EFTA00230208

IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
ADDENDUM TO THE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as 
follows: 
7A. 
The United States has the right to assigm to an independent third-party the responsibility 
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting 
the attorney representative for the individuals identified under the Agreement If the 
United States elects to assign this responsibility to an independent third-party, both the 
United States and Epstein retain the right to make good faith objections to the attorney 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
713. 
The parties will jointly prepare a short written submission to the independent third-party 
regarding the role of the attorney representative and regarding Epstein's Agreement to 
pay such attorney representative his or her regular customary hourly rate for representing 
such victims subject to the provisions of paragraph C, infra. 
7C. 
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney 
representative selected by the independent third party. This provision, however, shall not 
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, 
if after consideration of potential settlements, an attorney representative elects to file a 
contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested 
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney 
representative, as opposed to any statutory or other obligations to pay reasonable 
attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney 
representative, shall cease. 
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By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby, states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated:  /O/3 0 k 7 
Dated: / 6/ 2' 
Dated: 
Dated: 
By: 
1€ A. 
ASSISTANT U.S. ATTORNEY 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
 
 
ESQ. 
ATTORNEY FOR. JEFFREY EPSTEIN 
-416 54>stexw mucf4-
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By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER AQOSTA 
UNITED STATES ATTORNEY 
Dated:  
/3 0%7 
Dated: 
Dated: 
Dated: 
By: 
—16 / 10 44 
FA OSA 
oi A. 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
BRAID LEI:CO RT ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
 
 ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
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By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated:  /D /3 0/0'7 
Dated: 
Dated: 
Dated: )(yam 
By: 
4 A.
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY A 
ANCHEZ, ESQ 
ATTORNEY FOR JEFFREY EPSTEIN 
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U.S. Department of Justice 
United Slates Attorney 
Southern District of Florida 
R ALEXANDER ACOSTA 
UNITEDSTATES ATTORNEY 
DELIVERY BY FACSIMILE 
Fowler White Burnett, PA 
1395 Brickell Ave, I4th Floor 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Ms. Sanchez: 
99N E 'Sweet 
Sham. FL i1111 
(l05)90-000 Telephone 
(105)530.6144 - FOCJIII I lit 
December 19, 2007 
I write to follow up on the December 14th meeting between defense counsel and the Epstein 
prosecutors, as well as our First Assistant, the Miami FBI Special Agent in Charge and myself.' I 
write to you because I am not certain who among the defense team is the appropriate recipient of this 
letter. I address issues raised by several members of the defense team, and would thus ask that you 
please provide a copy of this letter to all appropriate defense team members. 
First, I would like to address the Section 2255 issue.2 As I stated in my December 4th letter, 
my understanding is that the Non-Prosecution Agreement entered into between this Office and Mr. 
Epstein responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal 
liability. Under this Agreement, this District has agreed to defer prosecution for enumerated sections 
I Over the past two weeks, we have received several hundred pages of arguments and exhibits from defense counsel. 
This is not the forum to respond to the several items raised, and our silence should not be interpret as agreement; I 
would, however, like to address one issue. Your December I i th letter states that as a result of defense counsel 
objections to the appointment process, the USAO proposed an addendum to the Agreement to provide for die use of 
an independent third party selector. As I recall this matter, before I had any knowledge of defense counsel 
objections, I sun sponte proposed the Addendum to Mr. Lelkowitz al an October meeting in Palm Beach. I did this 
in an attempt to avoid what I foresaw would likely be a litigious selection process. It was only after I proposed this 
change that Mr. Letkowitz raised with me his enumerated concerns. 
2 Section 2255 provides that: "falny person who, while a minor, was a victim of a violation of [enumerated sections 
of Title Si and who suffers personal injury as a result of such violation • .. may sue in any appropriate United States 
District Court and shall recover the actual damages such person sustains and the cost of the suit, including a 
reasonable attorney's fee." 
