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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

EFTA00247231

59 pages
Pages 1–20 / 59
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payment of co-conspirators and victims; and (4) store exploitative photographs for future sexual 
gratification. 
37. 
Computer files or remnants of such files can be recovered months or even years 
after they have been created or saved on an electronic device such as the Subject Devices. Even 
when such files have been deleted, they can often be recovered, depending on how the hard drive 
has subsequently been used, months or years later with forensics tools. Thus, the ability to retrieve 
from information from the Subject Devices depends less on when the information was first created 
or saved than on a particular user's device configuration, storage capacity, and computer habits. 
38. 
Based on the foregoing, I respectfully submit there is probable cause to believe that 
evidence of the Target Subjects' commission of the Subject Offenses is likely to be found on the 
Subject Devices. 
Procedures for Searching ESI 
A. Review of ESI 
39. 
Law enforcement personnel (who may include, in addition to law enforcement 
officers and agents, attorneys for the government, attorney support staff, agency personnel 
assisting the government in this investigation, and outside technical experts under government 
control) will review the ESI contained on the Subject Device for information responsive to the 
warrant. 
40. 
In conducting this review, law enforcement may use various techniques to 
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such 
techniques may include, for example: 
• 
surveying directories or folders and the individual files they contain (analogous to 
looking at the outside of a file cabinet for the markings it contains and opening a drawer 
believed to contain pertinent files); 
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• 
conducting a file-by-file review by "opening" or reading the first few "pages" of such 
files in order to determine their precise contents (analogous to performing a cursory 
examination of each document in a file cabinet to determine its relevance); 
• "scanning" storage areas to discover and possibly recover recently deleted data; 
scanning storage areas for deliberately hidden files; and 
• 
performing electronic keyword searches through all electronic storage areas to 
determine the existence and location of search terms related to the subject matter of the 
investigation. (Keyword searches alone are typically inadequate to detect all 
information subject to seizure. For one thing, keyword searches work only for text data, 
yet many types of files, such as images and videos, do not store data as searchable text. 
Moreover, even as to text data, there may be information properly subject to seizure 
but that is not captured by a keyword search because the information does not contain 
the keywords being searched.) 
41. 
Law enforcement personnel will make reasonable efforts to restrict their search to 
data falling within the categories of evidence specified in the warrant. Depending on the 
circumstances, however, law enforcement may need to conduct a complete review of all the BSI 
from the Subject Device to locate all data responsive to the warrant. 
B. Return of the Subject Device 
42. 
If the Government determines that the Subject Device is no longer necessary to 
retrieve and preserve the data on the device, and that the Subject Device is not subject to seizure 
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return the Subject 
Device, upon request. Computer data that is encrypted or unreadable will not be returned unless 
law enforcement personnel have determined that the data is not (i) an instrumentality of the 
offense, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, 
or (v) evidence of the Subject Offenses. 
IV. Conclusion and Ancillary Provisions 
43. 
Based on the foregoing, I respectfully request the court to issue a warrant to seize 
the items and information specified in Attachment A to this affidavit and to the Search and Seizure 
Warrant. 
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44. 
In light of the confidential nature of the continuing investigation, I respectfully 
request that this affidavit and all papers submitted herewith be maintained under seal until the 
Court orders otherwise. 
Sworn to before me on 
Septe ern, 2019 
S L. COTT 
STATES MAGISTRATE JUDGE 
Federal Bureau of Investigation 
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Attachment A 
I. Devices Subject to Search and Seizure 
The devices that are the subject of this search and seizure warrant (the "Subject Devices") 
are described as follows: 
The Subject Devices were all recovered from a search of a private island in the U.S. Virgin 
Islands, known as Little Saint James, which is an approximately 75 acre island located 
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands 
Residence") on or about August 12, 2019. The Virgin Islands Residence consists of multiple 
structures, including a main residence as well as several other smaller structures on the island, 
including a pool house, sheds, a beach house, an office, and multiple cabanas. The Subject Devices • 
are particularly described as follows: 
a. A gray Mac desktop computer labeled "kitchen mac," which was recovered from a 
desk in the main residence on the island ("Subject Device-1"); 
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89111772QT, 
which was recovered from a desk in the main residence on the island ("Subject 
Device-2"); 
