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
EFTA00225672
248 pages
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(30) On or about January 14, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #3. D (31) 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." On or about January 29, 2005, one of Defendant JEFFREY EPSTEIN's Jane Does #4, #5, and #6 (32) Raround 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 of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. (34) In or around thirst 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. (35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a e nteen-year-old girl, to play with his nipples. F (36) 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. 12 EFTA00225772
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(22) On or about October 30, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. D (23) 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. (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 seven-year-old girl. (25) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. (26) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #3 to rub his nipples. (27) In or around 2ADefendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. (28) In or around 2004, 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 mge for Defendant JEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 that read: "I have a female for him? 11 EFTA00225773
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(13) In or around 2003, Defendant told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked to take nude photographs of Jane (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) Raround 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 A 2, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. Jane Doe #3 (19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #3, who was then a fifteen-year-old girl. (20) In or around 2003, DefendFJEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. (21) On or about October 26, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. 10 EFTA00225774
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(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 D I 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 thRourteen-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, 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 A Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who would be interested in engaging in similar activities with him. (II) In or around 2003, Defendant took nude photographs r of Jane Doe #2, who was then a sixteen-year girl. (12) In or around 2003, Defendant RAH made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. 9 EFTA00225775
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(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 satistyndant JEFFREY EPSTEIN's prurient interests. Overt Acts 30. 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: R 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 WayAtairs 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 fourteen years' old, to pitch his nipples while he masturbated. (5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. 8 EFTA00225776
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29. 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 " , 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 and the New York residence to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. (b) I as further a part of the conspiracy that Defendants JEFFREY EPSTEIN, and • 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, AD 1A 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, and other F participants would make payments to, or cause p ents to be made to, the recruiters for bringing additional minor females to 358 El Brillo Way and the New York residence to engage in lewd conduct with Defendant JEFFREY EPSTEIN. 7 EFTA00225777
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COUNT 1 (Conspiracy: 18 U.S.C. § 371) Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by refe as though fully set forth herein. 27. 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, R DRIANA ROSS, aAc/a " 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 ingrate 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(h). Purpose and Object of the Conspiracy 28. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way and the New Fic residence 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 6 EFTA00225778
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23. During the period of her involvement with the Defendants, Jane Doe #10 attended Lake Worth High School in Palm Beach County. D During the period of her involvement with the Defendants, Jane Doe #11 attended the Professional Performing Arts School, a public high school, located in New York, New York. 25. During the period of her involvement with the Defendants, Jane Doe #13 attended John I. Leonard High School in Palm Beach County. R A F 5 EFTA00225779
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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. I) Pursuant to Florida Statutes Section 800.04(2), InJeither the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]." 15. 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]." R 16. Pursuant Florida Statutes Section 800.02, a "person who commits any unnatural and lascivious act with another person commits a misdemeanor of the second degree." 17. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical license. 18. During the period of her involvement with the Defendants, Jane Doe #4 attended Wellington High School and Palm Bekentral High School in Palm Beach County. 19. During the period of her involvement with the Defendants, Jane Doe #5 attended Wellington High School in Palm Beach County. 20. 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. 21. During the period of her involveFt with the Defendants, Jane Doe #7 attended William T. Dwyer High School in Palm Beach County. 22. 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. 4 EFTA00225780