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of Title 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies 
three general federal interests: (I) that Mr. Epstein plead guilty to a "registerable" state offense; (2) 
that this state plea include a binding recommendation fora sufficient term of imprisonment; and (3) 
that the Agreement not harm the interests of his victims. 
With this in mind, I have considered defense counsel arguments regarding the Section 2255 
portions of the Agreement. As I previously observed, our intent has been to place the victims in the 
same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. 
From our meeting, it appears that the defense agrees that this was the intent. During the course of 
negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously, 
appear far from simple to understand. I would thus propose that we solve our disagreements over 
interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7 
and 8 with the following language: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated in 
Title 18, United States Code, Section 2255, will have the same rights to proceed under 
Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an 
enumerated offense. For purposes of implementing this paragraph, the United States shall 
provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority 
interpreting this provision, including any authority determining which evidentiary burdens if 
any a plaintiff must meet, shall consider that it is the intent of the parties to place these 
identified victims in the same position as they would have been had Mr. Epstein been 
convicted at trial. No more; no less." 
Second, I would like to address the issue of victim's rights pursuant to Section 3771. I 
understand that the defense objects to the victims being given notice of time and place of Mr. 
Epstein's state court sentencing hearing. I have reviewed the proposed victim notification letter and 
the statute. I would note that the United States provided the draft letter to defense as a courtesy. In 
addition, First Assistant United States Attorney Sloman already incorporated in the letter several 
edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of 
proceedings and results of investigations of federal crimes as opposed to the state crime. We intend 
to provide victims with notice of the federal resolution, as required by law. We will defer to the 
discretion of the State Attorney regarding whether he wishes to provide victims with notice of the 
state proceedings, although we will provide him with the information necessary to do so if he wishes. 
Third, I would like to address the issue raised.regarding Florida Statute Section 796.03. At 
our meeting, Professor Dershowitz took the position that Mr. Epstein believes that his conduct does 
not satisfy the elements of this offense. His assertion raises for me substantial concerns. This Office 
will not, and cannot, be a party to an agreement in which Mr. Epstein pleads guilty to an offense that 
he believes he did not commit. We are considering how best to proceed. 
2 
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Finally, I would like to address a more general point. Our Agreement was first signed on 
September 24th, 2007. Pursuant to paragraph I I , Mr. Epstein was to use his best efforts to enter his 
guilty plea and be sentenced no later than October 26, 2007. As outlined in correspondence between 
our prosecutors and defense counsel, this deadline came and went. Our prosecutors reiterated to 
defense counsel several times their concerns regarding delays, and in fact, asked me several weeks 
ago to declare the Agreement in breach because of those delays. I resisted that invitation. I share 
this fact because it is background to my frustration with what appears to be an I Id' hour appeal, 
weeks before the now scheduled January 4th plea date. 
This said, the issues raised are important and must be fully vetted irrespective of timeliness 
concerns. We hope to preserve the January 4'h date. I understand that defense counsel shares our 
desire not to move that appearance and will work with our office to expedite this process over the 
next several days. With this in mind, and in the event that defense counsel may wish to seek review 
of our determinations in Washington D.C., I spoke this past Monday with the Assistant Attorney 
General Fisher, to inform her of a possible appeal, to ask her to grant the potential request for review, 
and to in fact review this case in an expedited manner to attempt to preserve the January 4th plea date. 
I want to again reiterate that it is not the intention of this Office ever to force the hand of a 
defendant to enter into an agreement against his wishes. Your client has the right to proceed to trial, 
and he should do so if he believes that he did not commit the elements of the charged offense. 
I will respond to the pending issues shortly. In the interim, I would ask that you 
communicate your position with respect to the sections 2255 and 3371 issues as quickly as possible. 
