York residence during the execution of a search warrant there in July 2019. 41 EFTA_00022501 EFTA02731122 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) New York and shared an apartment with 42 who also helped find girls to massage Epstein.. also recalled a young woman named travelling with Epstein. provided. with training regarding how to make scheduling calls and was direct supervisor. During the year. worked for Epstein, would primarily take responsibility for calling to confirm massage appointments when she was in New York and planning to travel to Palm Beach.. recalls Epstein wanted his massages confirmed either the night before or morning of each appointment. recalled that there were certain girls, such as and who would come to the Palm Beach residence with other girls and wait in the kitchen while the girls they brought massaged Epstein. In those circumstances both the girl who gave the massage and the girl who waited in the kitchen would be paid. stated that although in retrospect she believes there were indications that some of the individuals providing massages to Epstein were especially young or in high school, she did not know at the time that certain individuals were underage. She did understand generally, though, that at least some massages involved sex acts because she was required to perform such acts in the context of massages for Epstein. At some point when she was in Miami with Epstein and was directed to drive to Palm Beach to meet someone there. Both and Epstein told to drive to Palm Beach.. did not understand what was going on, but she recalls Epstein saying something happened with a visa. Epstein and directed. to gather computers and directories from the Palm Beach house and give them to a man who would meet there. gave. the phone number of the person. was to meet in Palm Beach. followed these instructions and gave the computers and directories from Palm Beach to a man who met her at Epstein's Palm Beach residence.43 After. completed that task in Palm Beach, asked. to gather the directories from Epstein's Virgin Islands residence and bring them back to New York. reminded. to check every building on Epstein's island for the directories. followed this instruction and brought the directories to Maxwell's house in New York, where she gave them to then told. to shred the directories in Maxwell's house. also recalled an instance when Darren Indyke met with her and told her that if she ever needed help she should not talk to the police. 42 appears on a number of logs for Epstein's private jet. The FBI has identified two potential addresses for and is attempting to contact her. 43 Materials from the search warrant executed by the Palm Beach Police Department in 2005 confirm that computers appeared to have been removed from Epstein's Palm Beach residence prior to the search. 42 EFTA_00022502 EFTA02731123 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) advised that she was also extensively sexually abused by Epstein during her year as his employee. Although we did not delve into specific detail about all of those events, she described having been requiredarovide sexual massages, similar to many other victims we have interviewed in this case. was primarily required to provide Epstein with sexualized massages at his residences in the Virgin Islands and New Mexico, though she recalls one such massage in Palm Beach. Epstein cone ed to that her job responsibilities included providing sexual masse es to him. recalled having about five sexual encounters with both Epstein and who was Epstein's girlfriend at the time. did not feel that she could decline to engage in sexual activity with Epstein. Her job depended on relenting to his advances, and she knew that he had guns, some of which he kept in his bedroom. After about a year, was finally able to quit and return to living with her husband. 2. On October 7, 2019, attorneys provided us with an attorney proffer, during which they explained how met Epstein and how Epstein abused her over several years, be innin when she was 18 years old. It was during the course of this abuse that Epstein brought into some of his massages to participate in sex acts with other girls. The attorney proffer detailed how Epstein controlled every aspect ofl life—including her physical appearance, her weight, and her clothing—for years. This controlling behavior took multiple abusive forms, including forcing to have multiple plastic surgeries, forcing her to engage in BDSM, referring to her as his "sex slave," insulting her, and physically abusing her, including by choking her and throwing her down a set of stairs. Additionally. her attorneys provided us with a photograph o and who both appear very thin— together wearing t-shirts that read "Don't Feed the Pig." 43 EFTA_00022503 EFTA02731124 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) First, on October 11, 2019, participated in an interview during which she walked us through her back ound, how she met E stein, and the general contours of her relationship with him. was and began modeling in Europe in her early teens. In approximately , when was IS years old, she received a visa to travel to New York to work as a model for Karin Models, which was owned by Jean Luc Brunel. was in New York for a few weeks before she met Epstein. During that time, employees of the agency told that she owed the company money for her travel and housing, but she also needed to lose weight before she could go on any castings. did not end up going on any castings because in-she met Epstein at Jean Luc Brunet's birthday party. Afteiegd 45 a few days later, inviting her to Palm Beach. briefly with Epstein at the party. received a call from E rein's assistant, eventually agreed to travel to E stein's Palm Beach residence, and during that first trip, Epstein engaged in sexual contact with flew with Epstein. in a massage room. A few days later, and to the Virgin Islands. She remained there for a few days before flying back to New York. In October 2003,E stein aid for to fly back to so that she could finish high school there. then returned t in or around at which int E stein offered to let her stay in an apartment in his building on 6 Street in New York. agreed. and after that, she travelled everywhere Epstein went. including his residences in New York, Palm Beach, the Virgin Islands, New Mexico, and Paris. Eventually. began travelling with Epstein less and less over the ensuing years. remained in a relationship with Epstein until August 2010. Earlier on. travelled often with Epstein and was roommate and close friend. and Ghislaine Maxwell also travelled with Epstein, and Jean Luc Brunel was also close friends of Epstein. Earlier on, Maxwell slept in Epstein's room when the traveled together, but eventually. began sleeping in Epstein's room. recalled that other assistants who worked for Maxwell and/or Epstein were and was unsure whether as The FBI has been unable to obtain contact information for 46 The FBI is attempting to identify contact information for 44 EFTA_00022504 EFTA02731125 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) assistant as well. recalled that Epstein would pit the women in his circle against each other and encouraged a lot of secrecy. also recalled that a woman named introduced some young women to Epstein in New York. In or around 2006, Epstein told that had been arrested for a drug charge, and to save herself, she set up Epstein to be investigated. was familiar with ■ as someone who gave Epstein sexualized massages. At some point later, learned that the charges against Epstein related to prostitution. recalls that her general sense at the time was that Epstein was being treated unfairly and that the women were setting him up to get money. emphasized that she now realizes that narrative was not true, but she accepted Epstein's version of events at the time. To reinforce this narrative, Epstein repeatedly provided with examples of women he claimed were blackmailing him. Epstein also told that if she was ever approached, she should not talk and should either tell Epstein or find a lawyer. recalled being interviewed by Epstein's attorneys around the time of the first investigation, and she remembers going into the interview with the goal of being on Epstein's "side." During the interview, she described sex acts she had with other women together with Epstein in Florida. Eventually, Epstein told and that he was going to jail for soliciting a prostitute. Epstein told them that the women he had engaged in sex acts with had lied to him about their ages. When Epstein went to jail in 2008, became closer with and they remained good friends for years until Epstein was arrested in 2019, at which point attorneys advised her to stop speaking with While Epstein was serving his first jail sentence in Florida, frequently visit him. She also recalled that and Brunel often visited Epstein. During that same period, began . After Epstein was released from jail, in or around 2009, Epstein became increasingly aggressive and irritable with At one point in 2009, Epstein became particularly violent with so she left. He then convinced her to return, but again in 2010, he was violent with her, and she ended the relationship. Until about 2012, Epstein's plane, and he would have sex with her on some of those trips. In 2012, began working as at her own company, and she stopped having sex with Epstein. In the last year or so before Epstein's 2019 arrest, he would check in with- whenever a news article that referenced her was published. explained that because of her association with Epstein, she has not been able to maintain steady employment or build new relationships. told Epstein about these difficulties, and they came to an agreement that Epstein would double whatever money she was able to make through her work as He also covered medical expenses for her and paid for her attorneys