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FBI VOL00009
EFTA00182748
256 sivua
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18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 15 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 37. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 38. From in or around July 2004 through in or around October 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #8, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 16 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 39. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 40. From in or around July 2004 through on or around December 29, 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, 39 EFTA00182928
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JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #9, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 17 (Enticement of a Minor: 18 U.S.C. § 2422(0) 41. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 42. From in or around July 2004 through on or about January 31, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #10, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. 40 EFTA00182929
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COUNT 18 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 43. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 44. From in or around the middle of 2004 through in or about March 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #11, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 19 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 45. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 46. From in or around the middle of 2004 through on or about April 22, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and 41 EFTA00182930
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did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #12, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 20 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 47. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 48. From in or around August 2004 through on or about May 27, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #13, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 21 (Enticement of a Minor: 18 U.S.C. § 2422(0)) 49. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 42 EFTA00182931
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50. From in or around November 2004 through in or around March 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and , a/k/a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #14, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 22 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 51. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 52. From in or around December 2004 through on or about June 5, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a/lc/a did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #15, who was a person who had not attained the age 43 EFTA00182932
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of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 23 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 53. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 54. From in or around February 2005 through in or around the first week of October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, ,, and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce or entice Jane Doe #16, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 24 (Enticement of a Minor: 18 U.S.C. § 2422(b)) 55. Paragraphs I through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 44 EFTA00182933
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56. From in or around February 2005 through in or around April 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and a/k/a ' ft did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #17, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 25 (Enticement of a Minor: 18 U.S.C. § 242200) 57. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 58. From in or around August 2003 through in or around February 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants, JEFFREY EPSTEIN, and did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #18, who was a person who had not attained the age 45 EFTA00182934
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of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2. COUNT 26 (Conspiracy to Travel: 18 U.S.C. § 2423(e)) 59. Paragraphs 1 through 23 of this indictment are re-alleged and incorporated by reference as fully set for the herein. 60. From at least as early as 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, the Defendants, JEFFREY EPSTEIN, a/k/a ' " and did knowingly and willfully conspire with each other and with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(1), with another person, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e). COUNT 27 (Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d)) 61. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 62. From at least as early as in or about 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendant, 46 EFTA00182935
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did, for the purpose of commercial advantage or private financial gain, arrange and facilitate the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d). COUNTS 28 THROUGH 35 (Travel to Engage in Illicit Sexual Conduct: 18 U.S.C. § 2423(b)) 63. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 64. On or about the dates enumerated as to each count listed below, from a place outside the Southern District of Florida to a place inside the Southern District of Florida, the Defendants listed below traveled in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in 18 U.S.C. § 2423(f), with a person under 18 years of age, that is, the person(s) listed in each count below: Count Date Minor(s) Involved Defendants 28 7/16/2004 Jane Doe V Jane Doe #8 Jane Doe #9 Jane Doe #10 JEFFREY EPSTEIN 29 8/6/04 Jane Doe #9 Jane Doe #11 JEFFREY EPSTEIN 30 8/19/04 Jane Doe #9 Jane Doe #10 Jane Doe #11 JEFFREY EPSTEIN 47 EFTA00182936
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Count Date Minor(s) Involved Defendants 31 10/29/04 Jane Doe #10 Jane Doe #11 Jane Doe #13 JEFFREY EPSTEIN 32 2/21/05 Jane Doe #11 Jane Doe #14 Jane Doe #15 JEFFREY EPSTEIN a/k/a ' 33 3/31/2005 Jane Doe #11 Jane Doe #14 Jane Doe #15 Jane Doe #16 JEFFREY EPSTEIN a/k/a ' 34 9/18/2005 Jane Doe #16 JEFFREY EPSTEIN ii/k/a ' 35 9/29/05 Jane Doe #16 JEFFREY EPSTEIN a/k/a ' All in violation of Title 18, United States Code, Sections 2423(b) and 2. FORFEITURE 1 Upon conviction of the violation alleged in Count 1 of this indictment, the defendants, JEFFREY EPSTEIN, a/k/r "and shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. 48 EFTA00182937