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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 activityla 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." 11. Pursuant to Florida Statutes Sections 800.04(5Xa) and 800.04(5Xc)(2), an adult "who intentio 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 bAs than 16 years of age. 12. 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. 13. Pursuant to Florida Statutes SectioF00.04(7)(a) and 800.04(7)(c), an adult "who: (I) [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 3 EFTA00225781
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2. Defendant JEFFREY EPSTEIN employed L.G. to perform, among other things, services as a personal assistant. 1) Defendants JEFFREY EPSTEIN and paid T.M., H.R., and A.F. to perform, among other things, recruiting services. 4. 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"). 5. DefendaRFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. 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. 7. Defendant JEFFREY STEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 8. 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. F 9. Defendant JEFFREY EPSTEIN se as president, sole director, and sole shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 10. 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 2 EFTA00225782
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA D 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(b) 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 2423(b) UNITED STATES RAMERICA vs. JEFFREY EPSTEIN, and • Defendants. A INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defendant JEFFREY EPSTEIN employed defendants " and to perform, among other things, services as personal assistants. T EXHIBIT B-30 EFTA00225783
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A. Villafaria, Esq. December 9, 2009 Page 3 our part would constitute a breach of the NPA. So the Rothstein lawyers, once again, are using the power of the federal government to perpetrate and further their fraud. And the expense of litigating these cases has been extreme. For example, Bob Josefsberg, who I do not believe was aware of the Rothstein crimes, is now demanding over $2 million in legal fees. As a lawsuit brought by some of the investors' claims, Rothstein and his partner Edwards used Jeffrey Epstein as bait. The litigation strategy, media pronouncements, and investigatory initiatives of Rothstein and Edwards were calculated to support Rothstein's deceptions rather than to advance the position of his clients. I bring these facts to your attention so that if you had contact with Edwards or those associated with him in the past concerning Mr. Epstein, you consider not continuing communications with any of them in the future. I would like a short conference with you in person to talk about Mr. Epstein's progress through the state criminal justice system, to discuss several outstanding issues that I want to make sure you have accurate information about, and, from my perspective, most importantly, so that I can provide Mr. Epstein with proper counsel going forward. If you email me some dates when you are available this month, we can schedule a short meeting in your office hopefully before the year ends. Roy Black RB/wg Enclosure Black, Srebnick. Komspan & Stumpf, P.A. EFTA00225784
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ROY BLACK HOWARD M. SREBNICK Scan' A. KORNSPAN LARRY A. STUMPF. MARIA NEYRA JACKIE PERCZEK MARK A.J. SHAPIRO JARED LOPEZ BLACK SREBNICK KORNSPAN & STUMPF =PA.= December 9, 2009 A. Villafafia, Esq. Assistant United States Attorney United States Attorney's Office Southern District of Florida 500 South Australian Avenue Suite 400 West Palm Beach, Florida 33401 RE: Jeffrey Epstein Dear JESSICA FONSECA-NADER KATHLEEN P. PHILLIPS AARON ANTHON MARCOS BEATON, JR. MATTHEW P. O'BRIEN JENIPER J. SOULIKIAS NOAH FOX E-Mail: RBlack@RoyBlack.com You emailed me a letter on November 2, asking whether Jeffrey Epstein's place of employment remained constant. It has. I reviewed a Google map to confirm that the distance between that place of employment and the location where he was stopped by Palm Beach Police is less than 3 miles (and that the location where he was walking was on a direct route to his place of work). It has taken us a while to respond to your letter because other matters have consumed our time and effort. Over the past five weeks, the massive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the Complaint is enclosed with this letter. ou sr know, Rothstein's firm represents and Wilde, three of the plaintiffs who have rou t civil actions against Mr. Epstein. The Rothstein firm was a criminal enterprise that used the litigation against Mr. Epstein to lure investors into its billion-dollar ponzi scheme. We believe that Rothstein and his co-conspirators used the government's criminal investigation as a means to perpetrate and further their fraud. For example: 201 S. Biscayne Boulevard, Suite 1300 • Miami. Florida 33131 • Phone: Fax: a • www.RoyBlack.com EFTA00225785
