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FBI VOL00009
EFTA00247131
100 pages
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EXHIBIT A 2017.08.02 EFTA00247171
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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED• STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x SEALED INDICTMENT 19 Cr. 19 CRIM COUNT ONE (Sex Trafficking Conspiracy) 490 ' 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 Residente") and his estate in Palm Beach, Florida (the "Palm Beach ResIdende") 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 EFTA00247172
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. r 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 EFTA00247173
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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, JEFFRBY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide 'massages' to EPSTEIN, which would be perforded 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. EPSTEXN:incentivized hie victims to become recruiters by paying these victim7tecruiters 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 pritate residence an the Upper East Side of Manhattan, New York, i.e., the New-York Residence. Between at least in or about 20Q2 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 EFTA00247174
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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 ■ EPSTEIN typically would also • • 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. Fuither, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed EFTA00247175
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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
additionr certain victim-recruiters routinely scheduled these
5
EFTA00247176
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• or
encounters through Employee-1, who sometimes asked the
recruiters to bring a specific minor girl for EPSTEIN.
The Palm Beach Residepde
14. In addition to reoruiting and. abusing minor girls
in Pew 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 Balt 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 bp-escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants ("Employee-2" and'
"Employee-S/ who, as described herein, Jere
.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. IF
also typically la
.
EPSTEIN would
6
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• 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 appeintments were scheduled for when he. arrived. I.n particular, in certain in's'tances, 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 EFTA00247178
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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 EFTA00247179
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3 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-I, 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 EFTA00247180
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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, Minbr Victim-2 was recruited to engage in sex acts with OSTEIN 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 sea acts with EPSTEIN. f. In or about 20.05, Minor Victim-3 was recruited to engage in set 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 61d she was, and Minor Victim-3 answered truthfully. 10 EFTA00247181
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g'. 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-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN. h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to'schedule an appointment for Minor Victim-3 to engage in paid sex acts with . EPSTEIN. (Title 18, United States Code, Section 371.) COUNT TWO (Sex Trafficking) The Grand Jury further charges: 23. The allegations contained in paragraphs.]: through 19 and 22 of this Indictment are repeated and realleged as if fdlly set forth within. 24. From at least in or about 2002, up to. and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the•age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous 11 EFTA00247182
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individuals who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in 'Manhattan, New York. . (Title 18, United States Code, Sections 1591(a), (b)(2), and 2.) • FORFEITURE ALLEGATIONS 25. As a result of committing the offense alleged in Count Tice of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property: a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments. and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc. 12 EFTA00247183
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Substitute Asset Provision 26. If any of the above-described forfeitable property, as a result of any act or ()passion of the defendant: • (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, 4 third person; (c) has been placed beyond the jurisdiction of the Court; (d)• has been substantially diminished in value; or (e) has been commingled with other property which cannot be subdivided with6ut difficulty; it is the intent of the United States, pursuant to 21 U.S.C. S 853(p) and 28 S 2461(c), to seek forfeiture of any other property of the defendant Up to the value. Of the above forfeitable property. (Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28, United States Code, Section 2461..) GEOFF clIT BERMAN. United States Attorney 4 PertL—_, 13 EFTA00247184
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Form No. USA-33s-274 (Ed. 9-25-58) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v. JEFFREY EPSTEIN, Defendant. 'INDICTMENT 418 U.S.C. §§ 371, 1591(a), (b)(2), and 2) GEOFFREY S. BERMAN United States Attorney Forepe -on 14 EFTA00247185
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EXHIBIT B 2017.08.02 EFTA00247186
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AO 93 (SDNY Rev. 01/17)Search and Seizure Wammt 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 identify the person byname and address) See Attachment A Case No. SEARCH AND SEIZURE WARRANT To: Any authorized law enforcement officer An application by a federal law enforcement officer or en attorney for the government requests the search of the following person or property located in the Southern District of New York (Identify the perm: or describe the property to be searched and glee its location): see Attachment A The person or property to be searched, described above, is believed to conceal (idea* the person or describe the property to be settecO: . See Attachment A The search and seizure are related to violation(s) of Oaten statutory citations): Title 18, United States Code, Sections 371 and 1591 I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the perion or property. YOU ARE COM:WIANDED to execute this warrant on or before 1- • rte ) (not to exceed 14 days) 21 in the daytime 6:00 a.m. to 10 p.m. Oat any time in the day or night as I find reasonable cause has been established. Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the property was taken. The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court. O Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate box) Ofor days (not to exceed 30). Ountil, the facts justifying, r specific date of Date and time issued: 1- lAtk ek • V\ • Judge's signature City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge Printed name =Mk EFTA00247187
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AO 93 (SONY Rev. 01!17) Search and Seth= Warrant ahle Return Case No.: Date and time warrant executed: Copy of warrant and inventory left with: Inventory made in the presence of : Inventory of the property taken and name of any person(s) seized: Certification I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the Court Date: Executing officer's signature Printed name and title EFTA00247188
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ATTACHMENT A I. Premises to be Searched—Subject Premises 1. The premises to be searched (the "Subject Premises") are described as a nearly 19,000 square foot multi-story single-family residence located at 9 East 71st Street, New York, New York, and include all locked and closed containers found therein. A photograph of the front entrance to the Subject Premises is included below: II. Items to Be Seized 1. This warrant authorizes executing agents to photograph, video record and otherwise document the full interior of the Subject Premises, including any items, furnishings, or possessions therein. 2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: a. Evidence concerning occupancy or ownership of the Subject Premises, including utility and telephone bills, mail envelopes, addressed correspondence, diaries, statements, identification documents, address books, telephone directories, and photographs of its occupant(s). b. Evidence concerning the layout, furnishings, decorations, and floor pattern of the Subject Premises, including photographs and blueprints of the Subject Premises. 2017.08.02 EFTA00247189
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EXHIBIT C 2017.08.02 EFTA00247190