EFTA00225102

Manner and Means 
29. 
The manner and means by which the Defendants and other participants sought 
to acco414 the purpose and object of the conspiracy included the following: 
(a) 
It was part of the conspiracy that Defendants 
11 
and other 
participants would contact minor females via the use of cellular and other telephones to 
arrange appointments„fotr minor females to travel to 358 El Brillo Way and the New York 
ete: 
residence to allow Deibridant JEFFREY EPSTEIN to engage in lewd conduct with them. 
(b) 
It was further, a part of the conspiracy that Defendants JEFFREY 
EPSTEIN, 
, and 
11 
, and other participants would make payments to, or cause payments to be 
made to, minor females in exchanglibr engaging in lewd conduct. 
(c) 
It was further a part of the conspiracy that Defendants JEFFREY 
EPSTEIN, MM
, 
aikia "=
" and other 
participants would ask females to recruit other minor females to engage in lewd conduct with 
Defendant JEFFREY EPSTEIN.
EPSTEIN, 
01 
It was further a part of threonspiracy that Defendants JEFFREY 
' and other 
participants would make payments to, or cause payments to be made.to, the recruiters for 
7 
EFTA00225222

bringing additional minor females to 358 El Brillo Way and the New York residence to 
engage in lewd conduct with Defendant JEFFREY EPSTEIN. 
I . 
, . 
(e) 
It was further a part of the conspiracy that Defendant JEFFREY 
EPSTEIN would pay minor females to engage in lewd conduct with Defendant 
to satisfy Defendant JEFFREY EPSTEIN's prurient interests. 
Overt Acts 
30. 
In furtherance of this conspiracy and to effect the objects thereof, there was 
It; 
committed by at leasetnie 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 wt 
ane 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, DefendanfiEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #2, who was then a fourteen-year-old girl. 
(4) 
In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, 
who was then fourteen years' old, to pinch his nipples while he masturbated. 
8 
11 
EFTA00225223

(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 IviAtth 11, 2003, an employee of Defendant JEFFREY 
EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's 
review regarding a telephone call received from Jane Doe #2. 
(10) 
In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 
if she had any younger friends who would be interested in engaging in similar 
activities with him. 
(11) 
In or around 2003, Defendant 
took nude photographs 
of Jane Doe #2, who was then a sixteen-year-old girl. 
9 
EFTA00225224

(12) 
In or around 2003, Defendant 
KELLEN made a payment of 
$500 to Jane Doe #2 in exchange for posing for nude photographs. 
.
i. 
 
(13) 
In or around 2003, Defendant 
told Jane Doe #2 that 
Defendant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane 
Doe #2. 
(14) 
In or arounI2003, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jatie.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 SARAH KELLEN 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. 
• 
4.• 
(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 SARAH 
placed a 
telephone call to a telephone used by Jane pcie #2. 
Jane Doe -43 
(19) 
In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #3, who was then a fifteen-year-old girl. 
10 
EFTA00225225

(20) 
In or around 2003, Defendant JEFFREY EPSTEIN made. a payment of 
$200 to Jane Doe #3. 
(21) On or about October 26, 2004, Defendant SARAH 
placed a 
telephone call to a telephone used by Jane Doe #3. 
(22) On or about October 30, 2004, Defendant IMI= 
placed a 
telephone call to a telephone used by Jane Doe #3. 
(23) 
ItLcir around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe 
#3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and 
to touch the adult female's breasts. 
(24) 
In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging 
device on the vagina of an adult female in the presence of Jane Doe #3, who was then 
a sixteen- or seventeen-year-,girl. 
(25) 
In or around 2004, Defendant JEFFREY EPSTEIN made a payment of 
$200 to Jane Doe #3. 
(26) In or arounI2004, Defendant JEFFREY EPSTEIN instructed Jane Doe 
#3 to rub his nipples. 
(27) In or around 2004, Defendant4JEFFREY EPSTEIN placed a massaging 
device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old 
girl-
11 
EFTA00225226

(28) 
In or aroun12004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 
to recruit additional females to come to 358 El Brillo Way. 
(29) On or about November 8, 2004, one of Defendant JEFFREY 
EPSTEIN's employees prepared a written telephone message for Defendant 
JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 
that read: "I have a female for him." 
(30) qn„or about January 14, 2005, Defendant ME 
placed a 
rney
telephone call to 'telephone used by Jane Doe #3. 
(31) 
On or about January 29, 2005, one of Defendant JEFFREY EPSTEIN's 
employees prepared a written telephone message for Defendant JEFFREY 
EPSTEIN's review regarding a telephone call received from Jane Doe #3 that read: 
"I have a female for him." L\ 
Jane Does #4. O. and #6 
(32) 
In or around the first half of 2004, Defendant 
led 
Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El 
Brillo Way. 
(33) 
In or around the first half df 2004, Defendant JEFFREY EPSTEIN 
asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. 
12 
EFTA00225227