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Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21, United States Code, Section 853. If the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, ailda " and (1) (2) (3) (4) (5) difficulty; it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendants up to the value of the above forfeitable property. All pursuant to Title ited States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Titl 21)U ted States Code, Section 853. FO EITURE 2 Upon conviction of any of the violations alleged in Counts 13-35 of this indictment, cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with a third person; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or has been commingled with other property which cannot be subdivided without the defendants, JEFFREY EPSTEIN, n and anda shall forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other proceeds obtained from such 49 EFTA00182938
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offense; and any property, real or personal, used or intended to be used to commit or to promote the commission of such offense, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 2253. If any of the forfeitable property described in the forfeiture section of this indictment, as a result of any act or omission of the defendants JEFFREY EPSTEIN, a/k/a " and cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third person; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or 50 EFTA00182939
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(e) has been commingled with other property which cannot be divided without difficulty; it is the intent of the United States, pursuant to Title 18, United States Code, Section 2253(o), to seek forfeiture of any other property of said defendant up to the value of the above forfeitable property. Pursuant to Title 18, United States Code, Section 2253. FORFEITURE 3 Upon conviction of any of the violations alleged in Counts 2-12 of this indictment, the defendants, JEFFREY EPSTEIN, n and a/k/a `M shall forfeit to the United States any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such violation; and any property, real or personal, constituting or derived from any proceeds that such person obtained, directly or indirectly, as a result of such violation, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the 51 EFTA00182940
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West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 1594(b). A TRUE BILL. FOREPERSON - Th YaMEIC7cCOST4 UNITED STATES ATTORNEY ASSISTANT UNITED STATES ATTORNEY 52 EFTA00182941
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INDICTMENT SUMMARY CT DATE(S) kEFENDANT(S) VICTIM(S) STATUTES/CHARGE 1 2001 - October 2005 NEPSTEIN Jane Does 1-19 18 U.S.C. §§ 371 and 2 Conspiracy to use a facility or means of interstate commerce to persuade, induce, or entice minors to engage in prostitution or any sexual activity for which any person can be charged with a criminal offense 2 2001 - 2004 ,\EPSTE1N Jane Doe #2 18 U.S.C. §§ 1591(a)(1) and 2 (Carolyn A.) Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 4 3 January 2004 - Jane Doe #4 18 U.S.C. §§ 1591(a)(1) and 2 July 2004 . 11 1 1 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 4 July 2004 - \EPSTEIN Jane Doe #9 18 U.S.C. §§ 1591(a)(1) and 2 December 29, 2004 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. Page 1 of 9 EFTA00182942
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CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 5 July 2004 - January 31, 2005 EPSTEIN t Jane Doe #10 18 U.S.C. §§ 1591(a)(1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 6 Mid-2004 - April 22, 2005 NIPSTEIN a Jane Doe #12 18 U.S.C. §§ 1591(a)(1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 7 Mid-2004 - April 22, 2005 i lc r IEIN Jane Doe #12 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 8 August 2004 - May 27, 2005 \ tPSTEIN Jane Doe #13 18 U.S.C. §§ 1591(a)(1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. Page 2 of 9 EFTA00182943
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CT DATE(S) DEFENDANT(S) VICTIM(S) STATUTES/CHARGE 9 November 2004 - March 2005 --a N EPSTEIN ..NEPSTEIN Jane Doe #14 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 10 December 2004 - June 5, 2005 Jane Doe #15 18 U.S.C. §§ 1591(aX1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 11 February 2005 - October 2005 \EPSTEIN Jane Doe #16 18 U.S.C. §§ 1591(a)(1) and 2 Knowingly, in or affecting interstate or foreign commerce, recruiting, enticing, providing, and obtaining by any means a person, knowing that the person was a minor and would be caused to engage in a commercial sex act. 12 2001 - October 2005 Jane Does 1-19 18 U.S.C. § 1591(aX2) Benefitting, financially or by receiving any thing of value, from participation in a venture which had engaged in the recruiting, enticing, providing, or obtaining by any means a person, knowing that the person or persons had not attained the age of 18 years and would be caused to engage in a commercial sex act Page 3 of 9 EFTA00182944
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CT DATE(S) FENDANT(S) VICTIM(S) STATUTES/CHARGE 13 Spring 2003 - October 2, 2005 \EPSTEIN Jane Doe #3 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 14 July 2004 N.E.PS;;EIN %\ P Jane Doe #7 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 15 July 2004 to October 2004 STEIN Jane Doe #8 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 16 July 2004 - December 29, 2004 \S TEIN Jane Doe #9 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense Page 4 of 9 EFTA00182945
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CT DATE(S) EFENDANT(S) VICTIMS) STATUTES/CHARGE 17 July 2004 - January 31, 2005 IN \ EPSTEIN Jane Doe #10 18 U.S.C. §§ 2422(6) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 18 Mid-2004 - March 2005 Jane Doe #11 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 19 Mid-2004 - April 22, 2005 • STEIN \ Jane Doe #12 18 U.S.C. §§ 2422(6) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 20 August 2004 - May 27, 2005 ii iel s1 Jane Doe #13 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense Page 5 of 9 EFTA00182946
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CT DATE(S) DFENDANT(S) VICTIM(S) STATUTES/CHARGE 21 November 2004 - March 2005 IIPSTEIN Jane Doe #14 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 22 December 2004 - June 5, 2005 . 'N PSTEIN Jane Doe #15 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 23 February 2005 - October 2005 ItPSTEIN Jane Doe #16 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense 24 February 2005 - April 2005 \STEIN Jane Doe #17 18 U.S.C. §§ 2422(b) and 2 Using a facility or means of interstate commerce to knowingly persuade, induce, or entice a person who had not attained the age of 18 years to engage in prostitution or sexual activity for which any person can be charged with a criminal offense Page 6 of 9 EFTA00182947