EFTA00098456

Ul 
S.J. QUINNEY 
COLLEGE OF LAW 
TI IC UNIVERSITY OF UTAH 
Metropolitan Police Service 
New Scotland Yard 
8-10 Broadway 
London SW1H 0BG 
United Kingdom 
PAUL G. CASSELL 
Ronald N. Boyce Presidential Professor of Criminal Law 
May 4, 2015 
Re: 
International Sex Trafficking by Jeffrey Epstein and Ghislaine Maxwell 
Dear Metropolitan Police: 
I write on behalf of my client — 
. She is the victim of an 
international sex trafficking crime in London shortly before March 13, 2001. In the following 
weeks (and much earlier), the crimes also continued into the United States, specifically New 
York City, New York, and the U.S. Virgin Islands. The perpetrators of these crimes include: (1) 
Jeffrey Epstein, a billionaire (and convicted sex offender) who is a citizen of the United States 
residing in New York City; (2) Ghislaine Maxwell, a well-to-do citizen of the United Kingdom 
who moved to the United States after the death of her father, Robert Maxwell; and (3) others 
known and unknown. 
would like for Scotland Yard and/or Metropolitan Police to 
investigate these crimes and prosecute those res onsible. The purpose of this letter is to provide 
background about the crimes and to offer 
assistance in any investigation and 
prosecution. 
has described the relevant facts surrounding these crimes in the attached 
sworn affidavit. Rather than repeat all the details recounted there I offer 'ust a quick summary. 
In approximately the summer of 1999 in Palm Beach, Florida, 
was approached by 
Ghislaine Maxwell to be a "masseuse" for Jeffrey Epstein. Epstein was a billionaire with a 
mansion in the area. When 
went to the mansion, Epstein (and Maxwell) sexually 
abused her. 
was 15 at the time of the first sexual abuse. She became Epstein's "sex 
slave" over the next few years, and Epstein and Maxwell groomed her to perform sexual acts for 
their powerful friends. 
A little over two years later, in around March 2013, Epstein and Maxwell flew 
to London on Epstein's private et. While in London, Epstein had sex with 
Epstein and Maxwell also "lent" 
to one of their powerful friends — Mr. Andrew 
Albert Christian Edward (a/k/a Prince Andrew, the Duke of York). The details of the sexual acts 
are described in the attached affidavit. Of importance here is the fact that 
had a 
photograph taken of her that evening. The photograph (the original of which I have access to) 
was taken by Jeffrey Epstein and de icts the inside of Maxwell's apartment — along with 
Maxwell, Prince Andrew, and 
. The date on the photograph shows that it was 
developed on March 13, 2001, which was shortly after the relevant events. Following this sexual 
EFTA00098456

act, 
returned with Epstein and Maxwell to New York City. Other events of a similar 
nature took place in New York and the U.S. Virgin Islands. 
It is my understanding that the activities of Epstein and Maxwell outlined above would be 
a violation of American criminal laws, including the American prohibition of transporting 
minors internationally for sexual purposes contained in 18 U.S. Code § 1591. I am not an expert 
on the applicable laws in the United Kingdom, but it seems like the same type of criminal 
offenses may exist there as well. 
In America, there is no statute of limitations for sexual offenses involving minors. It is 
possible that the law there in the United Kingdom is similar on this point as well. 
In 2002, to escape Epstein, 
moved to 
In 2011, agents from the 
Federal Bureau of Investigation's Office in the Southern District of Florida interviewed her, and 
she recounted this information, as she described both in the first attached affidavit as well as in a 
second attached affidavit. The status of the FBI's investigation into her allegations is uncertain at 
this time. It may be the case that the Southern District of Florida is disabled from prosecuting 
Epstein and Maxwell because of a "non-prosecution agreement" (NPA) that the U.S. 
Government has entered into with Epstein. Along with attorney Brad Edwards, I am 
representing 
and three other women who are trying to have that agreement set aside. 
Litigation on that subject continues. 