(34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, 
+Clime Doe #5, who was then a seventeen-year-old girl. 
(35) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
instructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his 
nipples. 
(36) In‘or around the first half of 2004, Defendant JEFFREY EPSTEIN 
instructed Jand Doe #4, who was then a seventeen-year-old girl, to remove her 
clothing. 
(37) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
stroked the vagina of Jane Doe #4, who was then a seventeen-year-old girl. 
(38) 
In or around the4lkst half of 2004, Defendant JEFFREY EPSTEIN paid 
$200 to Jane Doe #4. 
(39) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid 
$200 to Jane Doe #5. 
(40) 
In or around the first half or004, Defendant JEFFREY EPSTEIN 
asked Jane Doe #6 what high school she attended. 
(41) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone. 
13 
2 
EFTA00225228

(42) 
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. 
(43) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
digitally penetrated Jane'Doe #6, who was then a sixteen-year-old girl. 
(44) 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-odd girl. 
(45) Irit around the first half of 2004, Defendant JEFFREY EPSTEIN 
caused a payment of $200 to be paid to Jane Doe #6. 
Jane Does #7 and #8 
(46) 
In or around July 2004, Defendant JEFFREY EPSTEIN led.., who 
was then a fifteen-year-old gAkand Jane Doe #7, who was then a sixteen-years-old 
girl, from the kitchen of 358 El Brill° Way upstairs to Defendant JEFFREY 4 --
EPSTEIN's bedroom at 358 El Brillo Way. 
(47) On or about July 4, 2004, Defendant 
made one pr 
more telephone calls to a telephone used blr Jane Doe #7. 
(48) 
On or about July 5, 2004, Defendant 
placed a 
telephone call to a telephone used by 
14 
rr 
EFTA00225229

(49) 
In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in 
the presence of Jane Doe #8, who was then a seventeen-year-old girl. 
(50) 
In or around July 2004, Defendant JEFFREY EPSTEIN stroked the 
vagina of Jane Doe #8, who was then a seventeen-year-old girl. 
(51) 
In or around July 2004, Defendant JEFFREY EPSTEIN paid 
approximately $200 to Jane Doe #8. 
(52) 
In-or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to 
M. for recruiting Jane Doe #8 to travel to 358 El Brillo Way. 
(53) 
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. 
(54) 
On or about Jul); 15, 2004, Defendant 
more telephone calls to a telephone used by Jane Doe ii7. 
(55) 
On or about July 15, 2004, Defendant 
telephone call to a telephone used by Jane Doe #8. 
(56) 
On or about July IS, 2004„Defendant 
KELLEN placed one or 
placed a 
placed a 
telephone call to a telephone used by T.M. • 
(57) 
On or about July 16, 2004, Defendant MI=I 
placed one or 
more telephone calls to a telephone used by Jane Doe #7. 
15 
EFTA00225230

(58) On or about July 16, 2004, Defendant 
placed a 
telephone call to a telephone used by ■. 
11:23 (59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's 
employees prepared a written telephone message for Defendant JEFFREY 
EPSTEIN's review regarding a telephone call received from 
that read: "Me & 
[Jane Doe #7] can come tomorrow any time or [■.] alone". 
(60) 
19 or around July 2004, Defendant JEFFREY EPSTEIN masturbated in 
the presence oflane Doe #7, who was then a sixteen-year-old girl. 
(61) 
In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane 
Doe #7, who was then a sixteen-year-old girl, to rub his nipples. 
(62) 
In or around July 2004, Defendant JEFFREY EPSTEIN stroked the 
vagina of Jane Doe #7, who Wa then a sixteen-year-old girl. 
(63) 
In or around July 2004, Defendant JEFFREY EPSTEIN made a 
payment of $200 to Jane Doe #7. 
(64) 
In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe 
#7 that if she reported to anyone what•lad occurred at Defendant JEFFREY 
EPSTEIN's home, bad things could happeti to her. 
(65) On or about July 24, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #8. 
16 
EFTA00225231

