EFTA00234517

they would be in town. On several occasions, 
made the appointments with 
JD#15. 
Epstein gave JD#15 three Victoria's Secret bra and panty sets and gave her a "Pocket 
Rocket" vibrator for her 18th birthday. 
Jane Doe #15 never told Esptein her age, 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:OW was a close friend ofJD#15 and they often went to 
Epstein's house together. 
told Epstein that she and JD#15 went to the same school and 
were in the same class, and 
told Epstein that she was a junior in high school. There 
also is evidence that Epstein gave JD#15 a vibrator for her 18th birthday, knowing that it was 
her 18th birthday and offered to fly JD#15 to his home in the Virgin Islands after she was 18. 
Wi 
ct to the enticement charge and the human trafficking charge, I included 
andlill
ebecause of the number of calls that they were involved with. There were 
a total of 156 calls between 
and JD# I 5, and there were 28 calls between 
and 
JD#15. Although 
was aboard the plane during several trips, there is no evidence 
that she ever had contact with JD#15 or arranged for ID#15 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#15 was enticed, I elected to charge the enticement and 
fficking offenses over the range of dates representing the first telephone call from 
to JD#15 until the last call from 
before JD#15's 18th birthday (the activity 
with Epstein continued thereafter, but at that point it is beyond our jurisdiction to prosecute). 
ope
t for charging the travel offense is each trip, so I have charged the trips where 
or = 
spoke with JD#15 shortly before Epstein traveled, again stopping at the point 
that JD#15 turned 18. 
D. 
Tallailla 
also was recruited by,. 
and was a student a 
High 
School.' 
received approximately 60 calls from 
during t e eriod of 
April 25, 2004 (when she was 16) through October 6, 2005 (when she was 18). s
tates 
that she performed only a few sexual massages, although that is belied by th
er of 
telephone callsilareports that she performed the sexual massages while wearing her bra 
and panties. During the sessions, Epstein pulled 
bra down and grabbed her breast. 
Epstein tried to touch 
vagina and grabbed her butt. Epstein masturbated during the 
sessions and he instructed 
o pinch his nipples while he masturbated. 
41 
EFTA00234557

Epstein tolcallito take her clothes off and that she could make more mo 
if she 
would do more (engage in more sexual activity). Epstein constantly pushed ford 
become more sexual, asking her if she had sex with her boyfriend and if she liked sex. 
was paid $200 for each sexual massage that she performed, and she received the payments 
from Epstein and 
Epstein also toll. 
that she could m e more money if she "brought her pretty 
friends" to perform sexual massages. Epstein tol 
that the girls that she brought should 
know what to expect when they arrive. 
also aske 
to bring more girls. a 
brought at least two more girls to Epstein's home. She was paid $200 for each girl whom 
she brought. 
and 
made the appointments witla 
told Epstein that 
she was a junior at 
High School, so there is evidence that Epstein knew 
that." was under 18. 
E. 
Jane Doe #14 
Jane Doe #14 also attendeciallHigh 
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 #14 reported that she entered the home through the kitchen and was 
introduced to Sarah. Sarah brought JD#14 upstairs to the dressing area, where she met 
Epstein. JD#14 performed multiple sexual massages for Epstein. During the first massage, 
Epstein asked JD#14 how old she was and she said that she was 18. During that massage, 
she removed her clothes, and he masturbated. JD#14 also describes how Epstein would 
verbally push her to engage in more and more sexual activity. JD#14 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#14 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#14 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#14 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 
42 
EFTA00234558

