EFTA00040737

From: ' 
(USANYS)" < 
To: ' 
(USANYS)" 
Subject: FW: draft urgent matter report 
Date: Tue, 25 Jun 2019 19:10:37 +0000 
Importance: Normal 
Attachments: 2019-06-24, JE,_urgent_matter_report.docx 
> 
I'm reviewing 
From: 
Sent: Tuesday, June 25, 2019 11:59 AM 
To: 
(USANYS)
Cc: 
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Subject: RE: draft urgent matter report 
(USANYS) cM
> 
As requested, below is a draft urgent matter report, based on the example from the 
case. It's also attached in 
Word version in case that's easier to work off of for any edits. 
FROM: 
UNITED STATES ATTORNEY 
SOUTHERN DISTRICT OF NEW YORK 
PHONE: 212-637-2200 
DISTRICT POC: Geoffrey S. Berman, U.S. Attorney 
Phone 
SYNOPSIS: 
The USAO-SDNY plans to indict Jeffrey Epstein on one count of sex trafficking of a minor and one count of 
conspiracy to commit sex trafficking of a minor. The charges stem from Epstein's sexual abuse of minor girls in 
Palm Beach, Florida, and New York, New York, from at least in or about 2002, through up to and including in or 
about 2005. We plan to seek the indictment on or about July 2, 2019. 
DESCRIPTION: 
Since approximately December 2018, the USAO-SDNY has been investigating Jeffrey Epstein, a wealthy 
financier who during the relevant period maintained multiple residences in the continental United States and 
elsewhere, including in New York, New York (the "New York Residence"), and Palm Beach, Florida (the "Palm 
Beach Residence"). Beginning in at least 2002, Epstein enticed and recruited, and caused to be enticed and 
recruited, dozens of minor girls to engage in sex acts with him at the New York Residence and the Palm Beach 
Residence in exchange for money. In both New York and Florida, Epstein perpetrated this abuse in similar 
ways. Victims were initially recruited to provide "massages" to Epstein, which would be performed nude or 
partially nude, became increasingly sexual in nature, and would typically include one or more sex acts. Epstein 
paid his victims several hundred dollars in cash for each encounter. Moreover, Epstein paid certain of his 
victims to recruit additional minor girls to be similarly sexually abused. In this manner, Epstein maintained a 
steady supply of new victims to exploit. In particular, three victims in New York and Florida have described this 
pattern of conduct and abuse; each of the three victims also recruited other girls for Epstein to victimize in 
exchange for payment from Epstein. 
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Epstein previously was investigated for this conduct by the Southern District of Florida U.S. Attorney's Office 
("SDFL"), which entered into a non-prosecution agreement with Epstein (the "NPA"). By its terms, the NPA 
does not purport to bind any prosecuting authority other than the SDFL, and only purports to provide coverage 
for certain listed Florida victims. Here, the substantive count does not include as a victim any individuals based 
in Florida. Additionally, although the charged conduct occurred some time ago, for each count the sexual abuse 
occurred, in part, after April 2003, when 18 U.S.C. § 3283 was revised to permit the prosecution of sex offenses 
against minors at any time during the lifetime of the minor victim. Related, although currently the statute for 
conspiring to commit sex trafficking is 18 U.S.C. § 1594, that statute was not enacted until 2008, after the 
conduct described herein; accordingly, we intend to charge a conspiracy under 18 U.S.C. § 371. 
The USAO-SDNY intends to indict Epstein on one count of sex trafficking of a minor, in violation of 18 U.S.C. 
§ 1591, and one count of conspiracy to commit sex trafficking of a minor, in violation of 18 U.S.C. § 371. 
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