when she was deposed in 2015. also noticed that whenever negative articles were published, Epstein would wire her money. This included a $100,000 wire shortly after the Miami Herald 45 EFTA_00022505 EFTA02731126 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) series was published in November 2018. believed Epstein sent her this money because he felt guilty for the trouble the articles caused her. Second, on October 15, 2019, we met with for another proffer, during which she reviewed in more detail certain aspects of her experiences with Epstein. recalled that before the first investigation into Epstein, he had a number of nude photos of women in his residences, but at some point after the investigation, there were far fewer of those photographs in his Florida and Paris residences. Once Epstein was in jail, would visit him frequently. When he was in jail, Epstein would have his lawyer Darren Indyke and a paralegal bring him a computer, which he used to have video sex with While Epstein was on work release, a number of women visited him at his office and would watch movies with him on a couch. At some point when Epstein was on work release, was put on his approved driver list and would drive him back to jail at night in a suburban with a mattress in the back. Most nights, she and Epstein would park near the jail and have sex in the back of the car. Epstein seemed friendly with the guards at the jail, but she does not know why he was permitted these freedoms. Shortly after met Epstein, he pushed her to have a threesome with another woman. ultimately agreed, and Epstein subsequently brought into the massage room with other young women to engage in sex acts. The first time this took place was in Epstein's Palm Beach residence with who was a minor at the time. During that massage, Epstein directed and to massage him and then engage in sexual contact with each other and with him. had a few such experiences with. At the end of each sexual encounter, Epstein would send out of the massage room. recalled that or another member of the household staff would sometimes set up the massage room. does not recall seeing receive money. Epstein did not pay for engaging in sex acts, but he would give $100 bills as pocket money when they went on new trips together. Although knew■ was a senior in high school, she believed■ was at least 18 because of an instance when Epstein sent the two of them to an adult store where they were carded before entering. produced an ID and was permitted to enter the store, so assumed that was at least 18 years old. also recalls bringing a explained that was 17 at the friend to massage Epstein and talking about wanting to go to college. in most high school seniors are 18 or 19, but she now knows that time. In additional to. recalled having sexual encounters at Epstein's direction with a young woman named and a young woman named in the Palm Beach residence. Each took place in the massage room. Both and the other girl would massage Epstein, then Epstein would direct the girls to engage in sexual activity with each other and with him. Each encounter ended with Epstein ejaculating, at which point he would direct to leave the room, while the other girl stayed in the room and got dressed. 46 EFTA_00022506 EFTA02731127 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) More generally, understood that Epstein received one to two massages per day from women in Palm Beach. All of the young women appeared to be age, but she did not know for sure how old they were. In addition to the three girls with whom she had sexual contact, recalled masseuses named and One of or would walk the girls up to the massage Epstein's assistants—either room prior to each massage. also recalled that some of these girls would bring friends and wait in the kitchen while the friends ave Epstein a massage. heard the assistants scheduling massage appointments, but was not generally involved in scheduling. She believes she may have reached out to at some point to schedule a massage, though she is not certain. may have occasionally answered the phone in Epstein's Palm Beach residence and taken messages, but that was not her primary responsibility, so she did not do so frequently. knew that some masseuses, who were older than the other masseuses who only massaged Epstein, provided traditional, non-sexual massages to herself, Maxwell, and was not initially sure what was going on in the massage room with Epstein. Although she learned from her own experience that he engaged in sexual activity during massages, she was unsure whether every massage appointment involved sexual activity, or just some. Before Epstein went to jail, the frequency of his massages slowed and eventually stopped entirely. When was in New York, she did not stay in Epstein's New York residence, so she was not as familiar with his massage routine there as she was with his routine in Palm Beach. She did recall, however, multiple occasions when Epstein brought her into the massage room in his New York residence for sexual encounters with him and other women. also recalled some such experiences at Epstein's Virgin Islands residence, including at least one encounter with and a woman named did not recall encounters with other women in New Mexico, but she recalls some sexual encounters with Epstein and an older woman at Epstein's Paris residence. Third, on October 25, 2019, we conducted our final proffer with during which she provided additional details regarding her time with Epstein. When asked about Epstein's massage routine at his New York residence, recalled that he would usually have a morning and afternoon massage, both of which were ordinarily scheduled by Leslie Groff. The women coming over to give these massages appeared similar in age and general appearance to the young women who came for massages in Florida. Again, did not know the ages of these young women, though she believed they were around her age. Epstein stopped getting regular massages after he completed his jail sentence. did not recall people coming for regular massages in the New Mexico residence, but there was a massage room at that residence. In the Virgin Islands, one or two 47 EFTA_00022507 EFTA02731128 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) women came to give Epstein massages, but believes they were licensed masseuses. They would go into the massage room with Epstein. As to the young women who gave massages in Florida and New York, does not expressly recall seeing anyone pay those girls, but she acknowledged that it was reasonable to think that they were getting paid. Looking back, realizes that Epstein probably had her leave the room after each sexual encounter with another girl so that he could pay the girl. recalled that Epstein made her believe that and. were attracted to her and wanted to engage in sex with her. In retrospect, she realizes that was not true, and she is embarrassed that she believed him. was also aware that Epstein's assistants gave Epstein massages, and she believed and were each sexually involved with Epstein at some point. Epstein would refer to the group of assistants and girlfriends who traveled regularly with him as his "family." impression was that the only person Epstein saw as his equal was Maxwell. Epstein and Maxwell talked openly about sex. recalled one instance when Maxwell was with a group of girls at Epstein's Virgin Islands property and discussed oral sex and erotic books to read. and were all dependent on Epstein, which was in contrast to Maxwell, who was much older than those three. remarked that the longer a woman was around Epstein, the harder it was to get out, and she has no idea how managed to leave. She remarked that only "got out" by getting married, and "got out" by becoming also reviewed the details of her interactions with Brunel. She recalled that Brunel would encourage her to be good to Epstein and massage his feet for him. believed that Brunel and Epstein had a close relationship, and she heard them talk about women and sex in front of her. In or around early Brunel brought a young girl, who was about 15 years old, to Epstein's Virgin Islands residence. assumed as much because Epstein commented that the girl was 10 years younger than but does not know her exact age, nor does she know whether anyone engaged in sexual contact with the girl and does not recall the girl's name. During her years with Epstein, visa was sponsored by Brunel's modeling agency, even though she was not working. Epstein told that he paid Brunel $1 million to keep her in the country. As a result, felt that Epstein could have her deported with a single phone call to Brunel. In 2011, Epstein and Brunel refused to help renew visa, but she was able to obtain one through her work as explained that for years she and both thought that Epstein was the victim of a witch hunt targeting a wealthy man. She now realizes that Epstein was abusive, and she is embarrassed that she believed his manipulative narrative for so long. More recently, told about some of the physically abusive behavior Epstein engaged in toward her, and expressed surprise, saying she did not have similar experiences. 