pay her. (This is consistent with the record of a payment by the house manager to JD#14.) 
JD#14 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.33 Around the third or fourth visit, Epstein began asking JD#14 about plans for her 
18th birthday, and he said to her, "So you're really not eighteen." JD#14 states that they 
laughed a little and continued with the session. 
JD#14 received 31 calls from 
and 15 calls from 
JD#14 states that 
she received the payments from Epstein. JD#14 says that Epstein defmitely knew her age. 
JD#14 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. 
F. 
JANE DOE #91Ila 
Jane Doe #9 also attendedgaillieFfigh 
School. She was recruited by a 
girl named
 who also was an underage victim.34 Jane Doe #9 was involved with 
Epstein for more than a year, and she recruited Jane Does #10 and #16. Jane Doe #9 is 
believed to be the girl who saw Epstein the most. She estimates that she saw him hundreds 
of times. There are approximately 220 calls between Jane Doe #9 and = 
4 calls with 
Ma, 
and 3 calls with M. 
JD#9 reported that Illalapproached her one summer when she was working at the 
Wellington Mall. JD#9 said that she thought she was 16 or 17 years' old at the time. Her 
telephone contact with 
be an in July 2004, so this probably was the summer of 2004 
when JD#9 was 17 years' old. 
told her that she could make $200 performing a 
massage, but she would have to perform the massage naked. JD#9 agreed to perform the 
massage, and 
set it up for the same da . JD#9 remembered that it was a weekend 
because she only worked on weekends. 
took JD#9 to Epstein's home where they 
entered through the kitchen and met 
led JD#9 upstairs, and JD#9 described 
the pictures of naked women on the walls and tables of the house." When they reached the 
"One of the messages retrieved from the message pad was a call from David Copperfield 
asking Epstein to return his call. 
34As discussed below, there are six girls who will be included in a superseding indictment, 
once their telephone records are received and analyzed. 
is one of those girls. 
15A number of these photographs were seized during the search of Epstein's home. 
43 
EFTA00234559

dressing area, net 
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#9 undressed except for her panties. JD#9 massaged Epstein's back and legs. 
He then turned over and began masturbating as she continued to massage him. Epstein 
fondled JD#9's breasts as he masturbated, and the massa e ended when he ejaculated. JD#9 
received $200 from Epstein as payment for that session. 
also was paid, but JD#9 did 
not know how much. Epstein asked JD#9 to leave her elephone number. JD#9 wrote it 
down on a piece of stationery bearing Epstein's name. 
JD#9 described the escalation of sexual activity during the period that she knew 
Epstein. Epstein digitally penetrated JD#9, used the massager/vibrator on her vagina, and 
performed oral sex on her. JD#9 described how Epstein brought 
into the 
activity. He instructed JD#9 to perform oral sex on 
When JD#9 refused, 
Epstein promised an additional $200 if JD#9 would perform oral sex for five minutes. JD#9 
agreed, and Epstein masturbated while watching them. JD#9 said that various sex toys were 
used on her, including 
use of a strap-on dildo. JD#9 also said that Epstein 
forced her to have vaginal sex on one occasion when he became very excited. JD#9 
screamed for him to stop. Epstein did so and apologized. 
JD#9 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#9 how old she was. JD#9 said that she w 18 and Epstein told her 
that he knew she was not 18. Epstein knew that she attended 
High 
School. He sent roses to a high school play performance that JD#9 gave. They discussed 
JD#9's plans to attend college. JD#9 gave Epstein a copy of her transcript on three 
occasions. JD#9 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#9 for her 18th birthday. 
JD#9 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#9 on this trip. 
Epstein provided JD#9 with other gifts including a Louis Vuitton purse, a bathing suit, 
Victoria's Secret bra and panty sets, and cash gifts. JD#9 said that most of the time 
would call to set up the appointments for her to "work." 
would call from onet 
• 
several days in advance. Sometimes the appointments were made before Epstein arrived. 
44 
EFTA00234560