I should note that the attached affidavit was recently filed in the case attempting to set 
aside the NPA. The judge struck the affidavit from the record on grounds that it was not relevant 
at that stage of the proceedings. The judge made no findings regarding the accuracy of the 
allegations in the affidavit and said that the affidavit could be refiled at a later point in the 
proceedings if it became relevant and otherwise admissible in evidence. 
I represent 
, along with co-counsel, Florida attorneys Brad Edwards and 
Sigrid McCawley. We would like to discuss this matter with you at your earliest convenience. I 
believe the Metropolitan Police possess jurisdiction in this matter but, if not, please advise as to 
who would have jurisdiction. I have also attempted to send this communication via on-line 
means. 
While I am a professor at the University of Utah, I write in my own individual capacity as 
a pro bono attorney representing 
, rather than on behalf of the University itself. I 
look forward to further discussions with you in an effort to bring to justice Epstein, Maxwell, and 
any others criminally culpable in these serious trafficking crimes. 
Sincerely, 
2111
med. 
'". • 
2 
EFTA00098457

Cc: 
Brad Edwards, Esq. 
Sigrid McCawley, Esq. 
Jack Scarola, Esq. 
Enclosures 
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EXHIBIT 1 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
CASE NO. 08-80736-CIV-MARRA 
JANE DOE #1 and JANE DOE #2, 
Petitioners, 
VS. 
UNITED STATES OF AMERICA, 
Respondent. 
DECLARATION OF 
1. 
My name is 
and I was born in August, 1983. 
2. 
I am currently 31 years old. 
3. 
I grew up in 
When I was little, I loved animals and wanted 
to be a veterinarian. But my life took a very different turn when adults began to be interested in 
having sex with me. 
4. 
In approximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She is 
the daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell asked 
that I come with her to Jeffrey Epstein's mansion for the purposes of teaching me how to 
perform "massages" and to train me professionally in that area. Soon after that I went to 
Epstein's home in Palm Beach on El Brillo Way. 
5. 
From the first time I was taken to Epstein's mansion that day, his motivations and 
actions were sexual, as were Maxwell's. My father was not allowed inside. I was brought up 
some stairs. There was a naked guy, Epstein, on the table in the room. Epstein and Maxwell 
forced me into sexual activity with Epstein. I was 15 years old at the time. He seemed to be in 
his 40s or 50s. I was paid $200. I was driven home by one of Epstein's employees. 
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6. 
I came back for several days following and did the same sorts of sexual things for 
Epstein. 
7. 
After I did those things for Epstein, he and Maxwell said they were going to have 
me travel and were going to get an education for me. They were promising me the world, that I 
would travel with Epstein on his private jet and have a well-paid profession. Epstein said he 
would eventually match me up with a wealthy person so that I would be "set up" for life. 
8. 
So I started "working" exclusively for Epstein. He took me to New York on his 
big, private jet. We went to his mansion in New York City. I was shown to my room, a very 
luxurious room. The mansion was huge. I got scared because it was so big. Epstein brought me 
to a room with a massage parlor. To me, it looked like an S&M parlor. Epstein made me engage 
in sexual activities with him there. 
9. 
You can see how young I looked in the photograph below. 
Aet 
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10. 
Epstein took me on a ferry boat on one of the trips to New York City and there he 
took the picture above. I was approximately 15 or 16 years old at the time. 
11. 
Over the next few weeks, Jeffrey Epstein and Ghislaine Maxwell trained me to do 
what they wanted, including sexual activities and the use of sexual toys. The training was in 
New York and Florida, at Epstein's mansions. It was basically every day and was like going to 
school. I also had to have sex with Epstein many times. 
12. 
I was trained to be "everything a man wanted me to be." It wasn't just sexual 
training - they wanted me to be able to cater to all the needs of the men they were going to send 
me to. They said that they loved that I was very compliant and knew how to keep my mouth 
shut. 
13. 
Epstein and Maxwell also told me that they wanted me to produce things for them 
in addition to performing sex on the men. They told to me to pay attention to the details about 
what the men wanted, so I could report back to them. 