48 EFTA_00022508 EFTA02731129 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRAM. P. 6(e) 3. attorneys provided attorney proffers to us on July 31, 2019, September 6, 2019, and October 18, 2019. These proffers covered personal background, introduction to Epstein, sexual abuse she experienced at Epstein's hands, and job Tsi sibilities for Epstein. Her attorneys said that scheduling massages was just one small part o job. They also asserted that did not know that the massages involved sexual contact or that any masseuses were minors. Following these meetings, proffered with us, pursuant to a proffer apeement, on two occasions. The information she provided in those proffers closely tracked the information provided by her attorneys in their proffers and accordingly do we not separately summarize the attorney proffers below. We a with her attorneys, however, that for purposes of these two proffers, we would not discuss obstructive conduct during the first investigation. On November 26, 2019, we interviewed in New York. While there, some modeling jobs. As a result, was extremel isolated and alone to live with her husband and his family. and atte ' ted to find to support herself. After about a year. in or around a coworker mentioned a wealth couple who was looking for a personal assistant and invited to meet them in agreed and flew to where she met Epstein, Maxwell. and flew with that same group to New York. During this trip, there, 49 EFTA_00022509 EFTA02731130 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) herself as an ideal personal assistant for Epstein and Maxwell. flew back was back in for about a month before Maxwell called her and asked her to fly out to Palm Beach. agreed and was on a plane the next day. She then spent a few days at Epstein's Palm Beach residence, during which she was formally hired as Maxwell's personal assistant. She then continued travelling with Epstein and Maxwell and never returned . Shortly after was hired, Epstein instructed her to take a bath with him, during which he told her "you go the job, now you just have to keep it." Epstein then engaged in sexual contact with and understood that her job was dependent on her willingness to submit to Epstein's sexual demands. responsibilities included coordinating travel for Epstein and his entourage, managing his houses, completing shopping, organizing schedules and binders for each house, digitizing photographs, and running errands. For her first few years of employment, reported directly to Maxwell, and she worked out of Maxwell's house when they were in New York. When in New York, would occasionally stay at Epstein's New York residence, but she primarily resided in an apartment in Epstein's building on 66th Street. When Epstein got out of jail, no longer reported to Maxwell and instead worked out of Epstein's residence when they were in New York. During the time she worked for Epstein, travelled with him wherever he went. Each morning, either Epstein or Maxwell would give a list of tasks to complete for the day. When Epstein was in Palm Beach, was responsible for scheduling his daily massages. Typically in Palm Beach, Epstein would receive a morning massage and an afternoon massage. Maxwell and taught how to schedule massages using a directory that was kept in Maxwell's office. Maxwell or Epstein would tell who from the directory to call for a particular massage. Typically, would call to schedule massages a day ahead of time. believed that the people she was calling were experienced masseuses. If one masseuse could not make an appointment, she would either tell Maxwell or Epstein, or she would ask the masseuse whether they could refer anyone else. Eventually, was shown how to edit the directory on the computer,' and she would update the directory with new contact information for new masseuses when told to do so. recalled that some of the masseuses were regulars, while others came less frequently. Maxwell and other guests would sometimes get massages as well, and those ' This appears to be the directory that. was instructed to remove from Epstein's Palm Beach and Virgin Islands residences. As discussed above, was also instructed to remove the • computers from Epstein's Palm Beach residence, whit appears to have included the computer on which edited the directory. As result, law enforcement has not recovered a copy of this directory. 50 EFTA_00022510 EFTA02731131 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) massages were provided by people on the same directory list as the people who massaged Epstein. When asked what types of reasons these people gave when they could not make appointments, said she recalled some saying they had to work and one referencing soccer practice. When a masseuse arrived at the Palm Beach residence, generally someone would meet her in the kitchen. would then take her up to the massage room. If it was a masseuse's first time, would show her the table, lotions, and towels. would then leave and tell Epstein that his massage was ready. would typically then go run errands while Epstein received his massage, and she was sometimes present when a masse e finished. Sometimes multiple girls would give Epstein massages at the same time, but did not recall anyone bringing a girl for a massage and then waiting for that girl inside the house. did not really talk with any of the masseuses or learn about , and she recalls another who was pregnant. At riersonal lives. She did recall, though, one girl sa that she was on break from college believed that Epstein usually paid the masseuses, but a couple of times he asked her to pay them. recalled paying the masseuses around $200 per massage. When asked to name the masseuses she remembered, listed several names, including recalled that M and She was attendm cone e and that had a baby at some point, but she did not know much about or remembered one time when called and asked how much Epstein would pay to have sex with one of the masseuses. was shocked and told that Epstein "doesn't do that." did not mention the conversation to Epstein because she worried he would get mad at her and she felt uncomfortable bringing it up. also did not think that sexual abuse was taking place during the massages for several reasons. She explained that some massages were provided b men,49 and that no one ever acted like anything was wrong. The masseuses would also call and ask to come back, so did not believe anything abusive was taking place. also walked in on some of Epstein's massages, and the masseuses she saw in the massage room on those occasions were clothed. Epstein also asked to rovide him massages on a couple occasions, but they never turned sexual. As a result, did not connect massages with sexual activity. 48 was interviewed during the first Florida investigation. During that interview smil.vhen=1 was 23 years old, Maxwell recruited her to work as an assistant at Epstein's Palm Beac residence. She eventually gave massages to Epstein, and Her massages with Epstein included sexual contact. " No other witness has described any male masseurs providing massages to Epstein or anyone else in Epstein's circle. 51 EFTA 00022511 EFTA02731132 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) viewed the masseuses as her peers — i.e., young adults in their early 20s — and it never her mind that any of them were minors. In view. Epstein was the head of the household, and everyone did what he said. did recall Epstein telling her that he was for an SAT tutor for but never took the SATs because so she did not know what that test was or what it meant. She has recently learned that it is a test that someone would ordinarily take in high school, but she did not know that at the time. only learned that Epstein was sexually abusing minors when news articles started coming out about it. She recalled being shocked, angry, and disappointed. She was particularly angry with Epstein for manipulating her to help orchestrate the abuse of other women. During the first investigation, Epstein showed some of the masseuse's MySpace pages in which they claimed to be 18 or referenced drug use. felt that she had nowhere to mnd her reputation was ruined in the press, so she did not think she could get another job. said that she still feels awful and wishes she could apologize to the victims. She also said that she wishes she had been interviewed during the first investigation so that she could have told someone that she was being abused and explained that she did not recruit or procure girls—she just met them when they came to the house." On December 4. 2019, we conducted a second proffer with in New York. This proffer focused on the 5250.000 payment she received from Epstein in late 2018 and on the sexual abuse she experienced while working for Epstein. With tcsyect to the 2018 payment, explained that between approximately 2016 and 2018, she and her husband experienced fmancial difficulties. was still in touch with Epstein and saw him every other month or so. During those meetings. told Epstein about her financial troubles. Then one day in early December 2018, Leslie Groff emailed inviting her to visit with Epstein at his residence in New York. accepted the invitation and once again told Epstein about her financial difficulties. In r e. Epstein made a call to his accountant, Rich Kahn. and directed Kahn to wire 5250,000 to Epstein told not to tell anyone about the payment, but he did not say why. assumed Epstein did not want her husband to feel badly about accepting such a gift. The last time Erarnrovided with money before that transaction was a $100,000 gift for her wedding Notwithstanding Epstein's instruction to the contrary, told her husband about the $250,000 payment, and they used it to deal with their financial problems. mentioned the payment she received to who responded that she had recently received a payment of 5° We did not discuss the end of her relationship with Epstein durin this roffer. As discussed below, we covered that time period during our second proffer with 52 EFTA_00022512 EFTA02731133 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) $100,000 from Epstein. said that Epstein called her one day and asked if she could use money, and when she said yes, he sent her the money. believed Epstein was being generous because during their prior conversations about her financial difficulties, Epstein had told that she would always be safe and he would always take care of her. When asked about the Miami Herald series, said she was aware as early as April 2018 that a reporter for the Miami Herald was working on a story about Epstein. was aware of the series the