EFTA00194923

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(a)(2) 
18 U.S.C. § 2422(10 
18 U.S.C. § 2423(e) 
18 U.S.C. § 2423(d) 
18 U.S.C. § 2423(10 
UNITED STATES OF AMERICA 
vs. 
JEFFREY EPSTEIN, 
a/k/a 
and 
Defendants. 
The Grand Jury charges that: 
9! 
INDICTMENT 
BACKGROUND 
At all times relevant to this Indictment: 
1. 
Defendant JEFFREY EPSTEIN employed defendants 
-
a/k/a 
" and 
to perform, among other things, 
services as personal assistants. 
1. 
Defendants JEFFREY EPSTEIN and 
paid T.M., H.R., and A.F. to 
perform, among other things, recruiting services. 
2. 
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"). 
3. 
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. 
4. 
Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder 
of JEGE, INC., and had the power to direct all of its operations. 
5. 
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. 
EFTA00194923

6. 
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. 
7. 
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] nor a bona fide 
belief that such person is over the specified age [shall] be a defense." 
8. 
Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), 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 so 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. 
9. 
Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who 
[i]ntentionally touches a person under 16 years 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. 
10. 
Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who: (1) 
[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. 
11. 
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]." 
12. 
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]." 
EFTA00194924

13. 
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." 
14. 
Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical 
license. 
15. 
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. 
16. 
During the period of her involvement with the Defendants, Jane Doe #5 attended 
Wellington High School in Palm Beach County. 
17. 
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. 
18. 
During the period of her involvement with the Defendants, Jane Doe #7 attended 
William T. Dwyer High School in Palm Beach County. 
19. 
During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 
17, 18, and 19 attended Royal Palm Beach High School in Palm Beach County. 
20. 
During the period of her involvement with the Defendants, Jane Doe #10 attended Lake 
Worth High School in Palm Beach County. 
21. 
During the period of her involvement with the Defendants, Jane Doe #11 attended 
Jeaga Middle School in Palm Beach County. 
22. 
During the period of her involvement with the Defendants, Jane Doe #13 attended John 
I. Leonard High School in Palm Beach County. 
COUNT 1 
(Conspiracy: 18 U.S.C. § 371) 
1. 
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference 
as though fully set forth herein. 
2. 
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, 
JEFFREY EPSTEIN, 
a/k/a ' 
and 
II 
EFTA00194925

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 or foreign 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
1. 
It was the purpose and object of the conspiracy to procure females under the age of 18 
to travel to 358 El Brillo Way 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. 
Manner and Means 
1. 
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 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 other 
participants would make payments to, or cause payments to be made to, minor females in exchange for 
engaging in lewd conduct. 
(c) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, 
a/k/a 
and other participants would ask females to 
recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN. 
(d) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, 
a/k/a "
I," and other participants would make payments 
to, or cause payments to be made to, the recruiters for bringing additional minor females to 358 El Brillo 
Way 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. 
EFTA00194926

Overt Acts 
1. 
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 Jane Doe #1, 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, Defendant JEFFREY 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 a fourteen-years-old girl, to pinch his nipples while he masturbated. 
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 March 11, 2003, Defendant JEFFREY EPSTEIN reviewed a 
written telephone message prepared by one of his employees 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 would be interested in engaging in similar sexual activities 
with him. 
EFTA00194927

11. 
In or around 2003, Defendant 
took nude photographs of 
Jane Doe #2, who was then a sixteen-year-old girl. 
12. 
In or around 2003, Defendant 
made a payment of $500 to 
Jane Doe #2 in exchange for posing for nude photographs. 
13. 
In or around 2003, Defendant 
told Jane Doe #2 that 
Defendant JEFFREY EPSTEIN had asked ICELLEN 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, 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. 
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 
1. 
In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #3, who was then a fifteen-year-old girl. 
2. 
In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to 
Jane Doe #3. 
3. 
On or about October 26, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #3. 
4. 
On or about October 30, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #3. 
5. 
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. 
EFTA00194928

