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FBI VOL00009
EFTA00229861
45 sivua
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. On or about March 30, 2005, caused one or more calls to be made to a telephone used by Jane Doe #1. . On or about March 31, 2005, caused one or more calls to be made to a telephone used by Jane Doe #1. # . On or about March 31, 2005, EPSTEIN traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned b Defendant JEGE, INC. . On or about March 31, 2005, EPSTEIN and caused Jane Doe #1 to make a call to a telephone used by Jane Doe #2. # . On or about April 1, 2005, EPSTEIN and caused Jane Doe #1 to make one or more calls to a telephone used by Jane Doe #2. 3. Substantive Counts related to Jane Doe #2 Count Date(s) Offense Statute Defendant(s) 6 2/5/05-2/6/05 Use of cellular phone to persuade, induce, or entice JD#2 to engage in sexual activity or prostitution 2422(b) EPSTEIN 43 3/31/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE, INC. 60 3/30/05-4/1/05 Attempted use of cellular phone to persuade, induce, or entice S.G. to engage in sexual activity or prostitution 2422(b) EPSTEIN I did not charge EPSTEIN with traveling on February 3, 2005 from New York to Palm Beach based upon conduct with Jane Doe #2 because he traveled to Palm Beach prior to the appointment being made with Jane Doe #2. I charged the travel on March 31, 2005, even though Jane Doe #2 never went to EPSTEIN's house because at the time of his travel, EPSTEIN intended for Jane Doe #2 to come to the house. See United States v. Han , 230 F.3d 560 (2d Cir. 2000) (defendant could be convicted of violating Section 2423(b) even though no sexual activity occurred and "minor" was really an undercover officer because the defendant had formed the necessary intent by developing a plan to cross state lines to engage in sexual acts with the minor). 3. Possible Credibility Challenges Jane Doe #2 has been the focus of Epstein's attorneys because she was the youngest girl and the one who brought Epstein's activities to light. Copies of a MySpace page credited to Jane Doe #2 were provided to the State Attorney's Office and to our office. On that page, Jane Doe #2 states that she is 21 years' old, she drinks and has taken drugs, she shoplifts, and she earns $250,000 each year. The MySpace page also shows a picture of Jane Doe #2 wrestling with her boyfriend and a photograph of a naked girl lying on a beach. Copies of those materials are attached hereto. During her first sessions with the police, she also minimized what happened with Epstein, denying that he touched her. With respect to the minimization of the conduct, we have secured two experts in these types of cases, who will explain how child victims of sexual abuse minimize what happened to them until they feel more secure about the interviewer. In addition, there is the prior consistent statement that JD#2 made to JD#1 while they were in the car driving away from Epstein's home. With respect to the MySpace page, JD#2 says that it is inaccurate. When she was confronted with the page before the state grand jury, she denied putting certain items on the page. When we met with her, she again said that she did not remember putting certain things on the page and she believed that it wasn't her page. After that meeting, we tried to determine whether JD#2 was telling the truth and EFTA00229881
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that someone really had doctored her page. We were able to determine that the page was created on a single day and had never been accessed since the date of its creation. Some of the information was identical to JD#2's "active" MySpace page, and other parts were different. Unfortunately, because of the passage of time, the ISP no longer had information about the specific IP address used to create the page, so we could not trace the creation back to a particular persons address. Assuming that JD#2 really did create the MySpace page and simply forgot about it, in my opinion, most of the information that they are focused on doesn't really undermine JD#2's credibility in this case. MySpace pages are notorious for "puffing," so of course JD#2 claimed that she was 18 and made $250,000 — no one would believe the truth of those statements. Certainly Epstein never visited the site before sexually molesting JD#2, so he did not rely upon the claim that JD#2 was 18 when he decided to digitally penetrate her. JD#2 admittedly drank and was sexually active with her boyfriend. If JD#2 were not a person who engaged in these types of activities, JD#1 wouldn't have approached JD#2 to recruit her to give a sexual massage to Epstein. The photograph of the nude girl on the beach is obviously a picture that was digitally created (there is a cruise ship headed directly towards the girl on the beach) and is obviously not .I Ur:?. C. Jane Doe #3 - (=l) Jane Doe #3 also attended Royal Palm Beach High School with Jane Doe #1 and JD#1 recruited her to go to Epstein's home to perform a sexual massage. JD#3 was in her sophomore or junior year of high school. JD#1 told JD#3 that she could make $200 for massaging Epstein. JD#1 drove JD#3 to Epstein's house and told her that Epstein may ask her to take her top off and may try to touch her, but she could tell him if she felt uncomfortable. JD#1 also instructed JD#3 to tell Epstein that she was 18, if he asked. When they arrived at Epstein's house, they entered through the kitchen, and they were met by escorted JD#1 and JD#3 upstairs to the dressing area and helped them set up the massage table, select the lotions, and obtain towels. then left the room. Epstein entered and introduced himself. Epstein and JD#1 then stepped outside for a moment and only Epstein returned. Epstein removed his clothing and laid down on his stomach. During the massage, Epstein repeatedly grabbed and pulled at JD#3 to get her closer to him so he could fondle her. At the end of the massage, Epstein paid JD#3 $200 and asked