day it was published in November 2018, and she recalls that she received the email from Groff inviting her to meet with Epstein within a day or two of the series' publication. Although recalled mentioning the series when she met with Epstein in early December, she does not recall the details of what they discussed and did not believe the payment and articles were related. With respect to Epstein's sexual abuse, reiterated that Epstein first engaged in sexual contact with her shortly after she was hired when he directed her to take a bath with him and indicated that her job depended on engaging in sex acts with him. explained that she did not feel that she had a choice because she did not want to lose her job, which had finally helped her feel financially secure. Epstein paid for housing, travel, clothing, and food, in addition to paying her a salary, which began at approximately $35,000 per year, then increased annually until she was earning a bit over $100,000 per year. When Epstein went to jail, she took a pay cut to $75,000, which remained her salary until she left her job when she married her husband . Epstein also paid for attorney when she was deposed in lawsuit. For approximately the next several years, from approximately until around the time Epstein went to jail in 2008, Epstein engaged in frequent sexual contact with Over that period, could only recall a small number of trips she took with Epstein during which he did not engage in some sort of sexual contact with her. Usually this contact involved Epstein bringing to a bedroom and giving her explicit instructions regarding how to touch him and how to position herself while he masturbated on the bed. Additionally, Epstein frequently snuck into room while she was sleeping and woke her up by fondling her. insisted that she had no memory of any sexual contact taking place in any massage room with Epstein or in the context of any massage at all. During this period, had a small number of serious boyfriends, and Epstein knew about those boyfriends but still engaged in sexual contact with did not want to engage in any sexual contact with Epstein but felt obligated to do so in order to keep her job. The sexual contact slowed sometime before Epstein went to jail and evolved into Epstein just asking to sleep in his bed but not engaging in sexual contact. As this contact slowed, believes Epstein was spending more of his time with who was his girlfriend. After Epstein was released from jail, no longer slept in his bed, and they no longer had any sexual contact. 53 EFTA_00022513 EFTA02731134 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) explained that she did not quit her job because she did not know where else she could go and was completely dependent on Epstein. She had no friends outside of Epstein's world, no education, and no family to support her. Epstein was also controlling in other aspects of_ life. He would become enraged if she made a mistake or did not follow his instructions about travel plans precisely. Epstein also controlled physical appearance. He made her cut her hair short and dye it blonde. He also selected her clothes and would comment on her body and encourage her to lose weight. was aware that Epstein was similarly controlling of Epstein also controlled whe t re lived, as she travelled with him wherever he went and was required to be on call 24/7. so recalled that Epstein and Maxwell had sign a healthcare proxy assigning them responsibility if anything happened to her. was also required to sign a confidentiality agreement. recalled three instances during which Epstein directed to engage in sexual activity while another woman was present. First, shortly after she took the job, was directed by Maxwell and Epstein to engage in sexual contact with them at Epstein's Virgin Islands residence. does not remember how this incident began or ended, but she remembers Maxwell being naked in the bedroom with her and Epstein and directing- regarding how to sexually touch E stein. Second, in or around-, Epstein directed and a woman named 51 who was in her 20s, to engage in sexual contact with each other and with him at his Virgin Islands residence. Third, in or around Epstein directed and a woman named who was in college, to engage in sexual contact with each other and him at his New York residence. The most violent form of sexual abuse experienced occurred when she and Epstein were alone in the gym at Epstein's Palm Beach residence. While was doing sit- ups, Epstein closed the blinds to the windows and then roughly pulled pants down and aggressively raped her. That is the only time her. recalled Epstein having intercourse with did not tell Maxwell about the other incidents of sexual contact with Epstein because she was afraid Maxwell would become angry and that would lose her job. understood that Maxwell was Epstein's girlfriend and that she viewed the other girls Epstein had sex with as trash that should be quickly disposed of. did not want Maxwell to think of her that way. She recalled, though, one instance on Epstein's birthday in or around 2002 at Epstein's Virgin Islands residence when Maxwell directed and other young women to get naked, wrap themselves in saran wrap and take photographs while posing around Epstein as he sat on a massage table. Maxwell also directed and the other young women to put paint on their breasts and press them on a canvass to give to Epstein as a birthday present. also recalled a time when Maxwell discussed techniques for giving oral sex in presence. does not know, though, whether Maxwell engaged in any sexual contact with any other women. 51 The FBI has not yet identified this individual. 54 EFTA_00022514 EFTA02731135 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) After Epstein came out of jail, responsibilities increased as she stepped into the role that Maxwell previously held running all of his homes. did not recall scheduling massa es for E s stein an ore after he came back from 'ail. separated from Epstein in 2012 . At first tried to restructure her job responsibilities so that she would not have to travel so much with Epstein, but Epstein rejected that plan and encoura ed to leave her position and move in with her husbanc, the time she got married there, was managing was no longer Epstein's employee. From was ashamed of the sexual abuse she experienced and did not tell anyone about it for years. including her husband. The first people disclosed this abuse to were the attorneys who currently represent her. Because her husband did not know about Epstein's sexual abuse, he viewed Epstein as father-figure and encouraged her to remain in touch with him after they were married. At the end of the interview, said that she wished she could tell the victims that she would never knowingly facilitate their abuse. She emphasized that she would not knowingly help put someone through what she went through. E. Interview of On September 9, 2019. we interviewed in New York. . During this interview, we discussed with the process of her recruitment and her interactions with Maxwell. We also discussed at a high level her allegations that she was "lent out" to other individuals by Epstein to engage in sex acts with them.' At the be i of the interview. hasized that When asked to describe how she first came into contact with Epstein, referenced what she called her "training period" with Epstein and Maxwell, which began in or around also indicated that she previously believed she was 15 when she first met Maxwell, but the "records" showed that she was in fact 16 years old. She explained that she met Maxwell at Mar-a-Lago, and where Maxwell recruited her to come to Epstein's Palm Beach residence to massage Epstein. At the residence, Maxwell and Epstein both interviewed and then began " As described in more detail below, we have been unable to corroborate . haccounts of being "lent our' to other men for sex. We have, however, been able to corro rate er account of being recruited by Maxwell, being sexually abused by Epstein, and recruiting other minor girls to provide paid sexualized massages to Epstein at his Palm Beach residence. 55 EFTA_00022515 EFTA02731136 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) massaging Epstein. During the massage, Epstein and Maxwell asked questions about her background and difficult family life, and she told them truthfully how old she was. Epstein and Maxwell then directed to take off her clothes, and the massage became sexual. During what refers to as her "training period," Maxwell and Epstein taught about how to engage in sex acts. For example, Maxwell and Epstein taught how to perform oral sex and how to engage in anal stimulation. During this same period, also recalls many conversations during which Maxwell and Epstein would tell to look for and recruit young females. They directed to find young females who looked like the girl next door. explicitly remembered Epstein saying the "younger the better" and that he did not want "black girls." understood that these recruits would give paid sexualized massages to Epstein at his Palm Beach residence. Maxwell taught how to recruit younger girls for Epstein by taking on shopping trips, during which Maxwell would demonstrate how to recruit girls and would make practice doing so. Maxwell taught to recruit young girls by saying, "I know this really nice guy who likes to help people out," adding "you can make some money," and noting that the man could help the girl with her education or being a model. Maxwell criticized for being "bad" at recruiting girls and would show how easily Maxwell could recruit girls. followed these instructions and told the girls she recruited that they would have to give massages, but not normal massages. When girls agreed to the proposition, would exchange numbers with them. would then describe the girl to Epstein, who would decide whether he wanted to meet