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FBI VOL00009
EFTA00171911
56 sivua
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED. STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x SEALED INDICTMENT 19 Cr. 1 9 CREW 4910 COUNT ONE (Sex Trafficking Conspiraby) The Grand Jury charges: OVERVIEW 1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and• abused dozens of minor girls at his homes in Manhattan, New York, and Palm Beach, Florida, among other locations. 2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. Moreover, and in order to maintain and increase his supply of victims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In USAO 004341 EFTA_00022251 EFTA00171931
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this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in. locations including New York and Palm Beach. 3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age. • 4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with, others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence. FACTUAL BACKGROUND 5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental united States, including the New York Residence and the Palm Beach Residence. 6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and 2 USAO 004342 EFTA_00022252 EFTA00171932
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recruited, dozens of minor girls to engage in sex acts with him, after which EPSTEIN paid the victims hundreds of dollars in cash, at the New York Residence and the Palm Beach Residence. 7. In both New York and Florida, JEFFREY EPSTEIN, the defendant, 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. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. Moreover, EPSTEIN actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN. In so doing, EPSTEIN maintained a steady supply of new victims to exploit. The New York Residence 8. At all times relevant to this Indictment, JEFFREY EPSTEIN, the defendant, possessed and controlled a multi-story private residence on the Upper East Side of Manhattan, New York, i.e., the New York Residence. Between at least in or about 2002 and in or about 2005, EPSTEIN abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him. 3 USA() 004343 EFTA_00022253 EFTA00171933
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9. When a victim arrived at the New York Residence, she typically would be escorted to a room with a massage table, • where she would perform a massage on JEFFREY EPSTEIN, the defendant. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. 10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter. 11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Further, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed 4 USAO 004344 EFTA_00022254 EFTA00171934
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employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter. In
addition, certain victim-recruiters routinely scheduled these
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encounters through Employee-1, who sometimes asked the
recruiters to bring a specific minor girl for EPSTEIN.
The Palm Beach Residence
14. In addition to recruiting and abusing miner girls
in New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence. EPSTEIN frequently
traveled from New York to Palm Beach by private jet, before
which an employee or associate would ensure that minor victims
were available for encounters upon his arrival in Florida.
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants ("Employee-2" and'
"Employee-3") who, as described herein, were also responsible
for scheduling sexual encounters with minor victims. Once
inside, the victim would provide a nude or semi-nude massage for
EPSTEIN, who would himself typically be naked. During these
encounters, EPSTEIN would escalate, the nature and scope of the
physical contact to include sex acts such as groping and direct
and indirect contact with the victim's genitals. EPSTEIN would
also typically masturbate during these encounters, ask victims
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to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. 16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars for each encounter. . 17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional 'occasions. 18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters. 7 USAO 004347 EFTA_00022257 EFTA00171937
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19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victim- recruiters for each additional girl they brought to the Palm Beach Residence. STATUTORY ALLEGATIONS 20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section. 1591(a) and (b). 21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a 8 USAO 004348 EFTA_00022258 EFTA00171938
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commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2). Overt Acts 22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter. b. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully. c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed 9 USA() 004349 EFTA_00022259 EFTA00171939
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a telephone call to Minor Victim-1.in order to schedule an appointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN. d. In or about 2004, Minor Victim-2 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars after each encounter. EPSTEIN also encouraged and enticed Minor Victim-2 to recruit other girls to engage in paid sex acts, which she did. e. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-2 in order to schedule an appointment for Minor Victim-2 to engage in paid sex acts with EPSTEIN. f. In or about 2005, Minor Victim-3 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars for each encounter. _EPSTEIN also encouraged and enticed Minor Victim-3 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-3 how old she was, and Minor Victim-3 answered truthfully. 10 USFOD 004350 EFTA_00022260 EFTA00171940
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g• In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN. h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with' EPSTEIN. (Title 18, United States Code, Section 371.) COUNT TWO (Sex Trafficking) The Grand Jury further charges: 23. The allegations contained in paragraphs'l through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within. 24. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the.age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous 11 USAO 004351 EFTA_00022261 EFTA00171941