Other times, 
would call when they were already in Palm Beach. JD#9 was shown a 
photo array containing 
photograph. She positively identified 
Credibility Issues 
Attached at Tab 5 is Jane Doe #9's MySpace page. Attached at Tab 6 is the report of 
an arrest of Jane Doe #9 for using drugs. Tab 7 is a report of a firing from Victoria's Secret 
for theft. The defense rabidly attacks Jane Doe #9's credibility because of all of the sexual 
activity that she describes. One attack is that she is incredible because she was subpoenaed 
to appear before the State Grand Jury and never appeared. The defense neglects to point out 
that the subpoena was issued one or two days before JD#9 was to testify in West Palm 
Beach; she was living in Orlando at the time; and she was never served or told about the 
grand jury presentation. JD#9 admittedly has used drugs since becoming involved with 
Epstein, but she seems to have finished that phase of her life. Her statements also are 
corroborated by: her ability to describe the house, the telephone records, the property 
manager's written record of paying her, the earlier property manager's statement that he 
rented a car for JD#9 at Epstein's request, and the receipt provided by Epstein's counsel at 
Tab 8. 
G. 
JANE DOE #10 Sillilli 
Jane Doe #10 attendeall-ligh 
School and was recruited by Jane Doe #9. 
She reports that she gave approximately 15 sexual massages (this number is probably low . 
There are approximately 11 
tele hone calls between Jane Doe #10 and 
approximately 7 calls with 
and approximately 14 calls with 
. Jane Doe 
#10's phone activity began on July 22, 2004, when she was 17 and continued past her 18th 
birthday. Jane Doe #10 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. 
Jane Doe #10 reports that, in the spring of 2004, she was working at a store at the 
Wellington Mall with Jane Doe #9. Jane Doe #9 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 #10 agreed and Jane 
Doe #9 made the appointment. On the first visit, Jane Doe #9 led Jane Doe #10 up to the 
dressing area. Epstein entered wearing only a towel, and he directed Jane Doe #9 to leave. 
He removed the towel and laid down. Epstein asked Jane Doe #10 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 
45 
EFTA00234561

visit, Epstein again asked Jane Doe #10 to get undressed and she did. Jane Doe #10 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 #10's vagina and breasts while he masturbated; he also 
used the vibrator/massager on her vagina. E stein asked Jane Doe #I0 to touch his penis - 
Ilia 
On at least two occasions, 
was part of the active . Epstein and 
performed sexual acts on each other, including oral sex. 
placed her 
hand on Janc Doe #10's vagina and used the vibrator/massager on Jane Doe #10'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 #10 when she was on vacation and had no 
funds to get home. Both of these wire transfers occurred after her 18th birthday. 
H. 
JANE DOE #16 
Jane Doe #16 attendeMMIIIHigh 
School and was recruited by Jane Doe 
#9. She
id that she started going to Epstein's house in November 2004, but phone 
calls withl 
do not begin until February 2005. Jane Doe #9 approached her and asked 
if she wanted to make money massaging Epstein. Jane Doe #16 had heard of other girls at 
school making money that way and she agreed to go to Epstein's house. Jane Doe #9 took 
her to the house and introduced her to 
and Epstein in the kitchen. Jane Doe #9 led her 
upstairs to the dressing area where the massage table was already set up. Jane Doe #9 left 
and Epstein entered wearing a towel. Epstein told her to undress and Jane Doe #16 
performed the massage wearing only panties. Epstein masturbated until he ejaculated, which 
ended the massage. Jane Doe #16 received $200, so did Jane Doe #9. 
Jane Doe #16 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 #16 to kiss and fondle 
while he 
masturbated. Epstein also had vaginal intercourse with Jane Doe #16 on one occasion, for 
which he paid $350. 
Jane Doe #16 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 #16 told Epstein that she was 17 on her first visit. A few days before her 
46 
EFTA00234562

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 #16 recruited Jane Doe 
#17 and a non-minor female to go to Epstein's home. 
There are approximItAi 60 calls between Jane Doe #16 and 
and 14 calls 
between Jane Doe #16 and M. 
called Jane Doe #16 once. 
Credibility Issues 
Jane Doe #16 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 ME Fucicinglillt Those materials are attached at Tab 13. Epstein's attorneys 
do not have a copy of Jane Doe #16's state grand jury testimony. During that testimony, Jane 
Doe #16 exhibited no hostility towards Epstein and said that she testified only because she 
was subpoenaed to appear. Her statements are well corroborated by the telephone records, 
etc., but, as with the other girls, her past is not pristine. 
I. 
JANE DOE #17 
Jane Doe #17 also attendeallina 
High School. She was recruited by 
Jane Doe #16 and also was friends with Jane Doe #9. Jane Doe #17 went to Epstein's home 
twice, the first time when she was 16 and the second time when she was 17. Jane Doe #17 
was paid S200 each time. She did not recruit anyone else to go to Epstein's home. 
Jane Doe #16 approached Jane Doe #17 telling her that she could make $200 
massaging Epstein. Jane Doe #16 told Jane Doe #17 that she would have to perform the 
massage topless. Jane Doe #16 arranged that first appointment with-. 
Jane Doe #16 
and Jane Doe #17 went to Epstein's house together and entered through the kitchen. Jane 
Doe #16 led Jane Doe #17 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 #16 to leave the room. 
Epstein then began to masturbate as he instructed Jane Doe #17 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 #17 did so and met Epstein in the 
kitchen, where he paid here $200. Jane Doe #16 received the same amount. 
47 
EFTA00234563