c. A silver MacBook Pro bearing serial number c02qmOgugwdp, which was 
recovered from a desk in the main residence on the island ("Subject Device-3"); 
d. A silver Wad model A1567 bearing serial number dmpq125ng5ypy, which was 
recovered from a desk in the main residence ("Subject Device-4"); 
e. A silver Wad model A1567 bearing serial number dmpqL1rmg5y, which was 
recovered from a desk in the main residence ("Subject Device-5"); 
f. A silver Mac desktop computer bearing serial number cO2nmlmOfy14, which was 
recovered from a desk in the pool house on the island ("Subject Device-C); 
g. A silver Mac desktop computer, which was recovered from a desk in a cabana on 
the island ("Subject Device-7"); 
h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a 
shed on the island ("Subject Device-8"); 
i. An HP laptop bearing serial number cnd81368v5, which was recovered from a desk 
in a shed on the island ("Subject Device-9"); 
J. A silver Mac desktop computer, which was recovered from a desk in a cabana on 
the island ("Subject Device-10"); 
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k. A silver Macbook desktop computer, which was recovered from a desk in a cabana 
on the island ("Subject Device-I I"); 
1. A Dell Inspiron Tower computer model DI9M QCNFA335, which was recovered 
from a desk in the beach house on the island ("Subject Device-12"); 
m. A silver Mac desktop computer model A1311 bearing serial number 
W804736DDAS, which was recovered from a desk in the beach house on the island 
("Subject Device-13"); 
n. A Unfi video bearing mac ID 18291 b4fbe426ea90, which was recovered from a 
server rack inside a shed on the island ("Subject Device-14"); 
o. A Unifi Server bearing mac ID 1735K 788A20463234-8uuu9f, which was 
recovered from a server rack inside a shed in on the island ("Subject Device-15"); 
p. An HP server with four 500 GB drives, bearing serial number MDCQ3220187, which 
was recovered from a shed on the island ("Subject Device-16"); 
q. A Panasonic KX TDE100 computer bearing serial number 1OC-TDa0104 
9LCCD005398, which was found on a server rack in a shed on the island ("Subject 
Device-17"); 
r. A 6 bay with 146 GB drives bearing serial number MJCQ824A1R, which was found 
on a server rack in a shed on the island ("Subject Device-18"); 
s. A silver Mac desktop computer, which was recovered from a desk in a cabana on 
the island ("Subject Device-19"); 
t. An HP desktop tower model 260-A010, bearing serial number cnv7160050, which 
was recovered from the maintenance office on the island ("Subject Device-20"); 
u. An HP tower model 260-A010, bearing serial number cnv716004y, which was 
recovered from the maintenance office on the island ("Subject Device-21"); 
v. A Mac desktop computer model A1312, bearing serial number w89524czspj, which 
was recovered from the maintenance office on the island ("Subject Device-22"); 
w. A Lenovo tower machine type 90J0, bearing serial number mj07yg6u, which was 
recovered the maintenance office on the island ("Subject Device-23"); 
x. A Lenovo tower bearing serial number 153306g2umjxekgx, which was recovered 
the maintenance office on the island ("Subject Device-24"); 
y. An HP Tower bearing serial number CNV74213M3 570-P056, which was 
recovered the maintenance office on the island ("Subject Device-25"); 
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z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID
1843kb4fbe4d30c69-dcrgni9, which was found on a server rack in a shed on the 
island ("Subject Device-26"); and 
aa. A red Nikon digital camera, which was recovered on a file cabinet next to a desk in 
a cabana on the island ("Subject Device-27"). 
II. Review of ESI on the Subject Devices 
Law enforcement personnel (who may include, in addition to law enforcement officers and 
agents, attorneys for the government, attorney support staff, agency personnel assisting the 
government in this investigation, and outside technical experts under government control) are 
authorized to review the ESI contained on the Subject Device for 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: 
1. 
Evidence concerning the identity or location of the owner(s) or user(s) of the 
Subject Devices 
2. 
Evidence concerning the identi 
or location of, and communications with, co?
conspirators of Jeffrey Epstein, including 
3. 
Any documents or communications with or regarding victims or potential victims 
of the Subject Offenses; 
4. 
Documents or records reflecting payments to victims and/or co-conspirators 
including but not limited to bank and financial records, spreadsheets, ledgers, account listings, 
check and wire records, and documents reflecting cash withdrawals. 
5. 
Any photographs of victims or potential victims of the Subject Offenses. 
6. 
Any nude, partially nude, or sexually suggestive photographs of individuals who 
appear to be teenage girls, or younger. 
7. 
Records or other items that evidence ownership, control, or use of, or access to 
devices, storage media, and related electronic equipment used to access, transmit, or store 
information relating to the Subject Offenses, including, but not limited to, sales receipts, 
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved 
usemames and passwords, user profiles, e-mail contacts, and photographs. 
8. 
Any child erotica, defined as suggestive visual depictions of nude minors that do 
not constitute child pornography as defined by 18 U.S.C. § 2256(8). 
If the Government determines that any of the Subject Devices is no longer necessary to retrieve 
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure 
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject 
Device, upon request. 