6. 
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. 
7. 
In or around 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to 
Jane Doe #3. 
8. 
In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #3 to 
rub his nipples. 
9. 
In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device 
on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. 
10. 
In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 to 
recruit additional females to come to 358 El Brillo Way. 
11. 
On or about November 8, 2004, Defendant JEFFREY EPSTEIN reviewed a 
written telephone message prepared by one of his employees regarding a telephone call 
received from Jane Doe #3 that read: "I have a female for him." 
12. 
On or about January 14, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #3. 
13. 
On or about January 29, 2005, Defendant JEFFREY EPSTEIN reviewed a 
written telephone message prepared by one of his employees regarding a telephone call 
received from Jane Doe #3 that read: "I have a female for him." 
Jane Does #4, #5, and #6 
1. 
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. 
2. 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN learned that 
Jane Doe #4 was seventeen years old when he asked Jane Doe #4 about her age, and Jane 
Doe #4 responded with her true age. 
3. 
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, and 
Jane Doe #5, who was then a seventeen-year-old girl. 
4. 
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. 
EFTA00194929

5. 
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. 
6. 
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. 
7. 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 
to Jane Doe #4. 
8. 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 
to Jane Doe #5. 
9. 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane 
Doe #6 what high school she attended. 
10. 
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. 
11. 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
masturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl. 
12. 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN digitally 
penetrated Jane Doe #6, who was then a sixteen-year-old girl. 
13. 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN placed a 
large vibrating massager on the vagina of Jane Doe #6, who was then a sixteen-year-old girl. 
14. 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN caused a 
payment of $200 to be made to Jane Doe #6. 
Jane Does #7 and #8 
1. 
In or around July 2004, Defendant JEFFREY EPSTEIN led T.M., who was 
then a fifteen-year-old girl, and Jane Doe #7, who was then a sixteen-year-old girl, from the 
kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom. 
2. 
On or about July 4, 2004, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #7. 
3. 
On or about July 5, 2004, Defendant 
placed a telephone 
call to a telephone used by T.M. 
4. 
In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #8, who was then a seventeen-year-old girl. 
EFTA00194930

5. 
In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of 
Jane Doe #8, who was then a seventeen-year-old girl. 
6. 
In or around July 2004, Defendant JEFFREY EPSTEIN paid approximately 
$200 to Jane Doe #8. 
7. 
In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to T.M. for 
recruiting Jane Doe #8 to travel to 358 El Brillo Way. 
8. 
In or around July 2004, Defendant 
told Jane Doe #8 that 
Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a friend. 
9. 
On or about July 15, 2004, Defendant 
call to a telephone used by Jane Doe #7. 
10. 
On or about July 15, 2004, Defendant 
call to a telephone used by Jane Doe #8. 
11. 
On or about July 15, 2004, Defendant 
call to a telephone used by T.M. 
12. 
On or about July 16, 2004, Defendant 
telephone calls to a telephone used by Jane Doe #7. 
13. 
On or about July 16, 2004, Defendant 
call to a telephone used by T.M. 
placed a telephone 
placed a telephone 
placed a telephone 
placed one or more 
placed a telephone 
1. 
On or about July 17, 2004, Defendant JEFFREY EPSTEIN reviewed a written 
telephone message prepared by one of his employees regarding a telephone call received 
from T.M. that read: "Me & [Jane Doe #7] can come tomorrow any time or [T.M.] alone". 
2. 
In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #7, who was then a sixteen-year-old girl. 
3. 
In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe 
#7, who was then a sixteen-year-old girl, to rub his nipples. 
4. 
In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of 
Jane Doe #7, who was then a sixteen-year-old girl. 
5. 
In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of 
$200 to Jane Doe #7. 
EFTA00194931