Jane Does #9 and #10 
(66) 
On or about July 15, 2004, Defendant 
KELLEN placed one or 
more telephone calls to a telephone used by Jane Doe #9. 
(67) 
On or about July 16, 2004, Defendant 
caused Jane 
Doe #9 to make one or more telephone calls to a telephone used by Jane Doe #10. 
(68) 
On or about July 17, 2004, Defendant 
telephone call to.a telephone used by Jane Doe #9. 
(69) 
On or about July 18, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #9. 
(70) 
On or about July 22, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #9. 
(71) 
In or around JuiY2004, Defendant JEFFREY EPSTEIN fondled the 
breasts of Jane Doe #9, who was then a seventeen-year-old girl. 
(72) 
In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in 
the presence of Jane Doe #9, who was then a seventeen-year-old girl. 
(73) 
In or around July 2004, Defendant JEFFREY EPSTEIN made a 
payment of $200 to Jane Doe #9. 
(74) 
On or about July 22, 2004, Defendant 
telephone call to a telephone used by Jane Doe 410. 
At 
17 
placed a 
placed a 
EFTA00225232

(75) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and 
engaged in oral sex and sexual intercourse in the presence 
4 fitne Doe #9, who was then a seventeen-year-old girl. 
(76) 
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. 
(77) 
around the last half of 2004, Defendant JEFFREY EPSTEIN made 
a payment of $3040* to Jane Doe #9. 
(78) 
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. 
(79) 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN made 
a payment of $200 to Jane D it10. 
(80) 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. 
(81) On or about December 4, 
efendant 
provided 
200r
-4 
a written message to Defendant JEFFREY 
STEIN 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". 
(82) On or about December 29, 2004, Defendant 
placed 
a telephone call to a telephone used by Jane Doe #9. 
18 
EFTA00225233

(83) 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. 
(84) In or around the last half o f 2004 or January 2005, Defendant JEFFREY 
EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen-
year-old girl. 
(85) In oy around the last half of 2004 or January 2005, Defendant JEFFREY 
EPSTEIN fondled the breasts of Jane Doe it I0, who was then a seventeen-year-old 
girl. 
(86) On or about January 14, 2005, Defendant MEI 
placed one 
or more telephone calls to a telephone used by Jane Doe #10. 
(87) On or about JAary 27, 2005, Defendant 
I. 
a/k/a 
"placed one or more telephone calls to a telephone used by Jane 
Doe #10. 
(88) On or about January 28, 2005, Defendant MEM 
placed one 
or more telephone calls to a telephone used-by Jane Doe #10. 
(89) 
On or about February 1, 2005, Defendant 
placed one or more telephone calls to a telephone used by Jane Doe #10. 
(90) In or around February 2005, Defendant JEFFREY EPSTEIN caused a 
payment of $200 to be made to Jane Doe IN for recruiting Jane Doe #16 to travel to 
358 El Grillo Way. 
19 
EFTA00225234

Jane Doe #11 
(91) 
In or around 2004, Defendant JEFFREY EPSTEIN told Jane Doe #11 
that he would pay her to find and bring him more girls. 
(92) 
In or around 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane 
Doe # 11 for recruiting a minor female to travel to his New York home. 
(93) 
In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #11 
when she wou 
e getting more girls. 
(94) For about April 5, 2005, one of Defendant JEFFREY EPSTEIN's 
employees prepared a written message for Defendant JEFFREY EPSTEIN's review 
regarding a telephone call received from Jane Doe #11 that read: "Re does she have 
any new friends you can meet — I was away over the weekend so I have not spoken 
to anyone new. But, [unidentified Jane Doe] will be around later today and I know 
)2‘ 
she really wants to work. The others should be back around Thursday. Let me know 
about [unidentified Jane Doe]." 
(95) 
On or about June 22, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #11. 
Jane Does #12 and #13 
(96) 
On or about August 2, 2004, an employee of Defendant JEFFREY 
EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's 
review regarding a telephone call received from R. and Jane Doe #12 that stated: 
"They are available all weekend and maybe [Jane Doe #I ] too". 
20 
EFTA00225235

(97) On or about August 21, 2004, Defendant 
KELLEN placed a 
telephone call to a telephone used by Jane Doe #13. 
;; (98) 
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. 
(99) 
In or around the last half of 2004, Defendant JEFFREY EPSTEIN 
digitally penetrated Jane Doe #12, who was then a seventeen-year-old girl. 
(100) In,or around the last half of 2004, Defendant JEFFREY EPSTEIN 
attempted to plied a massaging device on the vagina of Jane Doe #12, who was then 
a seventeen-year-old girl. 
(101) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made 
a payment of $200 to Jane Doe #12. 
(102) In or around th e~tzgt hal f of 2004, DefendantJEFFREYEPSTEIN asked 
Jane Doe #12, who was then a seventeen-year-old girl, about her age. 
(103) 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. 
(104) In or around the last half of 2Q041, Defendants JEFFREY EPSTEIN and 
caused Jane Doe #12 to
 Jane Doe #13 to travel to 358 El 
Brillo Way. 
(105) 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. 
1•
A. 
21 
EFTA00225236