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EXHIBIT A 
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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. 
CRIM 490 ' 
coONT ONE 
(Sex Trafficking Conspiraby) 
The Grand Jury °barges: 
OVERVIEW 
1.  As set forth herein, over the course of many 
years, JEFFREY EPSTEIN, the defendant, sexually exploited and .
abused dozens of minor girls at his homes in'Manhattan, New .
York, and Palm Beach, Florida, among other locations. 
2. 
In particular, from at least in or about 2002, up 
to and including at least in or about 2005, JEFFREY EPSTEIN, the 
defendant, enticed and' recruited, and caused to be enticed and 
recruited, minor girls to visit his mansion in Manhattan, New 
York (the "New York Residence") and his estate in Palm Beach, 
Florida (the "Palm Beach 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, EpSTEIE also paid certain of hip victims to 
recruit additional girls to be similarly' 
abused by EPSTEIN. In 
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this way, EPSTEIN created a vast network of underage victims for 
him to sexually exploit in locations including New York and 
Palm Beach. 
3. 
The victims described herein were as young as 14 
years old at the time they were abused by JEFFREY EPSTEIN, the 
defendant, and were, for various reasons, often particularly 
vulnerable to exploitation. EPSTEIN intentionally sought out 
minors and knew that many of his victims were in fact under the 
'age of 18, including because, in some instances, minor victims 
expressly told him their age. 
•
 
4. 
In creating and maintaining this network of minor 
victims in multiple states to sexually abuse and exploit, 
JEFFREY EPSTEIN, the defendant, worked and conspired with 
others, including employees and associates who facilitated his 
• 
conduct by, among other things, contacting victims and 
scheduling their sexual encounters with EPSTEIN at the New York 
Residence and at the Palm Beach Residence. 
FACTUAL BACKGROUND 
5. 
During all time periods charged in this 
Indictment, JEFFREY EPSTEIN, the defendant,'was a financier with 
multiple residences in the continental United States, including 
the New York Residence and the Palm Beach Residence. 
6. 
Beginning in at least 2002, JEFFREY EPSTEIN, the 
defendant, enticed and recruited, and .caused to be enticed and . • 
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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 Pala Beach Residence. 
7: 
In both New York and Florida, JEFFREY EPSTEIN, 
the defendant, perpetuated this abuse in similar wayq. victims 
were initially recruited to provide "massages' to EPSTEIN, which 
would be perforted nude or partially nude, would become 
increasingly sexual in nature, and would typically include one 
or more sex acts. EPSTEIN paid his victims hundreds of .dollars 
in cash for each encounter. Moreover, EPSTEIN actively 
encouraged certain of his victims to recruit additional girls to 
be similarly sexually abused., EPSTEIN incentivized his victims 
to become recruiters by paying these victim-recruiters hundreds 
of dollars for each girl that they brought to EPSTEIN. In so 
doing, EPSTEIN maintained a steady supply of new victims to 
exploit. 
The New York Residence 
8. 
At all times relevant to this Indictment, JEFFREY 
EPSTEIN, the defendant, possessed and Controlled a multi-story 
private resideade on the Upper East Side of Manhattan, New York, 
i.e., the NeW York Residence. Between at least in or about 2002 
and in or about 2005, EPSTEIN abused numerous minor victims at 
the New York Residence by causing these victims to be recruited 
to engage in paid sex acts with him. 
EFTA00247240
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9. 
When 
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, 
riaid 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 
EFTA00247241
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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 additionil 
girls by offering to pay these victim-recruiters for every 
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York 
Residence, both the victim-recruiter and the new minor victim 
were paid hundreds of dollars by EPSTEIN for each encounter. In 
addition, certain victim-recruiters routinely scheduled these 
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encounters through Employee-3., who sometimes asked the 
recruiters tp bring a specific minor girl for EPSTEIN. 
The Palm Beath Residence 
14. In addition to recruiting and abusing minor girls 
in New York, JEFFREY EPSTEIN, the defendant, created a similar 
network of minor girls to victimize in Palm Beach, Florida, 
where EPSTEIN owned, possessed and controlled another large 
residence, i.e., the Palm Beach Residence. EPSTEIN frequently 
traveled from New York to Palm Beach by private jet, before 
which an employee or associate would ensure that minor victims 
were available for encounters upon his arrival in Florida. 
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the 
defendant, engaged in a similar course of abusive conduct. 