6. 
In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe #7 that 
if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN's home, bad 
things could happen to her. 
7. 
On or about July 24, 2004, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #8. 
Jane Does #9 and #10 
1. 
On or about July 15, 2004, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #9. 
2. 
On or about July 16, 2004, Defendant 
caused Jane Doe #9 
to make a telephone call to a telephone used by Jane Doe #10. 
3. 
On or about July 17, 2004, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #9. 
4. 
On or about July 18, 2004, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #9. 
5. 
On or about July 22, 2004, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #9. 
6. 
In or around July 2004, Defendant JEFFREY EPSTEIN fondled the breasts of 
Jane Doe #9, who was then a seventeen-year-old girl. 
7. 
In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #9, who was then a seventeen-year-old girl. 
8. 
In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of 
$200 to Jane Doe #9. 
9. 
On or about July 22, 2004, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #10. 
10. 
In or around the last half of 2004, Defendants JEFFREY EPSTEIN and 
engaged in oral sex and sexual intercourse in the presence of Jane 
Doe #9, who was then a seventeen-year-old girl. 
11. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly 
inserted his penis into the vagina of Jane Doe #9, who was then a seventeen-year-old girl. 
EFTA00194932

12. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a 
payment of $300 to Jane Doe #9. 
13. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN rubbed the 
vagina of Jane Doe #10, who was then a seventeen-year-old girl. 
14. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a 
payment of $200 to Jane Doe #10. 
15. 
On or about November 28, 2004, Defendant JEFFREY EPSTEIN arranged for 
one of his employees to provide an envelope filled with cash to Jane Doe #9. 
16. 
On or about December 4, 2004, Defendant 
provided a 
written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 9 and 10, stating: 
"[Jane Doe #10] would like to work @ 4:00 pm if possible. [[Jane Doe #9] is scheduled for 
5:00 today.] the movie is @ 7:30". 
17. 
On or about December 29, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #9. 
18. 
On or about December 30, 2004, Defendants JEFFREY EPSTEIN and 
caused the purchase of Broadway tickets as an eighteenth birthday gift 
for Jane Doe #9. 
19. 
In or around the last half of 2004 or January 2005, Defendant JEFFREY 
EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen-year-old 
girl. 
20. 
In or around the last half of 2004 or January 2005, Defendant JEFFREY 
EPSTEIN fondled the breasts of Jane Doe #10, who was then a seventeen-year-old girl. 
21. 
On or about January 14, 2005, Defendant 
more telephone calls to a telephone used by Jane Doe #10. 
22. 
On or about January 27, 2005, Defendant 
placed one or 
a/k/a a 
la" 
placed one or more telephone calls to a telephone used by Jane Doe #10. 
23. 
On or about January 28, 2005, Defendant 
more telephone calls to a telephone used by Jane Doe #10. 
24. 
On or about February 1, 2005, Defendant 
or more telephone calls to a telephone used by Jane Doe #10. 
placed one or 
placed one 
EFTA00194933

25. 
In or around February 2005, Defendant JEFFREY EPSTEIN caused a payment 
of $200 to be made to Jane Doe #9 for recruiting Jane Doe #16 to travel to 358 El Brillo 
Way. 
Jane Doe #11 
1. 
In or around the summer of 2004, Defendant 
led Jane Doe 
#11 and T.M. from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY 
EPSTEIN's master bedroom suite. 
2. 
In or around the summer of 2004, Defendant JEFFREY EPSTEIN paid $200 to 
T.M. for bringing Jane Doe #11 to 358 El Brillo Way. 
3. 
In or around the summer of 2004, Defendant JEFFREY EPSTEIN masturbated 
in the presence of Jane Doe #11, who was then a fifteen- or sixteen-year-old girl. 
4. 
In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed 
Jane Doe #11 to rub his chest and pinch his nipples while he masturbated. 
5. 
In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed 
Jane Doe #11 to write her telephone number on a notepad in his master bedroom suite. 
6. 
In or around the summer of 2004, Defendant JEFFREY EPSTEIN learned Jane 
Doe #11's true age when he asked Jane Doe #11 how old she was and she responded 
truthfully. 
7. 
In or around the summer of 2004, Defendant JEFFREY EPSTEIN told Jane 
Doe #11 that he did not care how old she was and that he did not like girls older than 
eighteen. 
8. 
In or around the second half of 2004, Defendant JEFFREY EPSTEIN placed a 
vibrating massager on the vagina of Jane Doe #11, who was then a sixteen-year-old girl. 
9. 
In or around the second half of 2004, Defendant JEFFREY EPSTEIN digitally 
penetrated the vagina of Jane Doe #11, who was then a sixteen-year-old girl. 
10. 
On or about August 6, 2004, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #11. 
11. 
On or about August 18, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #11. 
EFTA00194934

