This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00171800
28 pages
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AO 1O5 (SDNY Rev. 01(17) Application for a Search Warrant UNITED STATES DISTRICT COURT for the Southern District of New York In the Matter of the Search of (Briefly describe the property to be searched or identO the person by name and address) See Attached Affidavit and its Attachment A APPLICATION FOR A SEARCH AND SEIZURE WARRANT I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the property to be searched and give its location): located in the Southern District of New York , there is now concealed Menet& the person or describe the property to be .seized): See Attached Affidavit and its Attachment A The erliqs for the search under Fed. R. Crim. P. 41(c) is (check one or more): Invidence of a crime; O contraband, fruits of crime, or other items illegally possessed; O property designed for use, intended for use, or used in committing a crime; O a person to be arrested or a person who is unlawfully restrained. The search is related to a violation of: Code Section(s) 18 U.S.C. §§ 1591 and Sex trafficking of minors; sex trafficking conspiracy 371 The application is based on these facts: See Attached Affidavit and its Attachment A Offense Description(s) Continued on the attached sheet. O Delayed notice of days (give exact ending date if more than 30 days: under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. ttpplic et signature Sworn to before me and signed in my presence. Date: / A" Ck City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge ) is requested Printed name are (file judge's si; Printed name and title Tzto.Vga*. eiitAr4ke *191:ea UregeViva- USA0_004210 EFTA_00022120 EFTA00171800
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In the Matter of the Application of the United
States Of America for a Search and Seizure
Warrant for the Premises Known and Described
as 9 East 71st Street, New York, New York and
Any Closed Containers/Items Contained Therein
1 9111A6
572
TO BE FILED UNDER SEAL
Agent Affidavit in Support of
Application for Search and Seizure
Warrant
SOUTHERN DISTRICT OF NEW YORK) ss.:
"Ma
being duly sworn, deposes and says:
I. Introduction
A. Affiant
1.
I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since
2012. As such, I am a "federal law enforcement officer" within the meaning of Federal Rule of
Criminal Procedure 41(a)(2)(C), that is, a government agent engaged in enforcing the criminal
laws and duly authorized by the Attorney General to request a search warrant. I have been
employed by the FBI for three and a half years, and I am currently assigned to investigate violations
of criminal law relating to the sexual exploitation of children. I have gained expertise in this area
through classroom training and daily work related to these types of investigations. As part of my
responsibilities, I have been involved in the investigation of sex trafficking cases, and have been
involved in search warrants for physical premises.
2.
I make this Affidavit in support of an application pursuant to Rule 41 of the Federal
Rules of Criminal Procedure for a second warrant to search the premises specified below (the
"Subject Premises") for the purpose of
seizing the items and information described in
Attachment A. This affidavit is based upon my personal knowledge; my review of documents and
other evidence; and my conversations with other law enforcement personnel. Because this
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affidavit is being submitted for the limited purpose of establishing probable cause, it does not include all the facts that I have learned during the course of my investigation. Where the contents of documents and the actions, statements, and conversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated. B. The Subject Premises 3. The Subject Premises are particularly described as a multi-story, single-family residence located at 9 East 71st Street, New York, New York, and include all locked and closed containers found therein. As detailed further herein, the Subject Premises is believed to be owned, possessed and controlled by JEFFREY EPSTEIN, a target subject of this investigation. A photograph of the front entrance to the Subject Premises is included below: C. The Target Subject and the Subject Offenses 4. The Target Subject of this investigation is JEFFREY EPSTEIN. 5. For the reasons detailed below, I believe that there is probable cause to believe that the Subject Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United 2 2017.08.02 USAO_004212 EFTA_00022122 EFTA00171802
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States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject. U. Probable Cause and the First Warrant A. Probable Cause Regarding the Target Subject's Commission of the Subject Offenses 6. On or about July 2, 2019, a grand jury in this District returned an Indictment charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached hereto as Exhibit A and is incorporated by reference. B. Probable Cause Justifying Search of the Subject Premises The Indictment and Victim-1 7. As set forth in Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern District of New York and elsewhere. During that time and continuing to the present, EPSTEIN possessed and controlled the Subject Premises, which is described in Exhibit A as "the New York Residence." 8. As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous minor victims at the Subject Premises. In particular, and as alleged in the Indictment, when a victim arrived at the Subject Premises, she would be escorted to a room inside the Subject Premises with a massage table, where she would perform a massage on EPSTEIN. The victims, who wcre as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victims' genitals. EPSTEIN typically would also 3 2017.08.02 USAO_004213 EFTA_00022123 EFTA00171803
