EFTA00194923.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 18 U.S.C. § 371 18 U.S.C. § 1591(a)(1) 18 U.S.C. § 1591(a)(2) 18 U.S.C. § 2422(10 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 2423(10 UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, 9! a/k/a and Defendants. INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defendant JEFFREY EPSTEIN employed defendants - a/k/a " and to perform, among other things, services as personal assistants. 1. Defendants JEFFREY EPSTEIN and paid T.M., H.R., and A.F. to perform, among other things, recruiting services. 2. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 3. Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a Delaware corporation. JEGE, INC.'s sole business activities related to the operation and ownership of a Boeing 727-31 aircraft bearing tail number N908JE. 4. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 5. Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. EFTA00194923  6. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 7. Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older who engages in sexual activity with a person 16 or 17 years of age commits a felony of the second degree." For purposes of "this section, `sexual activity' means oral, anal, or vaginal penetration by, or union with, the sexual organ of another; however, sexual activity does not include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide belief that such person is over the specified age [shall] be a defense." 8. Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult "who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious molestation," which is a felony of the second degree if the victim is 12 years of age or older but less than 16 years of age. 9. Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who [i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or lascivious conduct," which is a felony of the second degree. 10. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who: (1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual physical or sexual contact with the victim, including, but not limited to . . . the simulation of any act involving sexual activity in the presence of a victim who is less than 16 years of age, commits lewd or lascivious exhibition," which is a felony of the second degree. 11. Pursuant to Florida Statutes Section 800.04(2), "[n]either the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]." 12. Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide belief of the victim's age cannot be raised as a defense in a prosecution under [Section 800.04]." EFTA00194924 13. Pursuant to Florida Statutes Section 800.02, a "person who commits any unnatural and lascivious act with another person commits a misdemeanor of the second degree." 14. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical license. 15. During the period of her involvement with the Defendants, Jane Doe #4 attended Wellington High School and Palm Beach Central High School in Palm Beach County. 16. During the period of her involvement with the Defendants, Jane Doe #5 attended Wellington High School in Palm Beach County. 17. During the period of their involvement with the Defendants, Jane Does # 6, 8, and 12 attended Palm Beach Central High School in Palm Beach County. 18. During the period of her involvement with the Defendants, Jane Doe #7 attended William T. Dwyer High School in Palm Beach County. 19. During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 17, 18, and 19 attended Royal Palm Beach High School in Palm Beach County. 20. During the period of her involvement with the Defendants, Jane Doe #10 attended Lake Worth High School in Palm Beach County. 21. During the period of her involvement with the Defendants, Jane Doe #11 attended Jeaga Middle School in Palm Beach County. 22. During the period of her involvement with the Defendants, Jane Doe #13 attended John I. Leonard High School in Palm Beach County. COUNT 1 (Conspiracy: 18 U.S.C. § 371) 1. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 2. From at least as early as 2001, the exact date being unknown to the Grand Jury, through in or around October 2005, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendants, JEFFREY EPSTEIN, II a/k/a ' and EFTA00194925 did knowingly and willfully combine, conspire, confederate, and agree with each other and with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, and entice individuals who had not attained the age of 18 years to engage in prostitution, in violation of Title 18, United States Code, Section 2422(b). Purpose and Object of the Conspiracy 1. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN's prurient interests. Manner and Means 1. The manner and means by which the Defendants and other participants sought to accomplish the purpose and object of the conspiracy included the following: (a) It was part of the conspiracy that Defendants a/k/a and other participants would contact minor females via the use of cellular and other telephones to arrange appointments for minor females to travel to 358 El Brillo Way to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. (b) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, and other participants would make payments to, or cause payments to be made to, minor females in exchange for engaging in lewd conduct. (c) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, a/k/a and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (d) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, a/k/a " I," and other participants would make payments to, or cause payments to be made to, the recruiters for bringing additional minor females to 358 El Brillo Way to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (e) It was further a part of the conspiracy that Defendant JEFFREY EPSTEIN would pay minor females to engage in lewd conduct with Defendant to satisfy Defendant JEFFREY EPSTEIN's prurient interests. EFTA00194926  Overt Acts 1. In furtherance of this conspiracy and to effect the objects thereof, there was committed, by at least one of the co-conspirators herein, at least one of the following overt acts, among others, in the Southern District of Florida, and elsewhere: Jane Does #1 and #2 1. In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity with Jane Doe #1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. 2. In or around 2001, Defendant led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. 3. In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a fourteen-year-old girl. 4. In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, who was then a fourteen-years-old girl, to pinch his nipples while he masturbated. 5. In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. 6. In or around 2001, Defendant placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. 7. In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse with an unidentified female in the presence of Jane Doe #2, who was then a fourteen-year-old girl. 8. In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. 9. On or about March 11, 2003, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #2. 