with them. If the girl was acceptable, then Maxwell would schedule the girl to come to the Palm Beach residence at a particular date and time. recalledgetting in trouble for not bringing enough girls and for not bringing the "right" girls for Epstein. was usually paid $200 for each girl she brought. If Epstein liked a girl brought in, he would give her $300 as an extra incentive. Usually Epstein paid but sometimes he told her to get money from Juan Alessi. Epstein would occasionally take the phone number of a girl himself after a massage if he liked her. vividly recalled a conversation with Maxwell and during which they were all smoking cigarettes inside Epstein's Palm Beach residence. During this conversation, asked Maxwell how she handled Epstein being with so many girls. Maxwell responded that it took the "pressure off" Maxwell having "to do it." added that the more girls they recruited the less they would "have to do" themselves. understood that Epstein had a sex addiction. When recruited girls, she would have them meet her at her home, and then she would get a ride. Sometimes would give her rides, and sometimes Juan Alessi would give her rides. Upon arriving at Epstein's Palm Beach residence, either Juan Alessi, Maria Alessi, Maxwell, or would answer the door. would then bring the girl up 56 EFTA_00022516 EFTA02731137 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) to the massage room and would stay in the room for the massage with them. did not recall recruiting anyone in New York and believes she only recruited girls in Florida. In total, believe that she brought no more than 20 girls to Epstein. She expressed sincere remorse for having recruited girls to be abused by Epstein. described herself as subservient durin her with Epstein and recalled quitting her Job at Epstein's direction. said that she initially believed she started travelling with Epstein about six months after her "training period," but upon reviewing Mar-a-Lago records and flight records, she realized she took her first trip with Epstein only three months after being recruited. recalled travelling very frequently, either weekly or every other week, with Epstein. When she travelled to New York, she would stay in an apartment in Epstein's building on 66th Street. During one such trip. left for a walk and was gone for a few hours, after which Maxwell and Epstein were angry that she had not stayed in the a artment and waited for them to contact her. In response to that incident, Maxwell bought a cellphone and told to stay in Epstein's New York residence and only leave when Epstein directed her to go to a sex store or go recruit girls though, as mentioned above, never successfully recruited any girls in New York). never slept over in Epstein's Palm Beach residence, but she recalled that eventually Epstein gave her money to pay for her own apartment in Florida, which enabled her to move out of her parents' home. Durin herperiod travelling with Epstein, spend most of her time with Epstein, Maxwell, and When that group spent time watching television or movies together. Maxwell would sometimes initiate sexual contact by taking off her clothes and telling to give her oral sex. Maxwell would also involve in the sexual contact, all while Epstein was present. On one such occasion, Maxwell used a sex toy on in a way that was physically painful to As spent more time with E stem, though. Maxwell became less directly involved in sexual contact. At some point, began using drugs so heavily that Epstein said he did not want her around anymore. She still maintained some contact with him, though. and when she turned 19 Epstein and Maxwell paid for to travel to for massage therapy school. % also mentioned someone named who was who was also good at recruiting girls. She also said that someone named would recruit girls for Epstein. initially described claimed that she had personally watched recruit girls, but she did not provide additional details. recalled meeting after her "training" was complete and she had already "proven" herself. Shortly before that first meeting. Epstein described as one of his "favorites." Epstein then brought to house in , where " The FBI has not yet identified this individual. as a "mastermind" at finding girls. first 57 EFTA_00022517 EFTA02731138 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) . Epstein, and all engaged in sexual contact with each other. recalled that already knew exactly what to do and what Epstein liked sexually. recalled Epstein saying that other than Maxwell, was the best for picking up girls. When asked to describe specific instances in which personally observed recruit someone, El said she did not recall actually seeing recruiting anyone, and added that she and did not really get along, and did not see her much. When asked whether- had other sexual experiences with she said there were "tons" and "too many to count." generally described Maxwell and Epstein directing her to engage in sex acts with other men. Although we did not delve into the details of this topic, volunteered some information about it, used the term "lent out" to describe instances in which Maxwell or Epstein directed her to have sexual contact with other men. Her first memory of being "lent out" was after Epstein paid for her to get an apartment in Florida and after Maxwell had gotten her a cellphone. One day, Maxwell told to massage Glen and Eva Dubin and explicitly told that she had to do to Glen what did for Epstein, which understood to mean engage in sex acts. added that at some point, Maxwell and Epstein told that they were going to "test me out" with other people, which she needed to do in order to be a "real" massage therapist. With respect to Prince Andrew,' recalled that Maxwell told that she was going to meet a prince and should make him happy and do the exact same things for him that she did for Epstein because the prince was a good friend of Maxwell's. explained that she was "lent out" so many times that she began using drugs, and she cannot estimate how many times she was "lent out" to other people. She recalls being "lent out" to some people multiple times, and some people just once. Sometimes Maxwell would direct to engage in sex acts with other men, and sometimes Epstein would do so. When in New York, either Maxwell or Epstein would call to the massage room and direct her to engage in sex with a man there. said that she was never paid by any of these other men for the sexualized massages she provided. does not recall any conversations about money taking place in front of any of the men to whom she was "lent out." also mentioned Alan Dershowitz, but we did not fully explore the details of her interactions with him. When asked whether she was aware of any other girls who were "lent out" like she said that was a participant in sex acts with "lots" of third parties. She also said that was "lent out" and that and were "lent out" together.' 54 We are in the process of obtaining the name of a lawyer who represents Prince Andrew. Once we have this contact information, we plan to request an interview. 55 This is inconsistent with account. does not recall ever being told to have sex with any men other than Epstein. This is also inconsistent with account. described being sexually abused by Epstein, but she did not describe ever being told to have sex with any men other than Epstein. 58 EFTA_00022518 EFTA02731139 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) also recalled being "lent our with a woman named and with- added that there were more girls whose names she could not think of at the time. noted that came into the picture toward the end of time with Epstein, so she did not know much about her. account of being recruited by Maxwell, abused by Maxwell and Epstein, engaging in paid sexualized massages with Epstein as a minor, recruiting other minors to engage in paid sexualized massages with Epstein, and travelling to other locations with Epstein are all consistent with other evidence and corroborated, in significant part, by employment records at Mar-a-Lego, fli t records for Epstein's private jet, and other witnesses. In particular. Juan Alessi confirms that frequently visited Epstein's Palm Beach residence to provide Epstein with masse es and often brought other your irls to the residence to massage Epstein. Alessi knew that was a minor and knew that travelled with Epstein. In addition, Maria Alessi and both recalled seeing with Epstein. Moreover, her account of theseiiiences remarkabimisistent with the experiences of other victim-recruiters. such as and number of the men has publicly identified as people to whom she was "lent out" have vociferously denied her allegations. No other victim has described being expressly directed b either Maxwell or Epstein to engage in sexual activitsithinither men. and recalled E stein asking her to massage Harve directed to remove her shirt. When not ask her to massage any other men again. Leon Black and Jes Staley, both of whom engaged in sexual contact with her against her will during the massages. Moreover, according to when she complained to Epstein about the sexual contact, he laughed and told that it was up to her whether to engage in sex during those massages. Weinstein and that during the massage Weinstein refused and left, Epstein apologized and did recalled Epstein asking her to massage I " The FBI has not yet identified this individual. 