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masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. Following each encounter, EPSTEIN or one of his employees or associates paid the victim in cash. 9. As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to recruit additional minor girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victim- recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were underage, including because certain victims told him their age. 10. One of the victims identified in paragraph 22 of Exhibit A is Victim-I. As part of the FBI's investigation of EPSTEIN, other law enforcement officers have interviewed Victim-I.' I know from my conversations with other law enforcement officers who have interviewed Victim- I, that Victim-1 has provided the following information, in substance and in part: a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-I on multiple occasions in the Subject Premises. This sexual abuse all occurred when Victim-I was under the age of 18. b. During that same period, Victim-1 observed multiple floors of the Subject Premises and numerous individual rooms within the Subject Premises. Victim-1 has provided detailed s with the Government, Victim Victim-1 Information prow by Victim-I has proven reliable and has been corroborate' •y rmepen evidence, including documents and records obtained during the investigation and the accounts of other victims whom Victim-1 has never met. 4 2017.08.02 USAO_004214 EFTA_00022124 EFTA00171804
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descriptions of certain aspects of the interior of the Subject Premises, including Victim-1's memory of specific details regarding the layout, furnishings, decorations, and floor pattern of various areas within the Subject Premises. c. In particular, Victim-I observed that a bathroom in the residence contained what appeared to be a bust of a human torso (the "Torso"). Victim-1 believed that the Torso was possibly a type of sex toy. d. In addition, Victim-I recalled observing what appeared to be a taxidermied dog in a living space in the Subject Premises. e. Victim-1 recalled that EPSTEIN typically abused her in a room she described as a "massage room," (the "Massage Room"), which contained a massage table, and was decorated with artwork depicting naked women, hung on walls that appeared to be adorned with fabric. f. Victim-1 has not been in the Subject Premises since approximately 2005. The July 6.2019 Search Warrant of the Subject Premises 11. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the Subject Premises. The search warrant is attached as Exhibit B and incorporated by reference herein. 12. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the "Search Team") commenced executing the search warrant at the Subject Premises; I joined the Search Team thereafter. While inside the Subject Premises, I observed the following, among other things: a. Inside a closet within the entryway to a bathroom in the Subject Premises, I observed what appear to be two busts of female human torsos, from their upper pelvis to the neck. In addition, inside the bathroom, I observed a third bust, which appears to depict a female body 5 2017.08.02 USA() 004215 EFTA_00022125 EFTA00171805
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from the ribcage to the clavicle (collectively, (the "Busts"). The Busts do not appear to be designed for use as sex toys, and appear instead to be artwork. Nevertheless, based on my conversations with law enforcement officers who have interviewed Victim-1, I have learned that the Busts appear to be generally consistent with Victim-I's description of observing the Torso in EPSTEIN's bathroom in the Subject Premises. Accordingly, there is probable cause to believe that the Busts are corroborating evidence of Victim-I's description of the Subject Premises. b. Inside the Subject Premises, I observed a room that, based on my conversations with law enforcement officers who have interviewed Victim-1, appears to be consistent with Victim-I's descriptions of the Massage Room. The room contained a table covered with a sheet, and appears to be a massage table. The walls appear to be covered in a type of felt-like tapestry fabric. I further observed two paintings and three photographs hanging on the walls of the Massage Room. The paintings and photographs depict nude females. One of the photographs appears to depict a nude girl. Based on my training and experience investigating crimes involving the sexual exploitation of children, the girl appears to be approximately 15 to 20 years old. c. Inside the Subject Premises, inside a closet adjacent to a bathroom, I observed a shelf that appears to contain several black binders, with labels on the spine of each binder. In particular, one of the binders is marked with a series of labels, one of which reads: "PB Girls." Given that the Indictment charges EPSTEIN with participating in a conspiracy to engage in sex trafficking of minor girls in both Palm Beach, Florida and New York, I believe that "PB Girls" may refer to minor victims in Palm Beach, Florida. d. Inside the Subject Premises, in what appears to be EPSTEIN's office, on or about the second floor of the Subject Premises, I observed what appears to be a taxidermied dog (the "Dog"). Based on my conversations with law enforcement officers who have interviewed 6 2017.08.02 USAO_004216 EFTA_00022126 EFTA00171806
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Victim-1, the Dog appears to be consistent with Victim-I's description of observing a taxidermied dog in the Subject Premises. e. Inside the Subject Premises, I observed in plain view several sheets of stationary, with letterhead marked "Jeffrey Epstein." 13. After observing the foregoing items, the Search Team stopped the search and froze the scene in order to seek a new search warrant. ILL Conclusion and Ancillary Provisions 14. Based on the foregoing, given that several items described by Victim-I as being present in the Subject Premises in 2005 appear to be currently in the Subject Premises, I respectfully submit there is probable cause to believe that evidence of the Subject Offenses, and in particular the items described in Attachment A, will be located within the Subject Premises and therefore request the court to issue a warrant to seize the items and information specified in Attachment A to this affidavit and to the Search and Seizure Warrant. 15. The Search Team is currently at the Subject Premises, securing the location, and would anticipate executing the requested search warrant immediately. However, given the late hour, it is anticipated that the Search Team would commence executing the search warrant after 7 2017.08.02 USAO_004217 EFTA_00022127 EFTA00171807
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10 p.m. In view of the foregoing circumstances, I respectfully submit that the present circumstances demonstrate good cause to execute the warrant after 10 p.m. Special Agent Federal Bureau of Investigation Sworn to before me on July 6 019 THE HONORABLE BARBARA MOSES UNITED STATES MAGISTRATE JUDGE 8 2017.08.02 kits1K‘d0e. Mcci\C ,tea USAO_004218 EFTA_00022128 EFTA00171808