for her telephone number. JD#1 also received $200 for bringing her. A short time later, called JD#3 and left a message asking her to perform another massage. Jane Doe #1 made arrangements for JD#3 to return for a second massage. During the second visit, JD#1 and JD#3 again entered through the kitchen, where they were greeted by Epstein. Epstein led JD#3 upstairs, leaving JD#1 in the kitchen. During the massage, Epstein was on the telephone, and no sexual activity took place. Both JD#1 and JD#3 received $200. JD#3 did not remove her clothing during either of these sessions. JD#3 did not return to Epstein's residence for several months because she and JD#1 had gotten into an argument. We do not know the exact date when JD#3 returned to Epstein's home, but we know that it was at least by December 3, 2004, because on that date, JD#3 received a call directly from . After that break in time, JD#3 started going to Epstein's home on a regular basis. Each time she removed more and more clothing, at Epstein's request. JD#3 also explains that Epstein pushed at every session for more sexual activity. Epstein would masturbate during virtually every session, and would ask JD#3 to pinch his nipples. Epstein would pinch JD#3's nipples, and rub her vagina. On several occasions, Epstein digitally penetrated JD#3, he also used a large vibrator/back massager on JD#3's vagina. Epstein asked JD#3 to straddle him naked while he was lying on his back. Epstein then reached through her legs to masturbate himself. Epstein tried to rub his penis against JD#3's vagina but never penetrated her. JD#3 stated that she was usually contacted by MI, via her cellular phone, to set up appointments. would sometimes call from New York or the U.S. Virgin Islands stating, "we will be coming into town, can you work?" Sometimes would call when they already were in town EFTA00229882
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asking if JD#3 was able to work the same day or the following day. sometimes made appointments before Epstein left town for the next time that they would be in town. On several occasions, made the appointments with JD#3. Epstein gave JD#3 three Victoria's Secret bra and panty sets and gave her a "Pocket Rocket" vibrator for her 18th birthday. 1. Overt Acts Based Upon Active with Jane Doe #3 #. On or about December 6, 2004, Defendant caused one or more telephone calls to be made to Jane Doe #3. #. On or about December 12, 2004, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about December 13, 2004, Defendant EPSTEIN traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about December 14, 2004, Defendant made one or more telephone calls to Jane Doe #3. #. On or about December 20, 2004, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about January 6, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about January 6, 2005, Defendant EPSTEIN traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about January 14, 2005, Defendant made one or more telephone calls to Jane Doe #3. #. On or about January 14, 2005, Defendants EPSTEIN, a and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about February 3, 2005, Defendants EPSTEIN, and traveled from Columbus, Ohio to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about February 4, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about February 10, 2005, Defendants EPSTEIN, a and traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about February 10, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about February 21, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about February 21, 2005, Defendants EPSTEIN, , and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about February 24, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about February 24, 2005, Defendants EPSTEIN, , and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about March 17, 2007, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. EFTA00229883
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#. On or about March 18, 2005, Defendant EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about March 30, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about March 31, 2005, Defendant EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about April 8, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about April 8, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about April 26, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about April 27, 2005, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about May 6, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about May 19, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #3. #. On or about May 19, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 2. Substantive Counts related to Jane Doe #3 Count Date(s) Offense Statute Defendant(s) 7 12/6/04- 6/2/05 Use of cellular phone to persuade, induce, or entice Jane Doe #3 to engage in prostitution 2422(b) EPSTEIN 32 12/13/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 35 I 6/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 36 1/14/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 2/3/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 38 2/10/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE EFTA00229884