Sincerely, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
cc: 
Alice Fisher, Assistant Attorney General 
First Assistant U.S. Attorney 
AUSA 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No: 
18 U.S.C. § 371 
18 U.S.C. § 1591(a)(1) 
18 U.S.C. § 1591(2)(2) 
18 U.S.C. § 2422(b) 
18 U.S.C. § 2423(e) 
18 U.S.C. § 2423(d) 
18 U.S.C. § 2423(b) 
UNITED STATES OF AMERICA 
vs. 
JEFFREY EPSTEIN, 
if 
and 
Defendants. 
INDICTMENT 
The Grand Jury charges that: 
BACKGROUND 
At all times relevant to this Indictment: 
I. 
Defendant JEFFREY EPSTEIN employed defendants 
, a/Ida 
' and 
among other things, services as personal assistants. 
to perform, 
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2. 
Defendant JEFFREY EPSTEIN. employed L.G. to perform, among other 
things, services as a personal assistant. 
Defendants JEFFREY EPSTEIN and 
if -.4' 
paid T. M., H.R., and 
A.F. to perform, among other things, recruiting services. 
4. 
Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, 
Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El 
Brillo Way"). 
5. 
De fendantjEFFREY EPSTEIN owned a property located at 9 East 71st Street, 
New York, New York (hereinafter referred to as "the New York residence"). 
6. 
Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a 
Delaware corporation. JEGE, INC.'s sole business activities related to the operation and 
ownership of a Boeing 727-31 aircraft bearing tail number N908JE. 
7. 
Defendant JEFFREY EPSTEIN served as president, sole director, and sole 
shareholder of JEGE, INC., and had the power to direct all of its operations. 
8. 
Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., 
a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation 
and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. 
9. 
Defendant JEFFREY EPSTEIN served as president, sole director, and sole 
shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 
2 
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10. 
Pursuant to Florida Statutes Section 794.05, a "person 24 years of age or older 
who engages in sexual activity with a person 16 or 17 years of age commits a felony of the 
second degree." For purposes of "this section, `sexual activity' means oral, anal, or vaginal 
penetration by, or union with, the sexual organ of another; however, sexual activity does not 
include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states 
that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation 
of age by [the victim I nor a bona fide belief that such person is over the specified age [shall] 
be a defense." 
11. 
Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(cX2), an adult 
"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, 
or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or 
entices a person under 16 years of age to w touch the perpetrator, commits lewd or lascivious 
molestation," which is a felony of the second degree if the victim is 12 years of age or older 
but less than 16 years of age. 
12. 
Pursuant to Florida Statutes Sections 800.04(6Xa) and 800.04(6Xb), an adult 
"who [i]ntentionally touches a person under 16 y 
of age in a lewd or lascivious manner 
or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd 
or lascivious conduct," which is a felony of the second degree. 
3 
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13. 
Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7Xc), an adult 
"who: (I) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or 
lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve 
actual physical or sexual contact with the victim, including, but not limited to . . . the 
simulation of any act involving sexual activity in the presence of a victim who is less than 
16 years of age, commits lewd or lascivious exhibition," which is a felony of the second 
degree. 
14. 
Pursuant to Florida Statutes Section 800.04(2), "[n]either the victim's lack of 
chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]." 
15. 
Pursuant to Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance 
of the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona 
fide belief of the victim's age cannot'be raised as a defense in a prosecution under [Section 
800.04]." 
16. 
Pursuant to Florida Statutes Section 800.02, a "person who commits any 
unnatural and lascivious act with another person commits a misdemeanor of the second 
degree." 
17. 
Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any 
medical I icense. 
4 
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18. 
During the period of her involvement with the Defendants, Jane Doe #4 
attended Wellington High School and Palm Beach Central High School in Palm Beach 
County., 
19. 
During the period of her involvement with the Defendants, Jane Doe #5 
attended Wellington High School in Palm Beach County. 
20. 
During the period of their involvement with the Defendants, Jane Does # 6, 8 
and 12 attended Palm Beach Central High School in Palm Beach County. 
21. 
During the period of her involvement with the Defendants, Jane Doe #7 
attended William T. Dwyer High School in Palm Beach County. 