14. 
From very early on I was fearful of Epstein. Epstein told me he was a billionaire. 
I told my mother that I was working for this rich guy, and she said "go, go far away." Epstein 
had promised me a lot, and I knew if I left I would be in big trouble. I also knew that I was a 
witness to a lot of illegal and very bad behavior by Epstein and his friends. If I left Epstein, he 
knew all kinds of powerful people. He could have had me killed or abducted, and I always knew 
he was capable of that if I did not obey him. He let me know that he knew many people in high 
places. Speaking about himself, he said "I can get away" with things. I was very scared, 
particularly since I was a teenager. 
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15. 
I visited and traveled with Jeffrey Epstein from 1999 through the summer of 
2002, and during that time I stayed with him, as his sex slave, at each of his houses (really more 
like mansions) in locations including New York City, New York; the area of Santa Fe, New 
Mexico; Palm Beach, Florida; an island in the U.S. Virgin Islands; and Paris, France. I had sex 
with him often in these places and also with the various people he demanded that I have sex 
with. Epstein paid me for many of these sexual encounters. In fact, my only purpose for 
Epstein, Maxwell and their friends was to be used for sex. 
16. 
To illustrate my connection to these places, I include four photographs taken of 
me in New Mexico (shown below). The first one is a museum in Santa Fe, New Mexico. We 
had gone sightseeing for the day. Epstein took this picture of me. I was approximately 17 at the 
time, judging from the looks of it. At the end of the day we returned to Epstein's ZO/TO Ranch. 
The second picture is me on one of Epstein's horses on the ranch in New Mexico. The following 
two are from wintertime in New Mexico. 
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17. 
When I was with him, Epstein had sex with underage girls on a daily basis. His 
interest in this kind of sex was obvious to the people around him. The activities were so obvious 
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and bold that anyone spending any significant time at one of Epstein's residences would have 
clearly been aware of what was going on. 
18. 
Epstein's code word for sexual encounters was that it was a "massage". At times 
the interaction between Epstein and the girls would start in a massage room setting, it was 
always a sexual encounter and never just a massage. 
19. 
In addition to constantly finding underage girls to satisfy their personal desires, 
Epstein and Maxwell also got girls for Epstein's friends and acquaintances. Epstein specifically 
told me that the reason for him doing this was so that they would "owe him," they would "be in 
his pocket," and he would "have something on them." I understood him to mean that when 
someone was in his pocket, they owed him favors. I also understood that Epstein thought he 
could get leniency if he was ever caught doing anything illegal, or more so that he could escape 
trouble altogether. 
20. 
Ghislaine Maxwell was heavily involved in the illegal sex. I understood her to be 
a very powerful person. She used Epstein's money and he used her name and connections to 
gain power and prestige. 
21. 
One way to describe Maxwell's role was as the "madame." She assumed a 
position of trust for all the girls, including me. She got me to trust her and Epstein. It turned out 
that Maxwell was all about sex all the time. She had sex with underage girls virtually every day 
when I was around her, and she was very forceful. 
22. 
I first had sexual activities with her when I was approximately 15 at the Palm 
Beach mansion. I had many sexual activities with her over the next several years in Epstein's 
various residences plus other exotic locations. I had sex with Maxwell in the Virgin Islands, 
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New Mexico, New York, as well as France and many other locations. I also observed Maxwell 
have sex with dozens of underage girls. 
23. 
Maxwell took pictures of many of the underage girls. These pictures were 
sexually explicit. Maxwell kept the pictures on the computers in the various houses. She also 
made hard copies of these images and displayed them in the various houses. Maxwell had large 
amounts of child pornography that she personally made. Many times she made me sleep with 
other girls, some of whom were very young, for purposes of taking sexual pictures. 
24. 
Harvard law professor Alan Dershowitz was around Epstein frequently. 
Dershowitz was so comfortable with the sex that was going on that he would even come and chat 
with Epstein while I was giving oral sex to Epstein. 