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39 2/21/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 40 2/24/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 42 3/18/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 43 3/31/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 44 4/8/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 45 4/27/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 46 5/6/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 47 5/19/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 51 12/6/04- 6/2/05 Recruiting, enticing, providing, or obtaining by any means a person knowing that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act. 1591(a)(1) EPSTEIN Jane Doe #3 never told her age to Epstein, but she also never told him that she was 18. They discussed her high school soccer games and her plans to attend college in the future. In addition, as discussed below, Jane Doe #4 was a close friend of JD#3 and they often went to Epstein's house together. Jane Doe #4 told Epstein that she and JD#3 went to the same school and were in the same class, and JD#4 told Epstein that she was a junior. There also is evidence that Epstein gave JD#3 a vibrator for her 18th birthday, knowing that it was her 18th birthday and offered to fly JD#3 to his home in the Virgin Islands after she was 18. With respect to the enticement charge and the human trafficking charge, I included and because of the number of calls that they were involved with. There were a total of 156 calls between and JD#3, and there were 28 calls between and JD#3. Although was aboard the plane during several trips, there is no evidence that she ever had contact with JD#3 or arranged for JD#3 to engage in sexual activity with Epstein; thus, I have not charged her in connection with any of this activity. Rather than try to parse out each instance where JD#3 was enticed, I elected to EFTA00229885
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charge the enticement and sex trafficking offenses over the ran e of dates representing the first telephone call from to JD#3 until the last call from before JD#3's 18th birthday (the activity with Epstein continued thereafter, but at that point it is beyond our jurisdiction to prosecute). The proper unit for charging the travel offense is each trip, so I have charged the trips where or spoke with JD#3 shortly before E stein traveled, again stopping at the point that JD#3 turned 18. D. Jane Doe #4 - Jane Doe #4 also was recruited by Jane Doe #1 and was a student at Royal Palm Beach High School. Jane Doe #4 received approximately 60 calls from during the period of April 25, 2004 (when she was 16) through October 6, 2005 (when she was 18). JD#4 states that she performed only a few sexual massages, although that is belied by the number of telephone calls. JD#4 reports that she performed the sexual massages while wearing her bra and panties. During the sessions, Epstein pulled JD#4's bra down and grabbed her breast. Epstein tried to touch JD#4's vagina and grabbed her butt. Epstein masturbated during the sessions and he instructed JD#4 to pinch his nipples while he masturbated. Epstein told JD#4 to take her clothes off and that she could make more money if she would do more (engage in more sexual activity). Epstein constantly pushed for JD#4 to become more sexual, asking her if she had sex with her boyfriend and if she liked sex. JD#4 was .200 for each sexual massage that she performed, and she received the payments from Epstein and . Epstein also told JD#4 that she could make more money if she "brought her pretty friends" to perform sexual massa es. Epstein told JD#4 that the girls that she brought should know what to expect when they arrive. also asked JD#4 to bring more girls. JD#4 brought at least two more girls to Epstein's home. She was aid $200 for each girl whom she brought. and made the appointments with JD#4. JD#4 told Epstein that she was a junior at Royal Palm Beach High School, so there is evidence that Epstein knew that JD#4 was under 18. 1. Overt Acts Basediactivity with Jane Doe #4 4. On April 25, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 5. On May 1, 2004, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. 6. On May 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 7. On May 14, 2004, Defendants EPSTEIN, and traveled from CYQX to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. 8. On May 14, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 9. On May 20, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 10. On May 21, 2004, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 11. On June 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 12. On June 4, 2004, Defendants EPSTEIN and traveled from New Haven, Connecticut to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 13. On June 11, 2004, Defendants EPSTEIN and traveled from Chicago, Illinois to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, EFTA00229886
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INC. 14. On June 11, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 15. On June 20, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 16. On June 20, 2004, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeini 727 aircraft owned by Defendant JEGE, INC. 17. On July 4, 2004, Defendants EPSTEIN, and traveled from Aspen, Colorado to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. 19. On July 10, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 24. On July 18, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 25. On July 22, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 28. On August 4, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 35. On August 25, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 40. On October 2, 2004, Defendants EPSTEIN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. 41. On October 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 45. On October 30, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 46. On November 4, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 81 On January 4, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 92. On January 22, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 113. On February 14, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 118. On February 24, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 129. On March 18, 2005, Defendant prepared a written message to Defendant EPSTEIN regarding Jane Doe #4. 132. On March 29, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 144. On April 11, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #4. 2 Substantive Offenses Count Date(s) Offense Statute Defendant(s) 8 4/25/04- 6/29/05 M Use of cellular phone to persuade, induce, or entice Jane Doe #4 to engage in prostitution 2422(b) EPSTEIN EFTA00229887