When a victim initially arrived at the Palm Beach Residence, she 
would be escorted to a room, sometimes by an employee of 
EPSTEIN's, including, At times, two assistants ("Employee-2" and 
"Employee-3") who, as described herein, Were also responSible 
for scheduling sexual encounters with minor victims 
Once 
inside, the victim would provide é nude ar.semi-nude massage for 
EPSTEIN, who would himself typically be naked. During those 
encounter's, EPSTEIN would escalate the nature and. scope of the 
physical contact to include. sex acts such As groping and direct 
and indirect contact with the Victimre genitals. EPSTEIN would 
also typically masturbate during these encounters, Ask victims 
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to touch him while he masturbated, and touch Victims' genitals 
with his hands of with sex toys. 
• 
16. In connection with each sexual encounter, JEFFREY 
EPSTEIN, the defendant, or one of his employees or associates, 
paid the victim-in cash. Victims typically were paid hundreds 
of dollars for each encounter. 
17. JEFFREY EPSTEIN, the defendant, knew that certain 
of his victims were underage, including because certain victims 
told him their age. In additiOn, as with New York-based 
victims, many Florida victims, once recruited, were abused by 
JEFFREY EPSTEIN, the defendant, on multiple additional 
occasions. 
18. JEFFREY EPSTEIN, the defendant, who during the
relevant time period was frequently in New York, would arrange 
for Employee-2 or other employees to contact victims by phone in 
advance-of EPETEXO's. travel to Florida to ensure appCintments 
were scheduled for when he. arrived. In particular, in certain 
instances, Employee-2 placed phone calls to minor victims in 
Florida to schedule encounters at the' Palm Beach Residence. At 
the time of certain :of those phone calls, EPSTEIN and Employee-2 
were in New York, New YOrk. Additionally, certain of the 
individuals victimized at the Palm Beach Residence were 
contacted by.phone by Employee-3 to schedule these encounters. 
EFTA00247244
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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 
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commercial sex act, in violation of Title 18, United States 
Code, Sections 1591(a) and (b)(2). 
Overt Acts 
22. In furtherance of the conspiracy and to effect 
the illegal object thereof, the following overt acts, among 
others, were committed in the Southern District of New York and 
elsewhere: 
a. 
In or about 2004, JEFFREY EPSTEIN, the 
defendant, enticed and recruited multiple minor victims, 
including minor victims identified herein as Minor Victim-1, 
Minor Victim-2, and Minor Victim-3, to engage in sex acts with 
EPSTEIN at his residences in Manhattan, New-York, and Palm.
Beach, Florida, after which he provided them with hundreds of 
dollars in cash for each encounter. 
b. 
In or about 2002, Minor Victim-1 was 
recruited to engage in sex acts with EPSTEIN and was repeatedly 
sexually abused by EPSTEIN at the New York Residence over a 
period of years and was paid hundreds of dollars for each 
encounter. EPSTEIN also encouraged and enticed Minor Victim-1 
to recruit other girls to engage tim 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 
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9 
a telephone call to Minot Victim-1.in Order to schedule an 
appointment for Minor Victim-1 to engage in paid sex acts with 
EPSTEIN. 
d. 
In or about 2004, Minor Victim-2 was 
recruited to engage in sexSots with EPSTEIN and was repeatedly 
sexually abused by EPSTEIN .at the Palm Beach Residence over a 
period of years and was paid hundreds of dollars after each 
encounter. EPSTEIN also encouraged and enticed Minor Victim-2' 
to recruit other girls to engage in paid sex acts, which she 
did. 
e. 
In or about 2005, Employee-2, located in the 
Southern. District of New York, and on behalf of EPSTEIN, placed 
a telephone call to Minor Viotim-2 in order to schedule an 
appointment for Minor Victim-2 to engage in paid sex acts with 
EPSTEIN. 
f. 
In or about 2005, Mirior Victim-3 was
recruited to engage in sex acts with EPSTEIN and was repeatedly 
sexually abused by EPSTEIN at the Palm Beach Residence over a 
period of years and was paid hundreds of dollars for each 
encounter. EPSTEIN also encouraged and enticed Minor Victim-3 
to recruit other girls to engage in paid sex acts, which she 
did. EPSTEIN asked Minot Victim-3 how old she was, and Minor 
Victim-3'answered truthfully. 
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r1/2  
• 
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'l 
through 19 and 22 of this Indictment are repeated and realleged 
as if fully 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 
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individuals•whd 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 Two 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. 
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•.
Substitute Asset Provision 
26. If any of the above-described forfeitable 
property, as a result of any act or omission of. the defendant: 
(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 
(e) has been commingled with other property which cannot 
be subdivided without difficulty; 
it is the intent of the United States, pursuant to 21 U.S.C. 
853(p) and 28 U.S.C. S 2461(c), to seek forfeitgre 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.) 
4, lu 
GEOFFR_TY S. BERMAN 
United states Attorney 
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