The second appointment also was made via Jane Doe #16 approximately one month 
later. They returned to the house the same way and Jane Doe #16 again led her upstairs, but 
left Jane Doe #17 to do the massage alone. Epstein entered wearing only a towel. Jane Doe 
#17 stripped down to her panties, but Epstein told her that she had to get completely naked, 
which she did. Jane Doe #17 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 # 17'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 #17 that the massage was over. Jane Doe # 17 got dressed and went 
downstairs to the kitchen, where she met Epstein and Jane Doe #16. Epstein paid her $200. 
Jane Doe #17 reports that Epstein asked about school. She told him that she attended 
High School. She also told him that she did not have her drivers license 
yet. Jane Doe #17 did not give her phone number to 
or Epstein and she told Jane Doe 
# 16 that she did not want to return. 
Because no calls went directly from Epstein or his employees to Jane Doe #17, the 
exact dates of contact are unknown. JD#17 says that she believes the events occurred around 
her birthday and there is phone traffic between JD#17 and her recruiter in February, March, 
and April, so I have charged the whole period [Count 13]. 
IS 
attended Royal Palm Beach High School and was recruited bill 
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 an substantive counts at this time. 
She is, however, the link between Epstein and 
also removed from the 
indictment). She is listed in an overt act making calls on 
behalf toll.. 
K. 
attende 
High School and was recruited balm 
is who asked if she wanted to mace 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. 
taken to Epstein's home by
 She was introduced to 
in the kitchen. 
led her upstairs to the dressing area and explained that there would be 
48 
EFTA00234564

lotions out already and Epstein would tell her which lotion to use. The massage table was 
already set up in the dressin area. =introduced'Mato 
Epstein, who was on the 
phone when they entered. 
lefi. Epstein was laying on his stomach wearing a white 
towel. 
began massaging his back and legs. Epstein told 
to get 
comfortab e and asked her to remove her shirt and pants. 
moved t ose items, 
remaining in her bra and panties. Epstein turned over and instructs 
er to pinch his nipples. 
Epstein asked about high school, asked if she was sexually active and what sexual 
sitions 
told him that she didn't like that ut e 
bra and brr
ilibing her breasts. IIIIIII 
she liked. 
said she didn't like talking about those things. Epstein undi 
continued. He removed his towel and began masturbating as he continued to touch 
Ian 
breasts and vagina; he finally di ital I 
netrated her. After he ejaculated, Epstein 
wiped himself off with his towel and tol 
at there was $200 on the dresser for her 
and $100 fot 
for bringing her. Epstein asked 
to leave her phone number 
because he wanted to see her again. 
_advised 
that she never went back and she stopped talking wino 
because she was upset over what happened. Mahone 
records show three calls to 
a
n 12/18/04, which is consistent with her recollection of the time frame. 
L. 
JANE DOE #41plalla 
Jane Doe # 7 attended 
High School. She was recruited by Tatum 
to go to Epstein's house when she was 16 years' old. Tatum also went to Epstein's house 
and performed sexual services starting when she was 15. Tatum refused to speak to police 
and the FBI, telling them that she was still in love with Epstein. Tatum was compelled via 
6001 immunity to provide information. She admitted that she brought around 30 girls to 
Epstein's house, including Jane Doe #7. Tatum says that she considers Epstein to be "the 
awesomest guy in the world," and she would marry him if he asked her. When asked if she 
ever brought a girl that Epstein did not like, she said: 
Yeah, once. I made a mistake. 
I brought a black girl. Not that 
Jeffrey is a racist. He still paid 
her, but he wouldn't let her 
massage him. 
Tatum is too volatile and hostile to be called as a witness for the United States, but her 
statement is so damaging that Epstein can't use her either. 
49 
EFTA00234565

Tatum approached Jane Doe #7 in May or June 2004 and was told that she could 
model lingerie for a wealthy Palm Beach man for money. Tatum and Jane Doe #7 traveled 
by Yellow Cab from Jane Doe #7's house in West Palm Beach to Epstein's house. They met 
Epstein outside the house and he took them in to the kitchen where the chef made them 
something to eat. Epstein and Tatum led Jane Doe #7 upstairs to the dressing area. Epstein 
went into the bathroom and came out wearing only a towel. Epstein laid on his stomach and 
Tatum and Jane Doe #7 began massaging his legs and feet. Jane Doe #7 asked Tatum why 
they were doing this and Tatum replied that it was part of the routine. Epstein told Tatum 
to leave and told Jane Doe #7 to get comfortable and take off her clothes. Epstein turned 
onto his back and started touching her breasts and her vagina (over her panties) while he 
masturbated. The massage ended when he ejaculated. Epstein told Jane Doe #7 that there 
was $200 on the dresser for her. One of Epstein's employees was ordered to drive Tatum 
and Jane Doe #7 home, which he did. (A former property manager reports driving girls home 
on several occasions.) Jane Doe #7 reports that she called Tatum after she got home saying 
that she wanted to report Epstein to the authorities but Tatum talked her out of it. 
Jane Doe #7 returned to Epstein's home 2 or 3 times. The first time that she returned 
she again stayed in her panties and Epstein touched her while he masturbated. The next time 
she returned, Epstein told Jane Doe #7 to take all of her clothes off, saying she was here for 
that reason. Jane Doe #7 complied and Epstein fondled her breasts and vagina while he 
masturbated. Epstein instructed Jane Doe #7 not to tell anyone what happened during the 
massages. 
Epstein had gotten Jane Doe #7's phone number after the first massage and 
would call to make appointments. Jane Doe #7 started avoiding their calls. Jane Doe #7 took 
a Xanax before each meeting with Epstein. It is believed that Tatum provided the Xanax, but 
she denies it. 
M. 
JANE DOE #111Milla 
Jane Doe # 13 attendee... 
High School in a 
She was recruited 
by another girl, who will be the subject of a superseding indictment. 
When Jane Doe # 13 arrived at Epstein's home, her recruiter led her upstairs. When 
Epstein entered, he asked both of them to remove their tops. Both started massaging his 
back, then Epstein asked the recruiter to leave. When the recruiter was gone, Epstein asked 
Jane Doe #13 to remove the rest of her clothes; Jane Doe #13 complied. Epstein told Jane 
Doe #13 to talk dirty to him, and Epstein masturbated. 
50 
EFTA00234566

Jane Doe #13 estimates that she went to Epstein's home about 10 times. After the first 
massage was completed, Epstein asked for her telephone number. Jane Doe #13 wrote the 
information, down on a notepad bearing Epstein's name. Jane Doe #13 was paid $200 for 
each massage. She also brought 2 other girls was paid $200 for each girl she brought. 
Epstein always made the payments. Epstein asked Jane Doe #13 to have sexual intercourse 
and promised to pay more money if she did. Jane Doe #13 declined. 
In addition to masturbating himself, Epstein used the back massager/vibrator on Jane 
Doe #13's vagina. Epstein fondled Jane Doe #13's breasts and buttocks, and digitally 
penetrated her vagina. 
Epstein asked Jane Doe #13 how old she was and she said she would be turning 18 
in the spring. She told Epstein several times that she was 17, she gave Epstein a school photo 
and wrote on the back that she couldn't wait to turn 18. Jane Doe #13 and Epstein discussed 
Jane Doe #13's age. Epstein said he couldn't wait until she turned 18 so they could travel to 
Paris together and so she could be his personal masseuse. 
Jane Doe #13 received calls from 
and 
to set up appointments, usually at 
least one a day in advance, sometimes the appointments were made before Epstein arrived 
Mir
Beach. There are records of approximately 40 calls between Jane Doe #13 and 
and 6 calls between Jane Doe #13 and ■. 
Jane Doe #13 still had 
number 
programmed into her cell phone. Jane Doe #13 came forward after press coverage revealed 
that Epstein passed a lie detector test saying that he didn't know any girls were under 18. 
Jane Doe #13 repeated that Epstein knew she was under 18 and also thought that Epstein 
knew that the recruiter also was 17. 
Credibility Issue 
While she was a juvenile, Jane Doe #13 was arrested for marijuana possession and 
shoplifting. 
IV. 
404(b) EVIDENCE 
The FBI's investigation has uncovered Epstein's activity with young girls dating back 
several years. In the early 1990's, Epstein flew a young high school girl to his ranch in New 
Mexico. Epstein and Ghislaine Maxwell (mentioned above) fondled the girl and encouraged 
her to engage in additional sexual activity, which she refused. The girl was from a "well-to-
do" family who threatened to report Epstein to the authorities. Since that time, Epstein has 
51 
EFTA00234567

not flown any other underage girls on his plane — it appears that someone counseled him not 
to do so to avoid getting into legal trouble.36 This girl and her family are terrified of speaking 
up about Epstein. One of them reported to the FBI that Ghislaine Maxwell had told her that 
she "could just disappear" if she told anyone what happened. When Vanity Fair found out 
about this and wrote a story about it, the reporter was approached by someone from Epstein's 
camp and became so fearful for her safety and the safety of her young child that the piece 
was rewritten to remove all references to any sexual conduct. That reporter has refused to 
speak to the FBI. 
Another woman who worked for Epstein in the early 1990's starting when she was 
15 now lives in Australia. Her family (who live in Colorado) and the young woman both 
expressed fear about talking to the authorities about Epstein and refused to provide any 
information to the FBI. 
A woman who worked at Epstein's building in New York several years ago spoke 
about innumerable underage girls going into Epstein's home to perform "massages." The 
property managers at Epstein's ranch in New Mexico report that Epstein travels there 
approximately 40 times each year and on every visit he receives "massages," although they 
refused to speculate on the ages of the "masseuses." 
And, as mentioned above, Tatum estimates that she brought thirty girls to Epstein's 
Palm Beach home during the 18 month period that she was in contact with him. 
I. 
OTHER ISSUES RAISED BY THE DEFENSE 
When you review the cover letter from Gerald Lefcourt (Appendix A), you will see 
that most of the letter is an attack on the police report and probable cause affidavit drafted 
by Det. Joe Recarey from PBPD. Neither document is ideal and his interviews of the girls 
and other investigative steps had some problems (although did an incredibly in-depth 
investigation for such a small police department). The defense also has complained 
repeatedly about the decision of the Palm Beach Police Chief to release information to the 
press and to complain loudly about State Attorney Barry Krisher's handling of the case. 
Giving the information to the press definitely did not help our investigation because it caused 
some of the girls to clam up, fearing more embarrassment. (It did, however, lead other girls 
to come forward and tell their stories.) 
36For example, Epstein told some of the girls that he "couldn't wait" for her to turn 18 so that 
he could take them on trips. 
52 
EFTA00234568

Very early in the investigation, the FBI and I decided to put Recarey's police report 
and PC Affidavit to the side and to look at the case with fresh eyes. The facts discussed 
herein are based upon a personal review of the audiotapes and videotapes of the girls' 
interviews, the tape of the state grand jury proceedings, follow-up interviews conducted by 
the FBI, and physical evidence seized during the search of Epstein's home, obtained via 
trashpulls, and obtained via grand jury subpoenas. 
CONCLUSION 
Based on tiling 
recommend that the Office approve the attached indictment 
charging Epstein, 
, JEGE, and Hyperion. I also recommend that 
the Office refuse a pre-indictment interview to Epstein or his counsel and that no information 
about the status of the case be shared to keep Epstein from fleeing from the jurisdiction. 
53 
EFTA00234569