12. 
On or about October 29, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #11. 
13. 
On or about November 5, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #11. 
14. 
On or about February 14, 2005, Defendant JEFFREY EPSTEIN reviewed a 
written telephone message prepared by one of his employees regarding a telephone call 
received from Jane Doe #11 that read: "Please! Call her back". 
15. 
On or about February 14, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #11. 
16. 
On or about February 21, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #11. 
17. 
On or about March 29, 2005, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #11. 
18. 
In or around the second half of 2005 or the first quarter of 2006, Defendant 
JEFFREY EPSTEIN offered to pay $400 to Jane Doe #11, who was then a sixteen-year-old 
girl, if she would engage in oral sex, or $500 or more if she would engage in sexual 
intercourse. 
19. 
In or around the second half of 2005, Defendant JEFFREY EPSTEIN offered 
to pay $100 to Jane Doe #11 if she would bring other girls to 358 El Brillo Way. 
Jane Does #12 and #13 
I. 
On or about August 2, 2004, Defendant JEFFREY EPSTEIN reviewed a 
written telephone message prepared by one of his employees regarding a telephone call 
received from T.M. and Jane Doe #12 that stated: "They are available all weekend and 
maybe [Jane Doe #13] too". 
2. 
On or about August 21, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #13. 
3. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated 
in the presence of Jane Doe #12, who was then a seventeen-year-old girl. 
4. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally 
penetrated Jane Doe #12, who was then a seventeen-year-old girl. 
EFTA00194935

5. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to 
place a massaging device on the vagina of Jane Doe #12, who was then a seventeen-year-old 
girl. 
6. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a 
payment of $200 to Jane Doe #12. 
7. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane 
Doe #12, who was then a seventeen-year-old girl, about her age. 
8. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane 
Doe #12 that he would take her to Los Angeles when she turned eighteen. 
9. 
In or around the last half of 2004, Defendants JEFFREY EPSTEIN and 
caused Jane Doe #12 to recruit Jane Doe #13 to travel to 358 El Brillo 
Way. 
10. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated 
in the presence of Jane Doe #13, who was then a seventeen-year-old girl. 
11. 
In or around the end of 2004, Defendant JEFFREY EPSTEIN placed a 
massaging device on the vagina of Jane Doe #13, who was then a seventeen-year-old girl. 
12. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a 
payment of $200 to Jane Doe #13. 
13. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally 
penetrated Jane Doe #13, who was then a seventeen-year-old girl. 
1. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane 
Doe #13, who was then a seventeen-year-old girl, about her age. 
2. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane 
Doe #13 that he wanted to take her to Paris but he could not because Jane Doe #13 was not 
yet eighteen years old. 
3. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane 
Doe #13 to bring her friends to his home, especially "girls who looked like [Jane Doe #13]." 
Jane Doe #14 
1. 
In or around the last half of 2004, Defendant 
led Jane Doe 
#14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's 
EFTA00194936

bedroom at 358 El Brillo Way. 
2. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane 
Doe #14 to provide her telephone number. 
3. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed 
Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples. 
4. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated 
in the presence of Jane Doe #14, who was then a seventeen-year old girl. 
5. 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a 
payment of $300 to Jane Doe #14. 
6. 
In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY 
EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeen-year-old girl. 
7. 
In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY 
EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl, whether she had any 
plans for her eighteenth birthday and acknowledged that she had not yet turned eighteen. 
8. 
On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a 
Western Union wire transfer order to be sent to Jane Doe #14. 
9. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a 
massaging device on the vagina of Jane Doe #14, who was then a seventeen-year-old girl. 
10. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged 
in sexual intercourse with Jane Doe #14, who was then a seventeen-year-old girl. 
11. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN 
performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl. 
12. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a 
payment of $600 to Jane Doe #14. 
13. 
On or about January 8, 2005, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #14. 
14. 
On or about January 9, 2005, Defendant 
a/k/a a 
placed a telephone call to a telephone used by Jane Doe #14. 
15. 
On or about January 26, 2005, Defendant 
a/k/a 
reviewed a written telephone message prepared by one of Defendant JEFFREY 
EFTA00194937