10. In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who would be interested in engaging in similar sexual activities with him. EFTA00194927 11. In or around 2003, Defendant took nude photographs of Jane Doe #2, who was then a sixteen-year-old girl. 12. In or around 2003, Defendant made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. 13. In or around 2003, Defendant told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked ICELLEN to take nude photographs of Jane Doe #2. 14. In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a sixteen-year-old girl. 15. In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a sixteen-year-old girl. 16. In or around 2003, Defendant placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. 17. On or about April 23, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. 18. On or about May 2, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. Jane Doe #3 1. In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #3, who was then a fifteen-year-old girl. 2. In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. 3. On or about October 26, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. 4. On or about October 30, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. 5. In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe #3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and to touch the adult female's breasts. EFTA00194928  6. In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of an adult female in the presence of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. 7. In or around 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. 8. In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #3 to rub his nipples. 9. In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. 10. In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. 11. On or about November 8, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #3 that read: "I have a female for him." 12. On or about January 14, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #3. 13. On or about January 29, 2005, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #3 that read: "I have a female for him." Jane Does #4, #5, and #6 1. In or around the first half of 2004, Defendant led Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. 2. In or around the first half of 2004, Defendant JEFFREY EPSTEIN learned that Jane Doe #4 was seventeen years old when he asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. 3. In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, and Jane Doe #5, who was then a seventeen-year-old girl. 4. In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his nipples. EFTA00194929  5. In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her clothing. 6. In or around the first half of 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #4, who was then a seventeen-year-old girl. 7. In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #4. 8. In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #5. 9. In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #6 what high school she attended. 10. In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone. 11. In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl. 12. In or around the first half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #6, who was then a sixteen-year-old girl. 13. In or around the first half of 2004, Defendant JEFFREY EPSTEIN placed a large vibrating massager on the vagina of Jane Doe #6, who was then a sixteen-year-old girl. 14. In or around the first half of 2004, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #6. Jane Does #7 and #8 1. In or around July 2004, Defendant JEFFREY EPSTEIN led T.M., who was then a fifteen-year-old girl, and Jane Doe #7, who was then a sixteen-year-old girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom. 2. On or about July 4, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #7. 3. On or about July 5, 2004, Defendant placed a telephone call to a telephone used by T.M. 4. In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #8, who was then a seventeen-year-old girl. EFTA00194930  5. In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #8, who was then a seventeen-year-old girl. 6. In or around July 2004, Defendant JEFFREY EPSTEIN paid approximately $200 to Jane Doe #8. 7. In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to T.M. for recruiting Jane Doe #8 to travel to 358 El Brillo Way. 8. In or around July 2004, Defendant told Jane Doe #8 that Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a friend. 9. On or about July 15, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #7. 10. On or about July 15, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. 11. On or about July 15, 2004, Defendant placed a telephone call to a telephone used by T.M. 12. On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. 13. On or about July 16, 2004, Defendant placed a telephone call to a telephone used by T.M. 1. On or about July 17, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from T.M. that read: "Me & [Jane Doe #7] can come tomorrow any time or [T.M.] alone". 2. In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #7, who was then a sixteen-year-old girl. 3. In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #7, who was then a sixteen-year-old girl, to rub his nipples. 4. In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #7, who was then a sixteen-year-old girl. 5. In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #7. EFTA00194931  6. In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe #7 that if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN's home, bad things could happen to her. 7. On or about July 24, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. Jane Does #9 and #10 1. On or about July 15, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. 2. On or about July 16, 2004, Defendant caused Jane Doe #9 to make a telephone call to a telephone used by Jane Doe #10. 3. On or about July 17, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. 4. On or about July 18, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. 5. On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. 6. In or around July 2004, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #9, who was then a seventeen-year-old girl. 7. In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #9, who was then a seventeen-year-old girl. 8. In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #9. 9. On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #10. 10. In or around the last half of 2004, Defendants JEFFREY EPSTEIN and engaged in oral sex and sexual intercourse in the presence of Jane Doe #9, who was then a seventeen-year-old girl. 11. In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly inserted his penis into the vagina of Jane Doe #9, who was then a seventeen-year-old girl. EFTA00194932 12. In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #9. 13. In or around the last half of 2004, Defendant JEFFREY EPSTEIN rubbed the vagina of Jane Doe #10, who was then a seventeen-year-old girl. 14. In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #10. 15. On or about November 28, 2004, Defendant JEFFREY EPSTEIN arranged for one of his employees to provide an envelope filled with cash to Jane Doe #9. 