25. 
I had sexual intercourse with Dershowitz at least six times. The first time was 
when I was about 16, early on in my servitude to Epstein, and it continued until I was 19. 
26. 
The first time we had sex took place in New York in Epstein's home. It was in 
Epstein's room (not the massage room). I was approximately 16 years old at the time. I called 
Dershowitz "Alan." I knew he was a famous professor. 
27. 
The second time that I had sex with Dershowitz was at Epstein's house in Palm 
Beach. During this encounter, Dershowitz instructed me to both perform oral sex and have 
sexual intercourse. 
28. 
I also had sex with Dershowitz at Epstein's Zorro Ranch in New Mexico in the 
massage room off of the indoor pool area, which was still being painted. 
29. 
We also had sex at Little Saint James Island in the U.S. Virgin Islands. I was 
asked to give Dershowitz a massage on the beach. Dershowitz then asked me to take him 
somewhere more private, where we proceeded to have intercourse. 
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30. 
Another sexual encounter between me and Dershowitz happened on Epstein's 
airplane. Another girl was present on the plane with us. 
31. 
I have recently seen a former Harvard law professor identified as Alan 
Dershowitz on television calling me a "liar." He is lying by denying that he had sex with me. 
That man is the same man that I had sex with at least six times. 
32. 
Epstein made me have sex with Prince Andrew several times. Prince Andrew, 
Maxwell, and I are shown in the photograph below. I had sex with him three times, including 
one orgy. I knew he was a member of the British Royal Family, but I just called him "Andy." 
33. 
One day when I was in London (specifically in a townhouse that is under 
Maxwell's name), I got news from Maxwell that I would be meeting a prince. Later that day, 
Epstein told me I was meeting a "major prince." Epstein told me "to exceed" everything I had 
been taught. He emphasized that whatever Prince Andrew wanted, I was to make sure he got. 
34. 
Eventually Prince Andrew arrived, along with his security guards. The guards 
then went out of the house and stayed out front in their car. It was just Epstein, Maxwell, and me 
inside alone with Andy. I was introduced to the Prince, and we kissed formally, cheek to cheek. 
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There was a lot of legal discussion about Andy and his ex-wife ("Fergie"). Then the discussion 
turned to me. Maxwell said "guess how old she is." Prince Andrew guessed 17. 
35. 
Then we all went to a Chinese restaurant for dinner and then to Club Tramp, a 
fancy "members only" night club in central London. Andy arranged for alcohol to be provided 
to me at the club. Eventually we left. I rode with Epstein and Maxwell back to the townhouse. 
On the way there, Epstein and Maxwell informed me that the Prince wanted to see "more of me" 
that night. Andy traveled in a separate car with his guards. 
36. 
We all arrived back at the townhome and went upstairs. Epstein took a picture of 
me and Andy with my own camera. The picture above is that picture, which has been widely 
circulated on the intemet. Andy has his left arm around my waist and is smiling. The picture was 
developed on March 13, 2001, and was taken sometime shortly before I had it developed. I was 
17 years old at the time. 
37. 
I wanted a picture with the prince because I was keeping in contact with my 
family. I had told my mom and my grandma that I was meeting Prince Andrew and that I'd take 
a picture for them. They told me to "be careful." 
38. 
After the picture, Epstein and Maxwell kissed me and said to "have fun." They 
left Andy and me alone upstairs. We went to the bathroom and bedroom, which were just steps 
away from where the picture was taken. We engaged in sexual activities there. Afterwards, 
Andy left quickly with his security. 
39. 
I chatted with Epstein about this the next day. I told him, "it went great." Epstein 
said something to the effect of, "You did well. The Prince had fun." I felt like I was being 
graded. It was horrible to have to recount all these events and have to try to meet all these needs 
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and wants. I told Epstein about Andy's sexual interests in feet. Epstein thought it was very 
funny. Epstein appeared to be collecting private information about Andy. 
40. 