22. 
During the periods of their involvement with the Defendants, Jane Does # 9, 
14, 15, 16, 17, 18, and 19 attended Royal Palm Beach I ligh School in Palm Beach County. 
23. 
During the period of 
involvement with the Defendants, Jane Doe #10 
attended Lake Worth High School in Palm Beach County. 
24. 
During the period of her involvement with the Defendants, Jane Doe #11 
attended the Professional Performing Arts School, a public high school, located in New 
York, New York. 
25. 
During the period of her involvement with the Defendants, Jane Doe #13 
attended John I. Leonard High School in Palm Beach County. 
5 
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COUNT 1 
(Conspiracy: 18 U.S.C. § 371) 
26. 
Paragraphs I through 25 of this Indictment arc re-alleged and incorporated by 
reference as though fully set forth herein. 
27. 
From at least as early as 2001, the exact date being unknown to the Grand Jury, 
through in or around October 2005, in Palm Beach County, in the Southern District of 
Florida, and elsewhere, the Defendants, 
PRIMPV PIKTPINI 
a/k/a " 
and
did knowingly and willfully combine, conspire, confederate and agree with each other and 
with others known and unknown to commit an offense against the United States, that is, to 
use a facility or means of interstate dr foisteign commerce to knowingly persuade, induce, and 
entice individuals who had not attained the age of 18 years to engage in prostitution, in 
violation of Title 18, United States Code, Section 2422(b). 
Purpose and Object of the Conspiracy 
28. 
It was the purpose and object of the conspiracy to procure females under the 
age of 18 to travel to 358 El Brillo Way and the New York residence so that JEFFREY 
EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females 
in order to satisfy JEFFREY EPSTEIN's prurient interests. 
6 
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Manner and Means 
29. 
The manner and means by which the Defendants and other participants sought 
to accomplish the purpose and object of the conspiracy included the following: 
(a) 
It was part of the conspiracy that Defendants 
a/k/a 
and other 
participants would contact minor females via the use of cellular and other telephones to 
arrange appointments :for minor females to travel to 358 El Brillo Way and the New York 
residence to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. 
(b) 
It was further a part of the conspiracy that Defendants JEFFREY 
EPSTEIN, 
and 
a/k/a 
 
and other participants would make payments to, or cause payments to be 
made to, minor females in exchanggifor engaging in lewd conduct. 
EPSTEIN, 
(c) 
It was further a part of the conspiracy that Defendants JEFFREY 
a/k/a 44j 
' and other 
participants would ask females to recruit other minor females to engage in lewd conduct with 
Defendant JEFFREY EPSTEIN. 
EPSTEIN, 
, 
(d) 
It was further a part of the conspiracy that Defendants JEFFREY 
a/k/a 
' and other 
participants would make payments to, or cause payments to be made to, the recruiters for 
7 
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bringing additional minor females to 358 El Brillo Way and the New York residence to 
engage in lewd conduct with Defendant JEFFREY EPSTEIN. 
(e) 
It was further a part of the conspiracy that Defendant JEFFREY 
EPSTEIN would pay minor females to engage in lewd conduct with Defendant 
 
to satisfy Defendant JEFFREY EPSTEIN's prurient interests. 
Overt Acts 
30. 
In furtherance of this conspiracy and to effect the objects thereof, there was 
committed by at least one of the co-conspirators herein, at least one of the following overt 
acts, among others, in the Southern District of Florida, and elsewhere: 
Jane Does #1 and #2 
(1) 
In or around the beginning of 2001, Defendant JEFFREY EPSTEIN 
engaged in sexual activity with lane Doe # I, who was then a seventeen-year-old girl, 
in the presence of Jane Doe #2, who was then a fourteen-year-old girl. 
(2) 
In or around 2001, Defendant 
led Jane Doe #2 from the 
kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 
El Brillo Way. 
(3) 
In or around 2001, DefendantJEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #2, who was then a fourteen-year-old girl. 