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17 5121104 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 18 6/4/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 19 6/20/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 22 7/22/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 23 8/6/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 28 11/5/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 35 1/6/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 40 2/24/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 43 3/31/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE #52 4/25/04- 6/29/05 Recruiting, enticing, providing, or obtaining by any means a person knowing that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act. 1591(a)(1) EPSTEIN E. Jane Doe #5 ( .) - Jane Doe #5 also attended Royal Palm Beach High School. She was recruited to give sexual massages to Epstein in the fall of 2004, when she was 17 years' old. She was recruited indirectly by Jane Doe #4. Jane Doe #5 reported that she entered the home through the kitchen and was introduced to brought JD#5 upstairs to the dressing area, where she met Epstein. JD#5 performed multiple sexual massages for Epstein. During the first massage, Epstein asked JD#5 how old she was and she EFTA00229888
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said that she was 18. During that massage, she removed her clothes, and he masturbated. JD#5 also describes how Epstein would verbally push her to engage in more and more sexual activity. JD#5 states that Epstein began fondling her vagina and digitally penetrating her, and the activity escalated to full sexual intercourse in his bedroom. Epstein asked JD#5 to straddle him and pinch his nipples while he reached through her legs to masturbate himself. He used the vibrator/massager on her vagina. When JD#5 told Epstein that she didn't like it, he responded that she was "scared to have pleasure." Epstein digitally penetrated her and performed oral sex on her. JD#5 was paid $300 during her visits to Epstein's home. On one occasion she received $500 and on another occasion she received $600. Epstein always paid her except for one occasion when he didn't have any cash. Epstein then asked one of his employees to pay her. (This is consistent with the record of a payment by the house manager to JD#5.) JD#5 received a $200 "Christmas present" via Western Union on December 23, 2004. Epstein offered her David Copperfield tickets and she spoke with Copperfield on the telephone. a l Around the third or fourth visit, Epstein began asking JD#5 about plans for her 18th birthday, and he said to her, "So you're really not eighteen." JD#5 states that they laughed a little and continued with the session. JD#5 received 31 calls from and 15 calls from . JD#5 states that she received the payments from Epstein. JD#5 says that Epstein definitely knew her age. JD#5 could not drive, and Epstein provided her with a private car company that would pick her up and take her home after the sexual encounters. 1. Overt Acts Based upon Activi with Jane Doe #5 #. On or about November 17, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #5. #. On or about November 18, 2004, Defendants EPSTEIN, , and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about December 3, 2004, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about December 5, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about December 13, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about December 13, 2004, Defendant EPSTEIN traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about December 14, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about December 17, 2004, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about December 18, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about December 23, 2004, Defendant EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #5. #. On or about January 1, 2005, Defendant caused a telephone call to be made to a telephone used by Jane Doe #5. #. On or about January 1, 2005, Defendants EPSTEIN, and traveled from Anguilla, British West Indies to Palm Beach County, Florida aboard the Gulfstream aircraft owned EFTA00229889
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by Defendant HYPERION AIR, INC. #. On or about January 6, 2005, Defendant EPSTEIN traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by defendant HYPERION AIR, INC. #. On or about January 8, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about January 9, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about January 19, 2005, Defendants EPSTEIN, la , and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about January 26, 2005, Defendant reviewed a telephone message from Jane Doe #5. #. On or about February 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about February 3, 2005, Defendants EPSTEIN, and traveled from Columbus, Ohio to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about February 10, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about February 10, 2005, Defendants EPSTEIN, = and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about February 21, 2005, Defendants EPSTEIN, =, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about February 24, 2005, Defendants EPSTEIN, , and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On or about February 25, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about March 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about March 4, 2005, Defendants EPSTEIN, =, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about March 16, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. #. On or about March 18, 2005, Defendant EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On or about March 21, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #5. 2. Substantive Offenses related to Jane Doe #5 Count Date(s) Offense Statute Defendant(s) 9 11/14/04 - 3/29/05 Use of cellular phone to persuade, induce, or entice Jane Doe #5 to engage in prostitution 2422(b) EPSTEIN 30 11/18/04 Travel in interstate commerce with intent to engage in illicit sexual 2423(b) EPSTEIN EFTA00229890