EPSTEIN's employees regarding a call received from Jane Doe #14 that read: "She is 
confirming for 5:30". 
16. 
On or about January 26, 2005, Defendant 
a/k/a a 
placed a telephone call to a telephone used by Jane Doe #14. 
17. 
On or about February 1, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #14. 
18. 
On or about March 1, 2005, Defendant 
a/k/a a 
placed a telephone call to a telephone used by Jane Doe #14. 
19. 
On or about March 21, 2005, Defendant 
a/k/a a 
placed a telephone call to a telephone used by Jane Doe #14. 
20. 
On or about March 29, 2005, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #14. 
Jane Doe #15 
1. 
On or about December 6, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #15. 
2. 
On or about December 14, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #15. 
3. 
In or around the first half of 2005, Defendant 
led Jane Doe 
#15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's 
bedroom at 358 El Brillo Way. 
4. 
In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed 
Jane Doe #15, who was then a seventeen-year-old girl, to pinch his nipples while he 
masturbated. 
5. 
In or around the first half of 2005, Defendant JEFFREY EPSTEIN fondled the 
breasts of Jane Doe #15. 
6. 
In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a 
payment of $200 to Jane Doe #15. 
7. 
On or about January 7, 2005, Defendant 
a/k/a a 
," placed a telephone call to a telephone used by Jane Doe #15. 
EFTA00194938

8. 
On or about February 4, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #15. 
9. 
On or about February 10, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #15. 
10. 
On or about February 21, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #15. 
11. 
On or about February 24, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #15. 
12. 
On or about March 17, 2005, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #15. 
13. 
On or about March 30, 2005, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #15. 
14. 
On or about March 31, 2005, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #15. 
15. 
On or about March 31, 2005, Defendant I
, a/k/a `a 
1," placed a telephone call to a telephone used by Jane Doe #15. 
16. 
On or about April 1, 2005, Defendant JEFFREY EPSTEIN reviewed a note 
prepared by one of his employees that read: "10:30 [Jane Doe #15]/[Jane Doe #10] on Fri 
around 2'Oclock". 
17. 
In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane Doe 
#15 with a gift of Victoria's Secret lingerie for her eighteenth birthday. 
Jane Does #16 & #17 
I. 
In or around February 2005, Defendant JEFFREY EPSTEIN masturbated in 
the presence of Jane Doe #16, who was then a seventeen-year-old girl. 
2. 
In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and 
caused Jane Doe #16 to place a telephone call to Jane Doe #17 to ask her 
to travel to 358 El Brillo Way. 
3. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN caused a 
payment to be made to Jane Doe #16 for recruiting Jane Doe #17 to travel to 358 El Brillo 
Way. 
EFTA00194939

4. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN 
masturbated in the presence of Jane Doe #17, who was then a sixteen-year-old girl. 
5. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN 
instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her clothing. 
6. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a 
massaging device on the vagina of Jane Doe #17, who was then a sixteen-year-old girl. 
7. 
In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a 
payment of $200 to Jane Doe #17, who was then a sixteen-year-old girl. 
8. 
In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN 
placed a massaging device on the vagina of Jane Doe #16, who was then a seventeen-year-
old girl. 
9. 
In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN 
asked Jane Doe #16, who was then a seventeen-year-old girl, how old she was, and she 
responded that she was seventeen years old. 
10. 
In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN 
engaged in sexual activity with Defendant 
in the presence of Jane 
Doe #16, who was then a seventeen-year-old girl. 
11. 
In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN 
asked Jane Doe #16, who was then a seventeen-year-old girl, to touch the breast of 
Defendant 
12. 
On or about April 11, 2005, Defendant l
l a/k/a a 
l
l," placed a telephone call to a telephone used by Jane Doe #16. 
13. 
On or about April 11, 2005, Defendant 
placed a telephone 
call to a telephone used by Jane Doe #16. 
14. 
On or about April 11, 2005, Defendant 
left a message for 
Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] can work tomorrow at 4pm." 
15. 
On or about May 19, 2005, Defendant 
call to a telephone used by Jane Doe #16. 
16. 
On or about June 30, 2005, Defendant 
call to a telephone used by Jane Doe #16. 
placed a telephone 
placed a telephone 
EFTA00194940