(106) 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-
(107) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made 
a payment of $200 to Jane Doe #13. 
(108) In or around the last half of 2004, Defendant JEFFREY EPSTEIN 
digitally penetrated Jane Doe #13, who was then a seventeen-year-old girl. 
(109)'el-around the last half of 2004, Defendant JEFFREY EPSTEIN asked 
Jane Doe #13, who was then a seventeen-year-old girl, about her age. 
(110) 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 yearsNld. 
(111) 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 04 
eig• 
(112) In or around the last half or2004, Defendant 
led 
Jane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY 
EPSTEIN's bedroom at 358 El Brillo Way. 
(113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked 
Jane Doe #14 to provide her telephone number. 
22 
EFTA00225237

(114) 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. 
(115) 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. 
(116) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made 
a payment of $300 to Jane Doe #I4. 
(117) In ..pr 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. 
(118) 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,* eighteenth birthday and acknowledged that she had 
not yet turned eighteen. 
(119) On or about December 23, 2004, Defendant JEFFREY EPSTEIN 
caused a Western Union wire transfer order to be sent to Jane Doe #I4. 
(120) In or around the first quarter 42005, Defendant JEFFREY EPSTEIN 
placed a massaging device on the vagina of Jane Doe #14, who was then a seventeen-
year-old girl. 
(121) 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. 
23 
EFTA00225238

(122) 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. 
1 -"4. (123) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN 
made a payment of $600 to Jane Doe #14. 
(124) On or about January 8, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #14. 
(125) On or about January 9, 2005, Defendant ADRIANA 
a/k/a 
*IT 
MII Muctiaka," placed a telephone call to a telephone used by Jane Doe #I4. 
(126) On or about January 26, 2005, one of Defendant JEFFREY EPSTEIN's 
employees prepared a written telephone message for Defendant 
review regarding a call received from Jane Doe #14 that read: "She is confirming for 
5:30". 
'J. 
(127) On or about January 26, 2005, Defendant 
a/k/a 
" placed a telephone call to a telephone used by Jane Doe #14. 
(128) On or about February 1, 2005, Defendant 
telephone call to a telephone used by Jane. 
e #14. 
(129) On or about March 1, 200 , 
r
Defendant 
'Ma 
placed a 
a/k/a 
" placed a telephone call to a telephone used by Jane Doe 414. 
(130) On or about March 21, 2005, Defendant 
placed a telephone calls to a telephone used by Jane Doe #14. 
tf 
A, 
24 
EFTA00225239

(131) On or about March 29, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe 414. 
Jane Doe #15 
(132) On or about December 6, 2004, Defendant 
KEI,LEN placed 
a telephone call to a telephone used by Jane Doe #15. 
(133) On or about December 14, 2004, Defendant 
KELLEN placed 
a telephone call to a telephone used by Jane Doe #I5. 
(134) 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. 
(135) 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. 
(136) In or around the first half of 2005, Defendant JEFFREY EPSTEIN 
fondled the breasts of Jane Doe #15. 
(137) In or around the first half of 2005, Defendant JEFFREY EPSTEIN 
' 
made a payment of $200 to Jane Doe #15.-v 
(138) On or about January 7, 2005, Defendant 
anda 
'S.," 
placed a telephone call to a telephone used by Jane Doe 
#15. 
25 
EFTA00225240

(139) On or about February 4, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #15. 
(140) On or about February 10, 2005, Defendant 
placed 
a telephone call to a telephone used by Jane Doe #15. 
(141) On or about February 21, 2005, Defendant 
placed 
a telephone call to a telephone used by Jane Doe #15. 
(142) On or about February 24, 2005, Defendant 
a telephone calf tea telephone used by Jane Doe #15. 
(143) On or about March 17, 2005, Defendant 
telephone call to a telephone used by Jane Doe #15. 
(144) On or about March 30, 2005, Defendant 
telephone call to a telephone/
 by Jane Doe #15. 
(145) On or about March 31, 2005, Defendant 
telephone call to a telephone used by Jane Doe #15. 
(146) On or about March 31, 2005, Defendant 
placed 
placed 
placed a 
placed a 
placed a 
a/k/a 
placed a telephone call to a telephone used by Jane Doe #15. 
(147) On or about April 1, 2005, one of Defendant JEFFREY EPSTEIN's 
employees prepared a note for Defendant JEFFREY EPSTEIN's review that read: 
"10:30 [Jane Doe #15]/[Jane Doe #10] on Fri around 2'Oclock". 
(148) In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane 
Doe #15 with a gift of 
Secret lingerie for her eighteenth birthday. 
is 
26 
EFTA00225241