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conduct HYPERION 31 12/3/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 32 12/13/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 34 I 1 05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 37 2/3/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 38 2/10/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 39 2/21/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 41 3/4/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 42 3/18/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 53 11/14/04 - 3/29/05 Recruiting, enticing, providing, or obtaining by any means a person knowing that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act. 1591(a)(1) EPSTEIN F. JANE DOE #6 - Jane Doe #6 also attended Royal Palm Beach High School. She was recruited by Jane Doe #17. F25 Jane Doe #6 was involved with Epstein for more than a year, and she recruited Jane Does #7 and #8. Jane Doe #6 is believed to be the girl who saw Epstein the most. She estimates that she saw him EFTA00229891
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hundreds of times. There are a proximately 22 calls between Jane Doe #6 and MI, 3 calls with and 1 call with JD#6 reported that Jane Doe #17 approached her one summer when she was working at the Wellington Mall. JD#6 said that she thought she was 16 or 17 years' old at the time. Her telephone contact with began in July 2004, so this probably was the summer of 2004 when JD#6 was 17 years' old. JD#17 told her that she could make $200 performing a massage, but she would have to perform the massage naked. JD#6 agreed to perform the massage, and JD#17 set it up for the same day. JD#6 remembered that it was a weekend because she only worked on weekends. JD#17 took JD#6 to Epstein's home where they entered through the kitchen and met led JD#6 upstairs, and JD#6 described the pictures of naked women on the walls and tables of the house. -F26 When they reached the dressing area, set up the massage table and selected the massage oils. Epstein entered the room and introduced himself. He lay face down on the massage table and JD#6 undressed except for her panties. JD#6 massaged Epstein's back and legs. He then turned over and began masturbating as she continued to massage him. Epstein fondled JD#6's breasts as he masturbated, and the massage ended when he ejaculated. JD#6 received $200 from Epstein as payment for that session. JD#17 also was paid, but JD#6 did not know how much. Epstein asked JD#6 to leave her telephone number. JD#6 wrote it down on a piece of stationery bearing Epstein's name. JD#6 described the escalation of sexual activity during the period that she knew Epstein. Epstein digitally penetrated JD#6, used the masse er/vibrator on her vagina, and performed oral sex on her. JD#6 described how Epstein brought into the activity. He instructed JD#6 to perform oral sex on . When JD#6 refused, Epstein promised an additional $200 if JD#6 would perform oral sex for five minutes. JD#6 agreed, and E stein masturbated while watching them. JD#6 said that various sex toys were used on her, including use of a strap-on dildo. JD#6 also said that Epstein forced her to have vaginal sex on one occasion when he became very excited. JD#6 screamed for him to stop. Epstein did so and apologized. JD#6 said that she received varying amounts of money for the sexual massages, depending on how much sexual activity took place, ranging from $300 to $1000 on the day that Epstein forced intercourse on her. Epstein asked JD#6 how old she was. JD#6 said that she was 18 and Epstein told her that he knew she was not 18. Epstein knew that she attended Royal Palm Beach High School. He sent roses to a high school play performance that JD#6 gave. They discussed JD#6's plans to attend college. JD#6 gave Epstein a copy of her transcript on three occasions. JD#6 believed that Epstein would help her get into NYU and that he would pay for her tuition there. Epstein also paid for a trip to New York for JD#6 for her 18th birthday. JD#6 went to Epstein's house to pick up an envelope of money to pay for the trip. Epstein also gave her tickets to the Phantom of the Opera in New York. Epstein did not accompany JD#6 on this trip. Epstein provided JD#6 with other gifts including a Louis Vuitton purse, a bathing suit, Victoria's Secret bra and panty sets, and cash gifts. JD#6 said that most of the time would call to set up the appointments for her to "work." would call from one day to several days in advance. Sometimes the appointments were made before Epstein arrived. Other times, would call when they were already in Palm Beach. JD#6 was shown a photo array containing photograph. She positively identified 1. Overt Acts Based u on Activity with Jane Doe #6 #. On July 15, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. #. On July 16, 2004, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. EFTA00229892