17. 
On or about July 2, 2005, Defendant 
call to a telephone used by Jane Doe #16. 
18. 
On or about July 22, 2005, Defendant 
call to a telephone used by Jane Doe #16. 
19. 
On or about August 18, 2005, Defendant 
telephone call to a telephone used by Jane Doe #16. 
20. 
On or about August 19, 2005, Defendant 
l
l," placed a telephone call to a telephone used by Jane Doe #16. 
21. 
On or about August 21, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #16. 
22. 
On or about September 3, 2005, Defendant l
l, a/lc/a a 
l
l," placed a telephone call to a telephone used by Jane Doe #16. 
23. 
On or about September 18, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #16. 
24. 
On or about September 19, 2005, Defendant 
sent a text 
message to a telephone used by Jane Doe #16. 
25. 
On or about September 29, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #16. 
26. 
On or about September 30, 2005, Defendant 
a/lc/a a 
l
l," placed a telephone call to a telephone used by Jane Doe #16 
27. 
On or about October 1, 2005, Defendant 
message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #15] 
and [Jane Doe #16] — 4PM". 
28. 
On or about October 2, 2005, Defendant 
call to a telephone used by Jane Doe #16. 
29. 
On or about October 3, 2005, Defendant 
call to a telephone used by Jane Doe #16. 
30. 
On or about October 3, 2005, Defendant 
placed a telephone 
placed a telephone 
placed a 
a/lc/a a 
•
 
left a telephone 
confirmed at 11 AM 
placed a telephone 
placed a telephone 
left a telephone 
message for Defendant JEFFREY EPSTEIN stating: "[Jane Doe #16] will be 1/2 hour late". 
EFTA00194941

31. 
In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN 
engaged in sexual intercourse with Jane Doe #16, who was then a seventeen-year-old girl. 
32. 
In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN 
made a payment of $350.00 to Jane Doe #16, who was then a seventeen-year-old girl. 
33. 
In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN 
provided a gift of Victoria's Secret lingerie to Jane Doe #16 for her eighteenth birthday. 
Jane Does #18 and #19 
1. 
In or around the last half of 2003, Jane Doe #18 was approached by A.F. and 
was asked whether she would be willing to provide a massage to Defendant JEFFREY 
EPSTEIN in exchange for $200. 
2. 
In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane 
Doe #18 to provide her telephone number. 
3. 
On or around August 27, 2003, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #18. 
4. 
In or around the last half of 2003, Defendant JEFFREY EPSTEIN masturbated 
in the presence of Jane Doe #18, who was then a seventeen-year-old-girl. 
5. 
On or around November 16, 2003, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #18. 
6. 
In or around the last half of 2003, Defendant JEFFREY EPSTEIN digitally 
penetrated Jane Doe #18, who was then a seventeen-year-old-girl. 
7. 
In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane 
Doe #18 to recruit other females to travel to 358 El Brillo Way. 
8. 
On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane Doe 
#19, who was then a seventeen-year-old girl, to leave when she refused to remove her shirt. 
9. 
On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally 
reprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she was 
not willing to undress for him. 
The Defendants' Travel 
1. 
On or about July 16, 2004, Defendants JEFFREY EPSTEIN, 
and 
traveled from Teterboro, New Jersey to Palm Beach 
EFTA00194942