When I got back from my trip, Epstein paid me more than he had paid me to be 
with anyone else — approximately $15,000. That money was for what I had done and to keep my 
mouth shut about "working" with the Prince. 
41. 
The second time I had sex with Prince Andrew was in Epstein's New York 
mansion in spring 2001. I was 17 at time. Epstein called me down to his office. When I got 
there, Epstein was there, along with Maxwell, 
and Andy. I was very surprised 
to see him again. Epstein and Maxwell were making lewd jokes about "Randy Andy". 
42. 
I had the impression that Andy had come there to see Epstein and to 
me 
with. There was no other apparent purpose for Andy to be there. 
43. 
I was told to go upstairs with Andy and to go to the room I thought of as the 
"dungeon" (the massage room, but it is really scary looking). I
with Andy there. I was 
only paid $400 from Epstein for servicing Andy that time. 
44. 
The third time I had sex with Andy was in an orgy on Epstein's private island in 
the U.S. Virgin Islands. I was around 18 at the time. Epstein, Andy, approximately eight other 
young girls, and I had sex together. The other girls all seemed and appeared to be under the age 
of 18 and didn't really speak English. Epstein laughed about the fact they couldn't really 
communicate, saying that they are the "easiest" girls to get along with. My assumption was that 
Jean Luc Brunel got the girls from Eastern Europe (as he procured many young foreign girls for 
Epstein). They were young and European looking and sounding. 
45. 
Afterwards we all had dinner by the cabanas. The other girls were chatting away 
among themselves, and Epstein and the Prince chatted together. I felt disgusted, and went 
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20 
quickly to my own cabana that night and went to sleep. Prince Andrew must have flown out 
early the next morning, as I did not see him when I got up. 
46. 
I have seen Buckingham Palace's recent "emphatic" denial that Prince Andrew 
had sexual contact with me. That denial is false and hurtful to me. I did have sexual contact 
with him as I have described here — under oath. Given what he knows and has seen, I was 
hoping that he would simply voluntarily tell the truth about everything. I hope my attorneys can 
interview Prince Andrew under oath about the contacts and that he will tell the truth. 
47. 
I also had sexual intercourse with Jean Luc Brunel many times when I was 16 
through 19 years old. He was another of Epstein's powerful friends who had many contacts with 
young girls throughout the world. In fact, his only similarity with Epstein and the only link to 
their friendship appeared to be that Brunel could get dozens of underage girls and feed Epstein's 
(and Maxwell's) strong appetite for sex with minors. 
48. 
Brunel ran some kind of modeling agency and appeared to have an arrangement 
with the U.S. Government where he could get passports or other travel documents for young 
girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United 
States for sexual purposes and farm them out to his friends, including Epstein. 
49. 
Brunel would offer the girls "modeling" jobs. A lot of the girls came from poor 
countries or poor backgrounds, and he lured them in with a promise of making good money. 
50. 
I had to have sex with Brunel at Little St. James (orgies), Palm Beach, New York 
City, New Mexico, Paris, the south of France, and California. He did not care about 
conversation, just sex. 
51. 
Jeffrey Epstein has told me that he has slept with over 1,000 of Brunel's girls, and 
everything that I have seen confirms this claim. Epstein, Brunel, and Maxwell loved orgies with 
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20 
kids — that is, having sexual interactions with many young teenagers at the same time. 
Sometimes as many as ten underage girls would participate in a single orgy with them. I 
personally observed dozens of these orgies. The orgies happened on Epstein's island in the U.S. 
Virgin Islands, in New Mexico, Palm Beach, and many other places. Most of the girls did not 
speak English. It was my understanding that the girls had been persuaded to come by Brunel 
offering them illegal drugs or a career in modeling. Brunel was one of the main procurers of 
girls. 
52. 
In addition to Ghislaine Maxwell, 
and 
were also 
involved in the orgies. At this stage, I am hopeful that these other women will come forward and 
tell the truth about everything because that will help prevent future similar abuse. 
53. 