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EXHIBIT A 2017.01.02 USAO_004219 EF1,00022129 EFTA00171809
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED. STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x SEALED INDICTMENT 19 Cr. 19 CRIM 490 COUNT ONE (Sex Trafficking Conspiracy) The Grand Jury charges: OVERVIEW 1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and . abused dozens of minor girls at his homes in Manhattan, New . York, and Palm Beach, Florida, among other locations. 2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. Moreover, and in order to maintain and increase his supply of victims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In USAO 004220 EFTA_00022130 EFTA00171810
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this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in. locations including New York and Palm Beach. 3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age. 4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence. FACTUAL BACKGROUND 5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence. 6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and 2 USAO 004221 EFTA_00022131 EFTA00171811
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recruited, dozens of minor girls to engage in sex acts with him, after which EPSTEIN paid the victims hundreds of dollars in cash, at the New York Residence and the Palm Beach Residence. 7: In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to EPSTEIN, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. Moreover, EPSTEIN actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN. In so doing, EPSTEIN maintained a steady supply of new victims to exploit. The New York Residence 8. At all times relevant to this Indictment, JEFFREY EPSTEIN, the defendant, possessed and controlled a multi-story private residence on the Upper East Side of Manhattan, New York, i.e., the New York Residence. Between at least in or about 2002 and in or about 2005, EPSTEIN abused numerous minor victims at the New York Residence by causing these victims to be recruited to engage in paid sex acts with him. 3 USAO 004222 EFTA_00022132 EFTA00171812
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9. When a victim arrived at the New York Residence, she typically would be escorted to a room with a massage table, where she would perform a massage on JEFFREY EPSTEIN, the defendant. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. 10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, Paid the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter. 11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Further, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasion& at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed 4 USAO 004223 EFTA_00022133 EFTA00171813
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employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash.' Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter. In
addition, certain victim-recruiters routinely scheduled these
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encounters through Employee-1, who sometimes asked the
recruiters to bring a specific minor girl for EPSTEIN.
The Palm Beach Residence
14. In addition to recruiting and abusing minor girls
in New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence. EPSTEIN frequently
traveled from New York to Palm Beach by private jet, before
which an employee or associate would ensure that minor victims
were available for encounters upon his arrival in Florida.
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants ("Employee-2" and'
"Employee-3") who, as described herein, were also responsible
for scheduling sexual encounters with minor victims. Once
inside, the victim would provide a nude or semi-nude massage for
EPSTEIN, who would himself typically be naked. During these
encounters, EPSTEIN would escalate the nature and scope of the
physical contact to include sex acts such as groping and direct
and indirect contact with the victim's genitals. EPSTEIN would
also typically masturbate during these encounters, ask victims
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to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. 16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, • paid the victim in cash. Victims typically were paid hundreds of dollars for each encounter. . 17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions. 18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived, In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters. 7 USAO 004226 EFTA_00022136 EFTA00171816
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19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victim- recruiters for each additional girl they brought to the Palm Beach Residence. STATUTORY ALLEGATIONS 20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section. 1591(a) and (b). 21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a 8 USAO 004227 EFTA_00022137 EFTA00171817
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commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2). Overt Acts 22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter. b. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked,Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully. c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed 9 USAO 004228 EFTA_00022138 EFTA00171818
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a telephone call to Minor Victim-1 in order to schedule an appointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN. d. In or about 2004, Minor Victim-2 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars after each encounter. EPSTEIN also encouraged and enticed Minor Victim-2 to recruit other girls to engage in paid sex acts, which she did. e. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-2 in order to schedule an appointment for Minor Victim-2 to engage in paid sex acts with EPSTEIN. f. In or about 2005, Minor Victim-3 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-3 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-3 how old she was, and Minor Victim-3 answered truthfully. 10 USAO 004229 EFTA_00022139 EFTA00171819
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