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individuals who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York. (Title 18, United States Code, Sections 1591(a), (b)(2), and 2.) FORFEITURE ALLEGATIONS 25. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property: a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc. 12 USAO 004352 EFTA_00022262 EFTA00171942
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Substitute Asset Provision 26. If any of the above-described forfeitable property, as a result of any act or omission of the defendant: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third person; (c) has been placed beyond the jurisdiction of the Court; (d), has been substantially diminished in value; or (e) has been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, pursuant to 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property. (Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28, United States Code, Section 2461.) EPERSON GEOFFREY S. BERMAN United States Attorney 13 . USAO 004353 EFTA_00022263 EFTA00171943
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Form No. USA-33s-274 (Ed. 9-25-58) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v . JEFFREY EPSTEIN, Defendant. 'INDICTMENT (18 U.S.C. §S 371, 1591(a), (b)(2), and 2) GEOFFREY S. BERMAN United States Attorney 14 USAO 004354 EFTA_00022264 EFTA00171944
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EXHIBIT B 2017.08.02 USAO_004355 EFTA_00022265 EFTA00171945
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Mod AO 442 (09113) Arrest Wanarrt AUSA Name & Telno: isJlson Moe, 212-637-2225 UNITED STATES DISTRICT COURT for the Southern District of New York United States of America v. Case No. Jeffrey Epstein Deeendant To: Any authorized law enforcement officer 19CEN 490 ARREST WARRANT YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay (name °Jaen»), to be arrested) Jeffrey Epstein who is accused of an offense or violation based on the following document filed with the court Indictment 0 Superseding Indictment Cl Information 0 Superseding Information 0 Complaint 0 Fibbed= Violation Petition CI Supervised Release Violation Petition °Violation Notice CI Order of the Court This offense is briefly deathbed as follows: . Title 18, United States Code, Section 371 (sex trafficking conspiracy) Title 18, Linked States Code, Sections 1591(a), (b)(2), and (2) (sex trafficking of minors) • %owl'', %il l ' /,, ,''r, 41/4. ; '4",f •' •• Date: 07/0212019 City and state: New York, NY ':'•,. 15, ; • ' • : t The Honorable Barbara Mosek,,U.B. taglWate Judge Printed name and title Bern This warrant was received on (date) , and the person was arrested on (elate) at (city and state) Date: 4Intabig qificeesslattalure Printed name and tale • USAO_004356 EFTA_00022266 EFTA00171946
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EXHIBIT C 2017.08.02 USAO_004357 EFTA_00022267 EFTA00171947
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AO 93 (SDNY Rut 01/17) Sarah cod Seiture Werrart ra. UNITED STATES DISTRICT COURT for the Southern District of New York In the Matter of the Search of (Brie describe the properly to be searched or klent(5, the penon by name and address) See Attachment A Case No. SEARCH AND SEIZURE WARRANT To: Any authorized law enforcement officer An application by a federal law enforcement officer or an attorney for the government requests the search of the following person or property located in the Southern District of New York (Ident(, the person or describe the property to be searched and give its location): See Attachment A The person or property to be searched, described above, is believed to conceal (Went& the person or describe the property to be seised): . See Attachment A The search and seizure are related to violation(s) of (insert statutory citations): Title 18, United States Code, Sections 371 and 1591 I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the perion or propertY. YOU ARE COMMANDED to execute this warrant on or before 7-40 lci ow to *wed 14 days) e in the daytime 6:00 to 10 M. Cl at any time in the day or night as I find reasonable cause has been established. Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the property was taken. The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court O Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. USW Initials O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate bos) Ofor days (not to exceed 30). Otmtil, the facts justifying, specific date of Date and time issued: - ‘O1AA ek:1A. City and state: New York, NY .hedge's signabere Hon. Barbara Moses, U.S. Magistrate Judge Printed name and title USAO 004358 EFTA_00022268 EFTA00171948
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AO 93 (SONY Rev. 01/17)Se:itch and Seine Warrant (Pago 2) Return Case No.: Date and time warrant executed: Copy of warrant and inventory left with: Inventory made in the presence of: Inventory of the property taken and name of any person(s) seized: Certification I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to tho Court. Date: Executing rates signal= Printed name and title USAO 004359 EFTA_00022269 EFTA00171949
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ATTACHMENT A L Premises to be Searched—Subject Premises 1. The premises to be searched (the "Subject Premises") are described as a nearly 19,000.square foot multi-story single-family residence located at 9 East 71st Street, New York, New York, and include all locked and closed containers found therein. A photograph of the front entrance to the Subject Premises is included below: IL Items to Be Seized 1. This warrant authorizes executing agents to photograph, video record and otherwise document the full interior of the Subject Premises, including any items, furnishings, or possessions therein. • • 2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sox trafficking of minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: a. Evidence concerning occupancy or ownership of the Subject Premises, including utility and telephone bills, mail envelopes, addressed correspondence, diaries, statements, identification documents, address books, telephone directories, and photographs of its occupant(s). b. Evidence concerning the layout, furnishings, decorations, and floor pattern of the Subject Premises, including photographs and blueprints of the Subject Premises. 2017.08.02 USAO_004360 • EFTA_00022270 EFTA00171950