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West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the Sfokt and South lines respectively of Lot 40, containing 0.07 acres, more or Pursuant to Title 18, United States Code, Section 1594(b). A TRUE BILL. FOREPERSON R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. VILLAFARA ASSISTANT UNITED STATES ATTORNEY 54 EFTA00225786
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(e) difficulty; has been commingled with other property which cannot be divided without it is theiiiiegt of the United States, pursuant to Title 18, United States Code, Section 2253(o), to seek forfeiture of any other property of said defendant up to the value of the above forfeitable property. Pursuant to Title 18, United States Code, Section 2253. FORFEITURE 3 Upon convictidn'of any of the violations alleged in Counts 2-11 of this indictment, the defendants, JEFFREY EPSTEIN, SARAH KELLEN, , a/k/a "Adrian Mucinska," and NADIA MARCINK0VA, shall forfeit to the United States any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such violation; and any propertl,:;real or personal, constituting or derived from any proceeds that such person obtained, directly or indirectly, as a result of such violation, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded kin' the West by the 53 EFTA00225787
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offense; and any property, real or personal, used or intended to be used to commit or to promote the commission of such offense, including but not limited to the following: a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as: Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida and BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. I Pursuant to Title 18, United States Code, Section 2253. If any of the forfeitable property described in the forfeiture section of this indictment, as a result of any act or omission of the defendants JEFFREY EPSTEIN, ADRIANA ROSS, a/k/a "Adriana Mucinska," and NADIA Ea (a) cannot be located upon the exercise-of due diligence; (b) has been transferred or sold to, or deposited with, a third person; (c) has been placed beyond the jurisdiction of the Court; (d) has been substantially diminished in value; or 52 EFTA00225788
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Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21, United States Code, Section 853. If the property described above as being subject to forfeiture, as a result of any act or omission of the defendants, JEFFREY EPSTEIN, SARAH a/k/a "Adriana Mucinska," and (1) cannot be located upon the exercise of due diligence; (2) has been transferred or sold to, or deposited with a third person; (3) has bectiiilaced beyond the jurisdiction of the Court; (4) has been substantially diminished in value; or (5) has been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, putsuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendants up to the value of the above forfeitable property. All pursuant to Title 28 United States Code, Section 2461; Title 18, United States Code, Section 98I(a)(1)(C); and Title 21 United States Code, Section 853. FORFEITURE 2 Upon conviction of any of the violations alleged in Counts 12-29 of this indictment, the defendants, JEFFREY EPSTEIN, a/k/a "Adriana Mucinska," and NADIA MARCINKOVA, shall forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other proceeds obtained from such 51 EFTA00225789
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Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in 18 U.S.C. § 2423(f), with a person under 18 years of age, that is, the person(s) listed in each count below: Count Date(s) Minor(s) Involved Defendant(s) 26 7/16/2004 Jane Doe #7 Jane Doe #8 Jane Doe #9 Jane Doe #10 JEFFREY EPSTEIN NADIA MARCINKOVA 27 3/31/200;5 Jane Doe #14 Jane Doe #15 Jane Doe #16 JEFFREY EPSTEIN ADRI llasIAIM, a/k/a "Adriana Mucinska" 28 9/18/2005 Jane Doe #16 JEFFREY EPSTEIN a/k/a "Adriana Mucuiska" 29 9/29/05 Jae Doe #16 _ JEFFREY EPSTEIN SARAH ADRIAN'', a/k/a "Adriana Mucinska" All in violation of Title 18, United States Code, Sections 2423(b) and 2. FORFEITURE 1 - . Upon conviction of the violation alleged ineount 1 of this indictment, the defendants, JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a "Adriana Mucinska," and shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation. 50 EFTA00225790
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did knowingly and willfully conspire with each other and with others lmown and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with another person, in violation of Title 18, United States Cod; Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e). COUNT 25 (Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d)) 61. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though Eitily set forth herein. 62. From at least as early as in or about 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendant, SARAH KELLEN, did, for the purpose of commercial advAntage or private financial gain, arrange and facilitate the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d). COUNTS 26 THROkIJGH 29 (Travel to Engage in Illicit Sexual CA:induct: 18 U.S.C. § 2423(b)) 63. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 64. On or about the dates enumerated as to each count listed below, from a place outside the Southern District of Florida to a place inside the SoutiOrh District of Florida, the 49 EFTA00225791