(4) 
In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, 
who was then fourteen years' old, to pinch his nipples while he masturbated. 
8 
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(5) 
In or around 2001, Defendant JEFFREY EPSTEIN made a payment of 
$300 to Jane Doe #2. 
(6) 
In or around 2001, Defendant 
placed a telephone call 
to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel 
to 358 El Brillo Way. 
(7) 
In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse 
with an unidentified female in the presence of Jane Doe #2, who was then a fourteen-
year-old girl. 
(8) 
In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane 
Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female 
to perform oral sex on Jane Doe #2 in EPSTEIN's presence. 
(9) 
On or about Mitich 11, 2003, an employee of Defendant JEFFREY 
EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's 
review regarding a telephone call received from Jane Doe #2. 
(10) 
In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 
if she had any younger friends who woup, be interested in engaging in similar 
re-4 
activities with him. 
(11) 
In or around 2003, Defendant 
of Jane Doe #2, who was then a sixteen-year-old girl. 
9 
took nude photographs 
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(12) 
In or around 2003, Defendant 
nade a payment of 
$500 to Jane Doe #2 in exchange for posing for nude photographs. 
(13) 
In or around 2003, Defendant al 
told Jane Doe #2 that 
Defendant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane 
Doe #2. 
(14) 
In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #2, who was then a sixteen-year-old girl. 
(15) 
In or around 2003, Defendant JEFFREY EPSTEIN made a payment of 
$200 to Jane Doe #2, who was then a sixteen-year-old girl. 
(16) 
In or around 2003, Defendan 
placed a telephone call 
to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel 
to 358 El Brillo Way. 
(17) On or about April 23, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #2. 
(18) On or about May 2, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #2. 
Jane Doe #3 
(19) 
In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #3, who was then a fifteen-year-old girl. 
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(20) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of 
$200 to Jane Doe #3. 
(21) On or about October 26, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #3. 
(22) On or about October 30, 2004, Defendant 
laced a 
telephone call to a telephone used by Jane Doe #3. 
(23) In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe 
#3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and 
to touch the adult female's breasts. 
(24) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging 
device on the vagina of an adult female in the presence of Jane Doe #3, who was then 
a sixteen- or seventeen-year-old girl. 
(25) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of 
$200 to Jane Doe #3. 
(26) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe 
#3 to rub his nipples. 
(27) In or around 2004, DefendaneJEFFREY EPSTEIN placed a massaging 
device on the vagina of Jane Doc #3, who was then a sixteen- or seventeen-year-old 
girl. 
11 
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(28) 
In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 
to recruit additional females to come to 358 El Brillo Way. 
(29) 
On or about November 8, 2004, one of Defendant JEFFREY 
EPSTEIN's employees prepared a written telephone message for Defendant 
JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 
that read: "I have a female for him." 
(30) 
On or about January 14, 2005, Defendan 
placed a 
telephone call to a telephone used by Jane Doe #3. 
(31) 
On or about January 29, 2005, one of Defendant JEFFREY EPSTEIN's 
employees prepared a written telephone message for Defendant JEFFREY 
EPSTEIN's review regarding a telephone call received from Jane Doe #3 that read: 
"I have a female for him." 
/ 
Jane Does #4, #5. and #6 
(32) 
In or around the first half of 2004, Defendant 
led 
Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El 
Brillo Way. 
(33) 
In or around the first half 
2004, Defendant JEFFREY EPSTEIN 
asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. 
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(34) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, 
afid Jane Doe #5, who was then a seventeen-year-old girl. 
(35) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
instructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his 
nipples. 
(36) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
instructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her 
clothing. 
(37) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
stroked the vagina of Jane Doe #4, who was then a seventeen-year-old girl. 
(38) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid 
$200 to Jane Doe #4. 
(39) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid 
$200 to Jane Doe #5. 
(40) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
asked Jane Doe #6 what high school she attended. 
(41) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone. 
13 
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