EFTA00029538

The Government expects Minor Victim-3 to testify, in substance and in part, that she met
the defendant when she was approximately 17 years old. Within a few weeks of meeting the
defendant, at the defendant's invitation, Minor Victim-3 went to the defendant's townhouse in
London for tea. The defendant expressed an interest in Minor Victim-3, talked with Minor Victim-
3 about Minor Victim-3's life and interests, and told Minor Victim-3 about her boyfriend Jeffrey
Epstein, who she wanted Minor Victim-3 to meet. Shortly after, the defendant invited Minor
Victim-3 to her home. During that first visit, the defendant introduced Minor Victim-3 to Epstein
and encouraged her to give Epstein a foot massage. Epstein instructed Minor Victim-3 to massage
his shoulders. Minor Victim-3 left the townhouse after she was excused.
Shortly thereafter, the defendant invited Minor Victim-3 to her home again and encouraged
Minor Victim-3 to provide Epstein with a massage. The defendant showed Minor Victim-3 to a
room in which a massage table was set up. Epstein was in the room. Epstein removed his robe
and was naked. The defendant handed Minor Victim-3 oil and closed the door. After the massage,
the defendant was outside the room and asked if Minor Victim-3 had fun and whether Epstein
liked the massage. The defendant subsequently told Minor Victim-3 that Epstein was impressed
with her and asked her to come back to her townhouse. The defendant encouraged Minor Victim-
3 to provide a massage to Epstein. The defendant thanked Minor Victim-3, indicating that if it
wasn't Minor Victim-3 or someone else, it would all fall to her (the defendant). The defendant
again showed Minor Victim-3 to a room with a massage table where Epstein was naked. Both
massages involved at least one sex act with Minor Victim-3.
Following those two encounters, the defendant and Epstein invited Minor Victim-3 to
travel with them to Florida, the U.S. Virgin Islands, and New York. Minor Victim-3 eventually
accepted these invitations, but she does not recall whether she was 17 or 18 when she took her first
trip at Epstein and the defendant's invitation. Minor Victim-3 traveled to visit the defendant and
Epstein in New York, Palm Beach, and Little Saint James. When Minor Victim-3 met the
defendant and Epstein in these locations, she provided additional massages to Epstein, during
which he engaged in sex acts with Minor Victim-3. Over the course of their interactions, the
defendant made multiple statements to Minor Victim-3 reflecting the defendant's awareness that
Epstein engaged in sex acts with Minor Victim-3. On at least one occasion, the defendant asked
Minor Victim-3 if she knew any other young females to bring to Epstein and made comments to
Minor Victim-3 about Epstein's significant sexual needs.
On one occasion in Palm Beach, the defendant provided Minor Victim-3 with a schoolgirl
uniform and told Minor Victim-3, in substance and in part, that she should bring Epstein his tea in
the uniform. After Minor Victim-3 brought Epstein tea that had been provided by the defendant,
Epstein raped Minor Victim-3.
EFTA00029538