16. On or about December 4, 2004, Defendant provided a written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 9 and 10, stating: "[Jane Doe #10] would like to work @ 4:00 pm if possible. [[Jane Doe #9] is scheduled for 5:00 today.] the movie is @ 7:30". 17. On or about December 29, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. 18. On or about December 30, 2004, Defendants JEFFREY EPSTEIN and caused the purchase of Broadway tickets as an eighteenth birthday gift for Jane Doe #9. 19. In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen-year-old girl. 20. In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #10, who was then a seventeen-year-old girl. 21. On or about January 14, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. 22. On or about January 27, 2005, Defendant a/k/a a la" placed one or more telephone calls to a telephone used by Jane Doe #10. 23. On or about January 28, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. 24. On or about February 1, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. EFTA00194933 25. In or around February 2005, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #9 for recruiting Jane Doe #16 to travel to 358 El Brillo Way. Jane Doe #11 1. In or around the summer of 2004, Defendant led Jane Doe #11 and T.M. from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's master bedroom suite. 2. In or around the summer of 2004, Defendant JEFFREY EPSTEIN paid $200 to T.M. for bringing Jane Doe #11 to 358 El Brillo Way. 3. In or around the summer of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #11, who was then a fifteen- or sixteen-year-old girl. 4. In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #11 to rub his chest and pinch his nipples while he masturbated. 5. In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #11 to write her telephone number on a notepad in his master bedroom suite. 6. In or around the summer of 2004, Defendant JEFFREY EPSTEIN learned Jane Doe #11's true age when he asked Jane Doe #11 how old she was and she responded truthfully. 7. In or around the summer of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #11 that he did not care how old she was and that he did not like girls older than eighteen. 8. In or around the second half of 2004, Defendant JEFFREY EPSTEIN placed a vibrating massager on the vagina of Jane Doe #11, who was then a sixteen-year-old girl. 9. In or around the second half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated the vagina of Jane Doe #11, who was then a sixteen-year-old girl. 10. On or about August 6, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. 11. On or about August 18, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. EFTA00194934 12. On or about October 29, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. 13. On or about November 5, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. 14. On or about February 14, 2005, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #11 that read: "Please! Call her back". 15. On or about February 14, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #11. 16. On or about February 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #11. 17. On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #11. 18. In or around the second half of 2005 or the first quarter of 2006, Defendant JEFFREY EPSTEIN offered to pay $400 to Jane Doe #11, who was then a sixteen-year-old girl, if she would engage in oral sex, or $500 or more if she would engage in sexual intercourse. 19. In or around the second half of 2005, Defendant JEFFREY EPSTEIN offered to pay $100 to Jane Doe #11 if she would bring other girls to 358 El Brillo Way. Jane Does #12 and #13 I. On or about August 2, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from T.M. and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #13] too". 2. On or about August 21, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #13. 3. In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #12, who was then a seventeen-year-old girl. 4. In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #12, who was then a seventeen-year-old girl. EFTA00194935  5. In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to place a massaging device on the vagina of Jane Doe #12, who was then a seventeen-year-old girl. 6. In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #12. 7. In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #12, who was then a seventeen-year-old girl, about her age. 8. In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #12 that he would take her to Los Angeles when she turned eighteen. 9. In or around the last half of 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #12 to recruit Jane Doe #13 to travel to 358 El Brillo Way. 10. In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #13, who was then a seventeen-year-old girl. 11. In or around the end of 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #13, who was then a seventeen-year-old girl. 12. In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #13. 13. In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #13, who was then a seventeen-year-old girl. 1. In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13, who was then a seventeen-year-old girl, about her age. 2. In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #13 that he wanted to take her to Paris but he could not because Jane Doe #13 was not yet eighteen years old. 3. In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13 to bring her friends to his home, especially "girls who looked like [Jane Doe #13]." Jane Doe #14 1. In or around the last half of 2004, Defendant led Jane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's EFTA00194936  bedroom at 358 El Brillo Way. 2. In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #14 to provide her telephone number. 3. In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples. 4. In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #14, who was then a seventeen-year old girl. 5. In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #14. 6. In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeen-year-old girl. 7. In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl, whether she had any plans for her eighteenth birthday and acknowledged that she had not yet turned eighteen. 8. On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #14. 9. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #14, who was then a seventeen-year-old girl. 10. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doe #14, who was then a seventeen-year-old girl. 11. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl. 12. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $600 to Jane Doe #14. 13. On or about January 8, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. 14. On or about January 9, 2005, Defendant a/k/a a placed a telephone call to a telephone used by Jane Doe #14. 15. On or about January 26, 2005, Defendant a/k/a reviewed a written telephone message prepared by one of Defendant JEFFREY EFTA00194937  EPSTEIN's employees regarding a call received from Jane Doe #14 that read: "She is confirming for 5:30". 16. On or about January 26, 2005, Defendant a/k/a a placed a telephone call to a telephone used by Jane Doe #14. 