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#. On July 22, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6. #. On July 22, 2004, Defendants EPSTEIN, , and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On August 6, 2004, Defendants EPSTEIN and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft ownec ndant JEGE, INC. #. On August 19, 2004, Defendants EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On August 19, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. #. On August 25, 2004, Defendants EPSTEIN, , and traveled from Ecuador to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant JEGE, INC. #. On August 25, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6. #. On November 7, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6. #. On November 10, 2004, Defendants EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On November 10, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #6. #. On November 17, 2004, Defendant caused a telephone call to be made to a telephone used by Jane Doe #6. #. On November 18, 2004, Defendants EPSTEIN, = and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. #. On December 1, 2004, Defendant used by Jane Doe #6. #. On December 13, 2004, Defendant a telephone used by Jane Doe #6. #. On December 17, 2004, Defendant used by Jane Doe #6. #. On December 29, 2004, Defendant used by Jane Doe #6. 2. Substantive Offenses related to Jane Doe #6 caused a telephone call to be made to a telephone caused one or more telephone calls to be made to caused a telephone call to be made to a telephone caused a telephone call to be made to a telephone Count Date(s) Offense Statute Defendant(s) 10 7/15/04 - 12/29/04 Use of cellular phone to persuade, induce, or entice Jane Doe #6 to engage in prostitution 2422(b) EPSTEIN 21 7/16/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 22 7/22/04 Travel in interstate commerce with intent to engage in illicit sexual 2423(b) EPSTEIN EFTA00229893
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conduct JEGE _) 1 ' 8/6/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 24 8/19/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 25 8/25/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 29 11/10/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 30 11/18/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 31 12/3/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 32 12/13/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 33 12/17/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 54 7/15/04 - 12/29/04 Recruiting, enticing, providing, or obtaining by any means a person knowing that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act. 1591(a)(1) EPSTEIN G. JANE DOE #7 - Jane Doe #7 attended Lake Worth High School and was recruited by Jane Doe #6. She reports that she gave approximately 15 sexual massages (this number is probably low). There are approximately 115 telephone calls between Jane Doe #7 and M, approximately 7 calls with and approximately 14 calls with . Jane Doe #7's phone activity began on July 22, 2004, when she was 17 and continued past her 18th birthday. Jane Doe #7 states that she originally told Epstein that she was 18 but he found out that she wasn't and gave her 4 tickets to a David Copperfield show for her 18th birthday. EFTA00229894
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Jane Doe #7 reports that, in the spring of 2004, she was working at a store at the Wellington Mall with Jane Doe #6. Jane Doe #6 approached her and said that she could make extra money providing massages to Epstein - the massages may have to be given nude, but if Epstein asked her to do something, she could say no. Jane Doe #7 agreed and Jane Doe #6 made the appointment. On the first visit, Jane Doe #6 led Jane Doe #7 up to the dressing area. Epstein entered wearing only a towel, and he directed Jane Doe #6 to leave. He removed the towel and laid down. Epstein asked Jane Doe #7 to undress but she only removed her top. She was paid $200 and Epstein asked her for her phone number, which she provided. Epstein asked her about her plans to attend college in the future. On the third visit, Epstein again asked Jane Doe #7 to get undressed and she did. Jane Doe #7 says that from this point, each visit became more sexual and Epstein would try to go farther each time. Epstein placed his hand on Jane Doe #7's vagina and breasts while he masturbated; he also used the vibrator/massager on her va ina. E stein asked Jane Doe #7 to touch his penis - she said "no." On at least two occasions, was part of the activity. Epstein and performed sexual acts on each other, including oral sex. placed her hand on Jane Doe #7's vagina and used the vibrator/massager on Jane Doe #7's vagina. usually would call to set up the appointments prior to their trip to Florida. On two occasions, Epstein wired money to Jane Doe #7 when she was on vacation and had no funds to get home. Both of these wire transfers occurred after her 18th birthday. 1. Overt Acts based upon Active with Jane Doe #7 # _ . On July 16, 2004, Defendant caused Jane Doe # 6 to make one or more telephone calls to a telephone used by Jane Doe # 7. # _. On July 22, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On August 17, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On August 25, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On September 16, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On October 3, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On October 26, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On December 4, 2004, Defendant provided a written message to Defendant EPSTEIN regarding Jane Doe #6 and Jane Doe #7. # _. On December 16, 2004, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On January 1, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On January 14, 2005, Defendants EPSTEIN, =, and traveled from U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant, JEGE, INC. # _. On January 14, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On January 27, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. # _. On January 28, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #7. EFTA00229895