59 EFTA_00022519 EFTA02731140 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) In the memoir, described a number of incidents that she has since admitted did not in fact wrotairtially fictionalized account of her experienced with Epstein and Maxwell. In take place. These include descriptions of a sexual encounter with a Nobel Prize winning scientist and a scene in which is caught with cocaine in her room and fired. The memoir also mentions Alan Dershowitz, but does not claim that engaged in sex acts with him. She did not raise those claims until 2014. Also in when was still writing her memoir, she exchanged emails with Sharon Churcher, a reporter for the Mail on Sunday. In one email.Misked Churcher to help her put together a list of Epstein's well-known associates so that could include them in her memoir. In response. Churcher wrote, "Don't forget Alan Dershowitz. JE's buddy and lawyer. Good name for your pitch... We all suspect Alan is a pedo and tho no proof of that, you probably met him when he was hanging with JE." As for well as account of her interactions with Prince Andrew a photograph of= with Prince Andrew and Maxwell. as recollection that Maxwell also introduced her to Prince Andrew. Prince Andrew. who has publicly denied the allegations we asked whether she recalled any other females who ma have been present with her during these sexual interactions. In response, said that and more girls whose names should could not recall, had all participated with sexual encounters with other men at the direction of either Epstein or Maxwell. However, and have very different memories. who as noted above, did recall meeting on one occasion, did not recall Epstein or Maxwell ever asking her to have sex with any other men. Nor did she recall ever being present when engaged in sex acts with other men. Similarly, although described numerous instances of sexual abuse, she did not describe ever being directed by Epstein or Maxwell to engage in sex acts with another man. She, too, did not recall ever being present when engaged in sex acts with other men. also described visiting residence in and engaging in sexual activity with and Epstein there. However, we have been unable to gather any evidence to 60 EFTA 00022520 EFTA02731141 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) suggest that ever resided in Rather, the information provided by other witnesses and corroborated by travel records, suggests that resided in Epstein's building on 66th Street in New York and otherwise travelled with Epstein wherever he went. Of particular si cance in evaluatin account of_ participation in sexual abuse, description o conduct was internally inconsistent within our single interview with her. At first, stated that was a "mastermind" recruiter and said that she had personally witnessed recruit minor girls to engage in paid sexualized massages with E stein. When asked to describe specific instances in which she observed- recruiting girls, said that she had never seen recruit anyone and had not actually spent much time with By contrast, when asked whether she recalled any other instances in which was present for sexual activity._ said there were "tons" and "too many to count." Additionally, in or around 2016, was deposed admitted to lying about her employment history on her resume, admitted to burning handwritten notes that she had made about her experiences with Epstein and Maxwell, and admitted that she inaccurately told a reporter that she was abused by Epstein for four years when she was only with him for about two years. She also confirmed that she was paid a total of nearly $200,000 for the statements and photo of Prince Andrew that she provided to Sharon Churcher, and she admitted to exchanging emails with Churcher about how "big headlines" would help sell her memoir. also admitted that she had previously claimed that the FBI told her they were aware of 40 other Epstein victims, when in fact the FBI never told her how many victims they had identified. She further claimed that the FBI told her that Epstein had cameras watching her at all times, including while in the bathroom (we are not aware of any such cameras). At one point during her deposition, became particularly combative when pressed to describe in detail any specific times she recalled when Maxwell directed her to have sex with another person. Eventually, cursed in her response, saying, "She's the one who brought me to be trafficked by Jeffrey Epstein in the flicking first place." Substantially all of the individuals accused by of engaging in misconduct have publicly denied the allegations. These denials include public statements made by Dershowitz and Prince Andrew, who both deny engaging in any sexual contact with And as noted below, Maxwell, through counsel, has similarly disputed substantial aspects o account. Finally, has engaged in a continuous stream of public interviews about her allegations, many of which have included sensationalized if not demonstrably inaccurate characterizations of her experiences. The most recent example arose this month when publicly claimed that the FBI had warned her of a "credible" death threat. In fact, both the FBI and our Office have repeatedly told that there are no credible threats to her safety. 61 EFTA_00022521 EFTA02731142 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Nevertheless, has stated both publicly and during a meeting of victims at the FBI's New York office that the FBI has identified a credible threat against her. F. Additional Investigative Steps In addition to conducting numerous witness interviews, we have met with attorneys for other subjects of the investigation, executed search warrants, reviewed financial records, and reviewed numerous documents in an effort to evaluate and corroborate witness accounts. 1. Attorney Meetings a. Counsel for Ghislaine Maxwell On October 8, 2019, Maxwell's attorneys provided us with an attorney proffer. During the meeting. her attorneys described Maxwell's background and upbringing. She was born in France in 1961 and raised in Paris. In the early 1990s, she began traveling to the United States more often as her father expanded his business there, and she met Epstein through a friend of her father's while in the United States. In 1991, he father died, and his company collapsed, leaving Maxwell with limited financial resources. Epstein supported Maxwell both emotionally and financially after her father's death, and they began a romantic relationship in 1992. Early on in the relationship, Epstein was very secretive and kept Maxwell in the dark about other parts of his life, including other girlfriends he had. During the earlier period of their relationship. Maxwell was not allowed to look at Epstein's message sheets or answer his phones. By around the mid-1990s. Maxwell only saw Epstein about half the days in any given month, and they were physically intimate less often. Around that same time, Maxwell began managing Epstein's properties. Epstein paid Maxwell a salary. and she would give him weekly its regarding his various properties. In 1996, they hired Kimberly Galindo57 and as assistants to help with Maxwell's management responsibilities. By the late 1990s. Maxwell wanted to many and have a child with Epstein. Although Epstein refused to many her, he told Maxwell that he would have a child with her, which was why Maxwell decided to stay with him. 57 The FBI has not yet identified this individual. 62 EFTA_00022522 EFTA02731143 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Around the late 1990s, Epstein began using testosterone patches, which made him more aggressive. Their relationship began to deteriorate, and Maxwell stopped sleeping in the same room as Epstein. In or around 1999 or 2000, Maxwell stopped having sex with Epstein. At that time, Epstein was dating a woman named-. 513 In or around Maxwell ended her romantic relationship with Epstein and began dating other men. Around the same time, Maxwell met in Hawaii and ended up hiring her to be Maxwell's personal assistant to replace Shortly after was hired, though, Epstein made clear that would be his assistant instead. Maxwell trained regarding how to manage Epstein's houses, and eventually took over Maxwell's responsibilities. Between about 2001 and 2003, Maxwell continued travelling with Epstein, even though they fought frequently, because Epstein wanted her to continue managing his properties. It was during this period that Maxwell met Maxwell does not recall meeting and she primarily recalls speaking with Leslie Groff on the phone. In 2003, Maxwell began a long-term relationship with Ted Wight, and she remained in a committed relationship with him until 2010. As a result of that relationship, Maxwell spent less and less time with Epstein. She was not present in 2005 when the Palm Beach Police Department searched Epstein's Palm Beach residence, and she was not contacted or interviewed during that investigation. Maxwell understood that Epstein pled guilty to having sex with an "underage prostitute," and she did not visit him in jail. Throughout their relationship, Epstein asked Maxwell to connect him with massage therapists, but she insists that she only hired adults for that role. She recalled Epstein getting one massage per day, and she believed that the massages were not sexual in nature. Maxwell did engage in sex acts with Epstein and other adult women, but she denies ever doing so with minors. Maxwell categorically denies any involvement in recruiting minors for sex with Epstein. Maxwell's attorneys claimed that she has a medical condition making some of the public allegations regarding certain sex acts involving Maxwell physically impossible. They did not provide any additional details regarding the nature of the condition or which acts it impacted. They added that she could be intimate with Epstein, but not every day because of this condition. At the conclusion of the proffer, Maxwell's attorneys walked through the public allegations against their client and explained their views of why the individuals making those claims were not credible. In doing so, they emphasized that Maxwell had not invoked her Fifth Amendment privilege against self-incrimination when she was deposed as a part of lawsuit.59 Although they discussed several witnesses during this portion of the ss The FBI has not yet identified this individual. " We have reviewed the transcripts of Maxwell's two-part deposition in 2016, which was taken in connection with defamation suit against Maxwell. During the deposition, Maxwell admitted to being in a romantic relationship with Epstein from the early 1990s through 63 EFTA_00022523 EFTA02731144 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) meeting. they primarily focused on three victims: and First, they highlighted a number of inconsistencies within account, including prior accounts of abuse that has since admitted to fabricating in her memoir. They also pointed out that account of being forced to have sex with other men differs dramatically from that of other victims of Epstein's abuse. Second, they noted that was an adult when she met Epstein and that she had admitted to lying and saying that she had video evidence of her abuse, when she did not. Finally, they noted that flight lo show that Maxwell was "never" in New Mexico in , which is when says Maxwell engaged in inappropriate behavior with her. Maxwell denies allegations. b. Counsel for Leslie Groff Leslie Groff worked as Epstein's primary New York-based assistant from at least in or about 2001 through the summer of 2019. Her responsibilities included, among other things, scheduling Epstein's massages at the New York residence. Generally, Groff would call victims to schedule massage appointments, but she had limited interactions with the victims beyond scheduling. In addition to scheduling massage appointments, Groff would also book flights for girls who travelled to meet Epstein at his various residences. Groff made these arrangements by phone from the New York office where she worked for Epstein. She spent little time in Epstein's residence and thus had few in-person interactions with victims. in or around 2000. She also described acting as his employee and being tasked with running his various properties. She claimed to have spent very little time with Epstein in the 2000s. Throughout the deposition. Maxwell took virtually every opportunity she could to call'. a liar and to accuse both and her attorneys of feeding "vicious lies" to the press. e denied any awareness that any minors other than ever massaged Epstein, and she denied any knowledge of any sexual contact between Epstein and any minors. She also denied knowing that Epstein engaged in sexual activity durin the course of massages. Maxwell admitted during herd eposition to meeting both and but denied any awareness that Epstein had sexual contact with t em. S e claim not to reca 1 age and claimed that she only saw at Epstein's Palm Beach residence and that was with her mother on all of those visits. Maxwell also claimed that she had never given anyone. including Epstein, a massage, though she admitted to showing people where "pressure points" are located on a hand and foot. She denied ever showing anyone how to massage Epstein. She also denied ever having sexual contact with- 60 It is true that the flight lo s for Epstein's private jet do not show Maxwell flying on his plane to New Mexico in ; however, it is still possible that Maxwell took a commercial flight to New Mexico. Given e passage of time, it has not been possible to obtain records of such travel. In any event, Maxwell admitted during her 2016 deposition that she met at Epstein's New Mexico residence. Although that admission does not inc. te, s e has admitted under oath to meeting 64 EFTA_00022524 EFTA02731145 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) On July 18, 2019, we gave a reverse proffer to Leslie Groff, during which we explained that numerous victims had indicated that she was responsible for scheduling massages during which they were sexually abused. We encouraged Groff to meet with us for a proffer so that she could share her story and explain her role. Subsequently, on August 7, 2019, we had a phone call with Groff's attorney during which he indicated that he would not bring Groff in for a proffer and had advised her to invoke her Fifth Amendment privilege against self-incrimination if she is subpoenaed to testify. In recent weeks, we have reached back out to Groff's attorney to convey that we will not be able to provide her with any sort of agreement if she does not proffer with us. He appeared to understand our position and is considering whether to bring Groff in for a proffer. c. Counsel for Jean Luc Brunel In August and September of 2019, we had multiple phone calls with an attorney for Jean Luc Brunel. On our last call, the attorney indicated that Brunel was not willing to meet with us for a proffer and would invoke his Fifth Amendment privilege against self-incrimination if subpoenaed to testify in the grand jury. d. Counsel for Leslie Wexner On July 25, 2019, counsel for Wexner provided us with an attorney proffer. Wexner is the billionaire founder and CEO of L Brands (formerly Limited Brands) corporation, which controls Victoria's Secret, among other retail brands. It has been publicly reported that Wexner and Epstein had a close relationship and that Epstein managed Wexner's finances from the 1990s through the 2000s. During our meeting, Wexner's attorneys indicated that Wexner had no knowledge of any inappropriate or unlawful activity with young women by Epstein. The attorneys emphasized Wexner's relationship with Epstein was more professional than social. The attorneys also explained that over his years handling Wexner's finances, Epstein stole or otherwise misappropriated several hundred million dollars from Wexner. That misconduct, together with fees that Epstein paid himself for his services to Wexner, appears to account for virtually all of Epstein's wealth. Wexner first met Epstein in the 1980s through a mutual friend who recommended Epstein as a financial adviser. After a couple other acquaintances recommended Epstein as well, Wexner brought Epstein on to help with his investments. Over time, Epstein became more involved in Wexner's finances until Epstein controlled all of Wexner's personal finances with virtually no oversight. In 1991, Epstein obtained a power of attorney from Wexner, which enabled Epstein to handle the purchase and sale of real estate and other assets on Wexner's behalf. At some point in 1998, Epstein sold himself the New York residence in which he resided until his arrest in 2019 at a deeply discounted price. The New York residence had previously 65 EFTA_00022525 EFTA02731146 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) belonged to Wexner, but the Wexners had moved out of it in 1995. Epstein also sold himself a private plane that previously belonged to Wexner at a deeply discounted price. In the 1990s, Epstein told Wexner that he had other clients and that Wexner did not need to pay Epstein because Epstein was having fun and they would settle up later. Epstein introduced Wexner to a number of other people as his clients, and Wexner interacted with other prominent people who knew Epstein, such as Prince Andrew, professors at Harvard, and a sultan in Dubai. Epstein had no formal role in L Brands or Victoria's Secret. At some point, Wexner heard a rumor that Epstein might be holding himself out as connected to Victoria's Secret, but when Wexner asked Epstein about it, Epstein denied doing so. Epstein handled Wexner's personal business affairs until 2007, when Wexner learned that Epstein had stolen or otherwise misappropriated several hundred million dollars from Wexner. Around that time, Epstein told Wexner that he was having legal problems involving an overly aggressive police chief and some sort of massage. Epstein said he was being blackmailed and it could get messy, so it would be best for Wexner's wife to take over the family finances. In response, Wexner's wife looked into the state of their finances and discovered that Epstein had misappropriated a significant amount of the family's funds. For example, Epstein frequently bought property on behalf of the Wexners and then sold it to himself for a fraction of the cost. The Wexners then decided to cut off Epstein. When confronted, Epstein tried to convince Wexner's wife that she did not understand the financials and insisted that he had the Wexners' best interests at heart. The Wexners did not want to bring unnecessary public attention to the issue, so they withdrew the power of attorney, and hired counsel to negotiate a private settlement with Epstein. As a result of those negotiations, Epstein agreed to return $100 million to the Wexners, which he did in January of 2008. At that point, Wexner severed all ties with Epstein, and he has not seen or spoken to Epstein since. Wexner knows nothing about the claim from and explained that at the time, Epstein owned a property adjacent to the Wexners about a half mile way from the Wexners's property. The Wexners's security team is not aware of any inappropriate incident taking place on the Wexners's property, and the Wexners first heard about allegations from public reporting this year. 2. Search Warrants In July and August 2019, we obtained and the FBI executed search warrants for Epstein's residences in New York and the Virgin Islands. We subsequently obtained warrants to search all electronic devices, drives, and discs seized from those residences. The FBI is continuing to review the extraordinarily large amount of data contained on those devices and is working with our filter team to complete a privilege review of that data. In addition, we have reviewed the materials obtained during the Palm Beach Police Department's October 2005 search of Epstein's Palm Beach residence. 66 EFTA_00022526 EFTA02731147 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Based on our review of these materials thus far, we have identified some victims who appear in photographs maintained in Epstein's residences. Of particular note, we have identified photographs of and at Epstein's residences. It bears noting that, contrary to some news reports, these searches did not reveal any cameras in any of the bedrooms or massage rooms. 3. Financial Records Together with the FBI, we have reviewed a number of financial documents regarding Epstein's, Maxwell's, and finances. We have also been in touch for counsel representing JP Morgan, Deutsche Bank, and TD Bank, each of which have held accounts related to Epstein or his associates. Epstein held the bulk of his finances at JP Morgan from the early 2000s until 2013, when he opened multiple accounts at Deutsche Bank and transferred his funds from JP Morgan to Deutsche Bank. In 2019, Deutsche Bank closed Epstein's accounts, and his funds from those accounts were primarily transferred to the Bank of Puerto Rico. Epstein's accounts appeared to be exclusively for the purpose of holding his own money. His Deutsche Bank accounts included checking accounts, money market accounts, and brokerage accounts for his charities, his consulting company Southern Trust Company, Inc., and several trusts, most of which appear to have been established to handle payments for Epstein's various expenses in connection with his properties and planes. We have not identified any accounts that are consistent with Epstein handling or investing other people's money. Additionally, in the fall of 2019, counsel for TD Bank reached out and informed us that several individuals and entities associated with Epstein held accounts at TD Bank, including accounts held by Epstein was not a signatory on any of the accounts, and TD Bank is in the process of closing all of the accounts. On September 12, 2019, we met for several hours with counsel for Deutsche Bank, which held the majority of Epstein's finances from 2013 through 2019. Their presentation was extremely thorough, including a 50-page summary of their analysis. The presentation broke down Epstein's finances into a number of useful categories, including listing various types of transactions by type and recipient. At a high level, there was no immediate indication of financial criminal activity or misconduct, including based on our analysis and the internal investigation that continues to be in progress at Deutsche. Additionally, as referenced above, there do not appear to be any signs that Epstein was trading on behalf of any clients in Deutsche accounts during the period when he was a client, between 2013 and 2019. 67 EFTA_00022527 EFTA02731148 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) We are continuing to receive additional documents from JP Morgan.61 and the FBI is continuing to review financial records for any evidence of potential misconduct or potential obstruction. 4. Additional Document Review Finally, as we have met with new witnesses, we have re-evaluated documents and records obtained pre-indictment for any corroborating information of new victim accounts. In particular, we have found numerous message pads featuring the names of victims who have spoken with us, which were found either in trash pulls or during the search of Epstein's Palm Beach residence during the 2005 Florida investigation. Additionally, we have identified some flight logs within the records obtained from one of Epstein's pilots that reflect instances during which certain victims flew on Epstein's private jet. III. Legal Landscape We have considered the applicability of three different criminal charges to the conduct revealed during the course of our investigation. This section walks through the elements and basic contours of each statute and summarizes the applicable statutes of limitations. A. Sex Trafficking of Minors In the original Indictment, we charged Epstein with sex trafficking of minors, in violation of Title 18, United States Code, Section 1591. This statute has the following elements: (1) That the defendant knowingly recruited, enticed, harbored, transported, provided, or obtained by any means a person, or aided and abetted the same; (2) In or affecting commerce: (3) Knowing the fact that the victim had not yet attained the age of 18 years old; (4) Knowing the victim would be caused to engage in a commercial sex act; and (5) That venue is proper in the Southern District of New York. 61 These productions include messages exchanged between Jes Staley and Epstein around the period when recalled being d by Staley during e at Epstein's New York residence. 68 EFTA 00022528 EFTA02731149 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 69 EFTA 00022529 EFTA02731150 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) I•1 70 EFTA_00022530 EFTA02731151 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) B. Transportation of Minors Title 18, United States Code, Section 2423 makes it a crime to transport minors with the intent to engage in criminal sexual activity. That crime has the following elements: (I) That the defendant knowingly transported a victim, or aided and abetted the same; (2) Across state lines; (3) At the time of the transportation, the victim was less than 18 years old; (4) The defendant transported the victim with the intent that the victim engage in "sexual activity for which any person can be charged with a criminal offense;" and (5) That venue is proper in the Southern District of New York. Title 18, United States Code, Section 2423(a) provides: A person who knowingly transports any individual under the age of 18 years in interstate or foreign commerce, or in any Territory or Possession of the United States, with intent that such individual engage in prostitution, or in any sexual 71 EFTA_00022531 EFTA02731152 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) activity for which any person can be charged with a criminal offense, shall be fined under this title or imprisoned not more than ten years, or both. "To secure a conviction under § 2423(a), the government ... must prove beyond a reasonable doubt that the defendant: (1) knowingly transported a minor across state lines and (2) with the intent that the minor engage in sexual activity for which some person could be criminally charged." United States v. Vargas-Cordon, 733 F.3d 366, 375 (2d Cir. 2013). 72 EFTA 00022532 EFTA02731153 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) C. Enticement of Minors We have also considered Title IS, United States Code, Section 2422(b), which makes it a crime to entice a minor to engage in illegal sexual activity. The enticement statute was enacted in February 1996, and the version of the statute in effect at that time provided: "Whoever, using any facility or means of interstate or foreign commerce, including the mail, or within the special maritime and territorial jurisdiction of the United States, knowingly persuades, induces, entices, or coerces any individual who has not attained the age of 18 years to engage in prostitution or any sexual act for which any person may be criminally prosecuted, or attempts to do so, shall be fined under this title or imprisoned not more than 10 years, or both." To prove a violation of the enticement statute, the Government must prove four elements: "that an individual (i) used a facility of interstate commerce; (ii) to knowingly persuade, induce or entice, or to attempt to persuade, induce or entice; (iii) any individual who is younger than eighteen-years old; (iv) to engage in sexual activity of a criminal nature." United States v. Brand, 467 F.3d 179, 201-02 (2d Cir. 2006). D. Statute of Limitations The conduct revealed during our investigation spanned from approximately 1994 through approximately 2005. " As discussed below, we anticipate recommending transportation of minors charges against Maxwell and will prepare a separate prosecution memorandum regarding those charges. That prosecution memo will detail the applicable state statutes for the conduct relevant to the proposed charges against Maxwell. 73 EFTA_00022533 EFTA02731154 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 74 EFTA_00022534 EFTA02731155 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) IV. Analysis In light of the evidence gathered during our investigation, as well as the tools available, in this section, we evaluate whether there is sufficient evidence to charge 69 The term "sexual abuse" is defined as including "the employment, use, persuasion, inducement, or coercion of a child to engage in, or assist or another person to engage in, sexually explicit conduct or the rape. molestation, prostitution, or other form of sexual exploitation of children, or incest with children." 18 U.S.C. § 3509(8). The term "sexually explicit conduct" means "actual or simulated (A) sexual intercourse [. ..] (C) masturbation: [or] (D) lascivious exhibition of the genitals or pubic area of a person[.]" 75 EFTA 00022535 EFTA02731156 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Leslie Groff and/or Ghislaine Maxwell with a federal crime and, if so. whether such charges would be in the interests of justice. A. I. Evidence That Conspired to Sex Traffic Minors 76 EFTA_00022536 EFTA02731157 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) a. Knowledge of Sex Acts 77 EFTA 00022537 EFTA02731158 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 78 EFTA 00022538 EFTA02731159 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) b. Knowledge of Age 79 EFTA 00022539 EFTA02731160 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 80 EFTA_00022540 EFTA02731161 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 81 EFTA_00022541 EFTA02731162 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 82 EFTA 00022542 EFTA02731163 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 83 EFTA_00022543 EFTA02731164 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) B. • 84 =_00022544 EFTA02731165 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 85 EFTA_00022545 EFTA02731166 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) D. Leslie Groff E. Ghislaine Maxwell 86 EFTA_00022546 EFTA02731167