17. On or about February 1, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. 18. On or about March 1, 2005, Defendant a/k/a a placed a telephone call to a telephone used by Jane Doe #14. 19. On or about March 21, 2005, Defendant a/k/a a placed a telephone call to a telephone used by Jane Doe #14. 20. On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. Jane Doe #15 1. On or about December 6, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. 2. On or about December 14, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. 3. In or around the first half of 2005, Defendant led Jane Doe #15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. 4. In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #15, who was then a seventeen-year-old girl, to pinch his nipples while he masturbated. 5. In or around the first half of 2005, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #15. 6. In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #15. 7. On or about January 7, 2005, Defendant a/k/a a ," placed a telephone call to a telephone used by Jane Doe #15. EFTA00194938  8. On or about February 4, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. 9. On or about February 10, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. 10. On or about February 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. 11. On or about February 24, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. 12. On or about March 17, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. 13. On or about March 30, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. 14. On or about March 31, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. 15. On or about March 31, 2005, Defendant I , a/k/a `a 1," placed a telephone call to a telephone used by Jane Doe #15. 16. On or about April 1, 2005, Defendant JEFFREY EPSTEIN reviewed a note prepared by one of his employees that read: "10:30 [Jane Doe #15]/[Jane Doe #10] on Fri around 2'Oclock". 17. In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane Doe #15 with a gift of Victoria's Secret lingerie for her eighteenth birthday. Jane Does #16 & #17 I. In or around February 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #16, who was then a seventeen-year-old girl. 2. In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #16 to place a telephone call to Jane Doe #17 to ask her to travel to 358 El Brillo Way. 3. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN caused a payment to be made to Jane Doe #16 for recruiting Jane Doe #17 to travel to 358 El Brillo Way. EFTA00194939  4. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #17, who was then a sixteen-year-old girl. 5. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her clothing. 6. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #17, who was then a sixteen-year-old girl. 7. In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #17, who was then a sixteen-year-old girl. 8. In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #16, who was then a seventeen-year- old girl. 9. In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, how old she was, and she responded that she was seventeen years old. 10. In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN engaged in sexual activity with Defendant in the presence of Jane Doe #16, who was then a seventeen-year-old girl. 11. In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, to touch the breast of Defendant 12. On or about April 11, 2005, Defendant l l a/k/a a l l," placed a telephone call to a telephone used by Jane Doe #16. 13. On or about April 11, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 14. On or about April 11, 2005, Defendant left a message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] can work tomorrow at 4pm." 15. On or about May 19, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 16. On or about June 30, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. EFTA00194940 17. On or about July 2, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 18. On or about July 22, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 19. On or about August 18, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 20. On or about August 19, 2005, Defendant a/lc/a a l l," placed a telephone call to a telephone used by Jane Doe #16. 21. On or about August 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 22. On or about September 3, 2005, Defendant l l, a/lc/a a l l," placed a telephone call to a telephone used by Jane Doe #16. 23. On or about September 18, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 24. On or about September 19, 2005, Defendant sent a text message to a telephone used by Jane Doe #16. 25. On or about September 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 26. On or about September 30, 2005, Defendant a/lc/a a l l," placed a telephone call to a telephone used by Jane Doe #16 • 27. On or about October 1, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #15] confirmed at 11 AM and [Jane Doe #16] — 4PM". 28. On or about October 2, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 29. On or about October 3, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #16. 30. On or about October 3, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] will be 12 / hour late". EFTA00194941 31. In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doe #16, who was then a seventeen-year-old girl. 32. In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN made a payment of $350.00 to Jane Doe #16, who was then a seventeen-year-old girl. 33. In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN provided a gift of Victoria's Secret lingerie to Jane Doe #16 for her eighteenth birthday. Jane Does #18 and #19 1. In or around the last half of 2003, Jane Doe #18 was approached by A.F. and was asked whether she would be willing to provide a massage to Defendant JEFFREY EPSTEIN in exchange for $200. 2. In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to provide her telephone number. 3. On or around August 27, 2003, Defendant placed a telephone call to a telephone used by Jane Doe #18. 4. In or around the last half of 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #18, who was then a seventeen-year-old-girl. 5. On or around November 16, 2003, Defendant placed a telephone call to a telephone used by Jane Doe #18. 6. In or around the last half of 2003, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #18, who was then a seventeen-year-old-girl. 7. In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to recruit other females to travel to 358 El Brillo Way. 8. On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #19, who was then a seventeen-year-old girl, to leave when she refused to remove her shirt. 9. On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally reprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she was not willing to undress for him. The Defendants' Travel 1. On or about July 16, 2004, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach EFTA00194942  County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 2. On or about August 6, 2004, Defendants JEFFREY EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. 3. On or about August 19, 2004, Defendants JEFFREY EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft o