EFTA00313640

Case 1:17-cv-00616 Document 1 Filed 01/26/17 Page 7 of 21 
promises, coercion, and threats of coercion in order to entice young females into 
sex and, once sexual activities ensued, to cause them to remain in the enterprise. 
The Defendants also transported females in interstate and foreign commerce and in 
ways that affected interstate and foreign commerce. 
22. 
Defendants 
specifically 
targeted 
underprivileged, 
emotionally 
vulnerable and/or economically disadvantaged young females to join the 
Defendants' enterprise. 
23. 
It is unknown exactly how long Defendant Epstein and Maxwell's 
aforementioned criminal and illegal enterprise operated, although it was at least 
continuously and actively in operation from the mid-1990's through and including 
the calendar year 2007. 
24. 
Defendant Epstein has continued the enterprise and conspiracy up to 
the present time. 
25. 
In 2005, Defendant Epstein and numerous co-conspirators within the 
enterprise were the subjects of a Palm Beach, Florida Police Department criminal 
investigation which revealed that Defendant Epstein had engaged in sexual 
activities with dozens of young teenage children. Each child was lured into 
Defendant Epstein's Palm Beach mansion with a promise that she would receive 
money for providing him with a body massage, although once there, each child 
was made to engage in a sex act in order to receive the promised compensation. 
EFTA00313640