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# . On February 1, 2005, Defendant be made to a telephone used by Jane Doe #7. 2. Substantive Offenses Related to Jane Doe #7 caused one or more telephone calls to Count Date(s) Offense Statute Defendant(s) 11 7122104- 1/31/05 Use of cellular phone to persuade, induce, or entice Jane Doe #3 to engage in prostitution 2422(b) EPSTEIN 21 7/16/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 22 7/22/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 24 8/19/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 26 9116104 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN JEGE 27 10/29/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 33 12/17/04 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 34 1/1/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 55 7/22/04- 1/31/05 Recruiting, enticing, providing, or obtaining by any means a person knowing that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act. 1591(a)(1) EPSTEIN # 2/10/05 Transporting with 2421 EPSTEIN JEGE intent that she engage in criminal sexual activity EFTA00229896
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# 3/4/05 Transporting with 2421 EPSTEIN JEGE intent that she engage in criminal sexual activity # 5/6/05 Transporting with 2421 EPSTEIN HYPERION intent that she engage in criminal sexual activity H. JANE DOE #8 ( . ) Jane Doe # 8 attended Royal Palm Beach High School and was recruited by Jane Doe #6. She estimated that she started going to Epstein's house in November 2004, but phone calls with do not begin until February 2005. Jane Doe #6 approached her and asked if she wanted to make money massaging Epstein. Jane Doe #8 had heard of other girls at school making money that wa and she agreed to go to Epstein's house. Jane Doe #6 took her to the house and introduced her to and Epstein in the kitchen. Jane Doe #6 led her upstairs to the dressing area where the massage table was already set up. Jane Doe #6 left and Epstein entered wearing a towel. Epstein told her to undress and Jane Doe #8 performed the massage wearing only panties. Epstein masturbated until he ejaculated, which ended the massage. Jane Doe #8 received $200, so did Jane Doe #6. Jane Doe #8 estimates that she went to Epstein's home 10-15 times. Each time Epstein pushed for more sexual activity. Epstein fondled her buttocks and breasts and pulled her closed to him while he masturbated. Epstein used the large white vibrator/massager on her vagina. Epstein asked Jane Doe #8 to kiss and fondle while he masturbated. Epstein also had vaginal intercourse with Jane Doe #8 on one occasion, for which he paid $350. Jane Doe #8 would receive calls from and to arrange appointments to "work" which meant to give a sexual massage. Sometimes appointments were made before they arrived; other time the appointments were made when Epstein was already in town. Jane Doe #8 told Epstein that she was 17 on her first visit. A few days before her 18th birthday was the date when she and Epstein had vaginal intercourse. Epstein gave her 2 or 3 Victoria's Secret bra and panty sets for her birthday. Epstein also gave her an Olympus digital camera as a gift during their relationship. Jane Doe #8 recruited Jane Doe #9 and a non-minor female to go to Epstein's home. Jane Doe #8 is the basis for one count of the state indictment. Epstein's attorneys have accused her of lying and have made much of her MySpace page, which uses the profile name ' " Those materials are attached. Epstein's attorneys do not have a copy of Jane Doe #8's state grand jury testimony. During that testimony, Jane Doe #8 exhibited no hostility towards Epstein and said that she testified only because she was subpoenaed to appear. There area roximately 60 calls between Jane Doe #8 and and 14 calls between Jane Doe #8 and called Jane Doe #8 once. 1. Overt Acts Based u on Activity with Jane Doe #8 On February 25, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. On March 4, 2005, Defendants EPSTEIN, , and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant, JEGE, INC. On March 7, 2005, Defendant caused one ore more telephone calls to be made to a telephone used by Jane Doe #8. On March 31, 2005, Defendant EPSTEIN travels from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant, JEGE, INC. On April 2, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. On April 8, 2005, Defendants EPSTEIN, . and traveled from EFTA00229897
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Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On April 11, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. On May 19, 2005, Defendant caused one or more telephone calls to be made to a telephone used by Jane Doe #8. On May 19, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On June 8, 2005, Defendants EPSTEIN, and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant, JEGE, On June 12, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On June 18, 2005, Defendants EPSTEIN. , traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On June 20, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On June 30, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On June 30, 2005, Defendants EPSTEIN, S traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On July 2, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On July 22, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On July 22, 2005, Defendants EPSTEIN, , traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft ownecH dant HYPERION AIR, INC. On August 18, 2005, Defendants EPSTEIN, , and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On August 18, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On August 19, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On August 21, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On September 3, 2005, Defendants EPSTEIN, traveled from U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On September 3, 2005, Defendant caused one or more telephone calls to be made from Jane Doe #8 to defendant. On September 8, 2005, Defendant caused one or more telephone calls to be made from Jane Doe #8 to defendant. On September 9, 2005, Defendants EPSTEIN, and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. EFTA00229898