I have seen reports saying or implying that I had sex with former President Bill 
Clinton on Little Saint James Island. Former President Bill Clinton was present on the Island at 
a time when I was also present on the Island, but I have never had sexual relations with Clinton, 
nor have I ever claimed to have had such relations. I have never seen him have sexual relations 
with anyone. 
54. 
I now understand that Epstein reached a non-prosecution agreement with the 
federal government in 2007 and pled guilty to two state crimes in June 2008. 1 now know that I 
was identified by the federal government as one of Epstein's and his co-conspirator's sexually 
abused victims. However, no one told me about those events until after they happened. 
55. 
On September 3, 2008, the FBI sent a victim notification letter to me. This was 
the first written communication I had received from the FBI. The letter is attached as Exhibit I. 
The letter describes an agreement in which compensation would be made victims of Epstein's 
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20 
sexual abuse. The letter also said that the federal government was going to "defer federal 
prosecution." No one had told me about deferring federal prosecution before this. 
56. 
In 2011, two FBI agents, called m 
met me at the 
nd then came to meet me. They 
They seemed to be very professional and hard working. 
I thought to myself, "Wow, these people will do the right thing against the bad guys and protect 
me." 
57. 
The agents were mainly focused on Epstein but while there I provided them some 
information about others who were involved in illegal acts as well. I was aware that a false 
statement to these law enforcement officers was a crime and I told the truth — giving them the 
information that I could recall about the individuals they inquired about. 
58. 
Epstein also trafficked me for sexual purposes to many other powerful men, 
including politicians and powerful business executives. Epstein required me to describe the 
sexual events that I had with these men presumably so that he could potentially blackmail them. 
I am still very fearful of these men today. 
59. 
I will continue to cooperate fully in the investigation and prosecution of Epstein, 
Maxwell, or any of their friends who participated in the sexual abuse of minors. I also hope that 
this information is treated in a way that will keep me safe from Epstein and others criminals 
identified here so as to encourage more victims of similar crimes to come forward. If these 
crimes are not prosecuted, despite my volunteering this information and cooperation, then it may 
deter other similar victims from coming forward. 
60. 
In this affidavit, I have tried to focus on how I was trafficked for sexual purposes. 
I have not described all of the details of the sexual activities Epstein forced me to have. Also, I 
have not described all of the details of the other events discussed here. If a judge wants me to 
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20 
present my information in more detail, including more specific descriptions of the sexual 
activities with the men Epstein sent me to. I could do so. 
61. 
I have directed my attorneys. Bradley J. Edwards and Paul G. Cassell, to pursue 
all reasonable and legitimate means to have criminal charges brought against these powerful 
people for the crimes they have committed against me and other girls. They are representing me 
in this case pro bono. 
62. 
Since I filed my motion in this case. my credibility has been attacked. I am telling 
the truth and will not let these attacks prevent me from exposing the truth of how I was trafficked 
for sex to many powerful people. These powerful people seem to think that they don't have to 
follow the same rules as everyone else. That is wrong. I hope that by coming forward, I can 
help expose the problem of sex trafficking and prevent the same sort of abuse and degradation 
that happened to me from happening to other girls. 
63. 
I declare under penalty of perjury that the foregoing is true and correct. 
Executed this  (l ily  of January. 2015. 
(Location of signature left undisclosed for security reasons) 
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EXHIBIT 1 
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20 
U.S. Departme:ral oCatistice 
United States Attorney 
Southern District of Florida 
300 South Australian Ave.. Suite 400 
West Point Reach, FL 33401 
(561)8204711 
Facsimile: (561) 820-8777 
September 3, 2008 
NOTIFICATION OF *IDENTIFIED VICTIM 
NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED 
STATES CODE, SECTION 3509(d) AND FLORIDA LAW, 
THE ATTACHED DOCUMENT IS TO BE TREATED AS 
CONFIDENTIAL AND SHALL NOT BE DISCLOSED 
EXCEPT IN CONNECTION 
WITH 
A 
LEGAL 
PROCEEDING. 
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