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On September 18, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On September 18, 2005, Defendants EPSTEIN, and traveled from Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On September 29, 2005, Defendant caused one or more telephone calls to be made to Jane Doe #8. On September 29, 2005, Defendants EPSTEIN, =, and Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Defendant HYPERION AIR, INC. On October 3, 2005, Defendant Doe #8. traveled from caused one or more telephone calls to be made to Jane 2. Substantive Counts related to Jane Doe #8 Count Date(s) Offense Statute Defendant(s) 12 2113105 - 10/3/05 Use of cellular phone to persuade, induce, or entice Jane Doe #3 to engage in prostitution 2422(b) EPSTEIN 47 5/19/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 48 6/30/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 49 9/9/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 50 9/18/05 Travel in interstate commerce with intent to engage in illicit sexual conduct 2423(b) EPSTEIN HYPERION 56 2/13/05- 10/3/05 Recruiting, enticing, providing, or obtaining by any means a person knowing that the person has not attained the age of 18 years and will be caused to engage in a commercial sex act. 1591 (a)( 1 ) EPSTEIN I. JANE DOE #9 Jane Doe #9 also attended Royal Palm Beach High School. She was recruited by Jane Doe #8 and also was friends with Jane Doe #6. Jane Doe #9 went to Epstein's home twice, the first time when she was 16 and the second time when she was 17. Jane Doe #9 was paid $200 each time. She did not recruit anyone else to go to Epstein's home. Jane Doe #8 approached Jane Doe #9 telling her that she could make $200 massaging Epstein. Jane Doe #8 told Jane Doe #9 that she would have to perform the massage topless. Jane Doe #8 EFTA00229899
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arranged that first appointment with Jane Doe #8 and Jane Doe #9 went to Epstein's house together and entered through the kitchen. Jane Doe #8 led Jane Doe #9 upstairs to the dressing area. Epstein entered wearing only a towel. The two girls undresses down to their panties. Epstein selected the massage oils and lay face down on the massage table. Both girls began massaging Epstein's back, legs, and feet. After some time, Epstein turned over and instructed Jane Doe #8 to leave the room. Epstein then began to masturbate as he instructed Jane Doe #9 to massage his chest. After Epstein ejaculated, he used the towel he had been wearing to wipe himself off, and told Jane Doe to get dressed and meet him downstairs. Jane Doe #9 did so and met Epstein in the kitchen, where he paid here $200. Jane Doe #8 received the same amount. The second appointment also was made via Jane Doe #8 approximately one month later. They returned to the house the same way and Jane Doe #8 again led her upstairs, but left Jane Doe #9 to do the massage alone. Epstein entered wearing only a towel. Jane Doe #9 stripped down to her panties, but Epstein told her that she had to get completely naked, which she did. Jane Doe #9 massaged Epstein's back and legs for a while and the he turned over and began masturbating as she rubbed his chest. This time Epstein to the massager/vibrator and began using it on Jane Doe # 9's vagina. Epstein did that for a while and then stopped so he could focus on himself. After he ejaculated, he wiped himself off and told Jane Doe #9 that the massage was over. Jane Doe # 9 got dressed and went downstairs to the kitchen, where she met Epstein and Jane Doe #8. Epstein paid her $200. Jane Doe #9 reports that Epstein asked about school. She told him that she attended Royal Palm Beach High School. She also told him that she did not have her drivers license yet. Jane Doe #9 did not give her phone number to or Epstein and she told Jane Doe # 8 that she did not want to return. Because no calls went directly from Epstein or his employees to Jane Doe #9, the exact dates of contact are unknown. JD#9 says that she believes the events occurred around her birthday and there is phone traffic between JD#9 and her recruiter in February, March, and April, so I have charged the whole period [Count 13]. J. JANE DOE #10 ffi . M Jane Doe #10 attended Royal Palm Beach High School and was recruited by Jane Doe #1. When she was interviewed, she told them she only performed one massage. She has not yet been interviewed by the FBI, so she is not the subject of any substantive counts at this time. She is, however, the link between Epstein and Jane Doe #11. She is listed in an overt act making calls on behalf to Jane Doe #11. K. JANE DOE #11 ffi ) Jane Doe # 11 attended Royal Palm Beach High School and was recruited by Jane Doe # 10, who asked if she wanted to make extra money for Christmas. She only went to Epstein's home on one occasion, when she was 16. Epstein never asked her age, but they discussed events at the high school. Jane Doe # 11 was taken to Epstein's home by Jane Doe # 10. She was introduced to in the kitchen. led her upstairs to the dressing area and explained that there would be lotions out already and Epstein would tell her which lotion to use. The massage table was already set up in the dressin area. introduced Jane Doe #11 to Epstein, who was on the phone when they entered. left. Epstein was laying on his stomach wearing a white towel. Jane Doe #11 began massaging his back and legs. Epstein told Jane Doe #11 to get comfortable and asked her to remove her shirt and pants. Jane Doe #11 removed those items, remaining in her bra and panties. Epstein turned over and instructed her to pinch his nipples. Epstein asked about high school, asked if she was sexually active and what sexual positions she liked. Jane Doe #11 said she didn't like talking about those things. Epstein undid Jane Doe #11's bra and began rubbing her breasts. Jane Doe #11 told him that she didn't like that but he continued. He removed his towel and began masturbating as he continued to touch Jane Doe #11's breasts and vagina; he finally digitally penetrated her. After he ejaculated, Epstein wiped himself off with his towel and told Jane Doe #11 that there was $200 on the dresser for her and $100 for EFTA00229900