EFTA01249981

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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 
addition, certain victim-recruiters routinely scheduled these 
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EFTA 00095967 
EFTA01250041

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 7 of 15 
encounters through Employee-1, who sometimes asked the 
recruiters to bring a specific minor girl for EPSTEIN. 
The Palm Beach 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 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 sex acts such as groping and direct 
and indirect contact with the victim's genitals. EPSTEIN would 
also typically masturbate during these encounters, ask victims 
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EFTA_00095968 
EFTA01250042

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 8 of 15 
to touch him while he masturbated, and touch victims' genitals 
with his hands or 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 EPSTEIN's travel to Florida to ensure appointments 
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. 
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EFTA_00095969 
EFTA01250043

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 9 of 15 
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 (D). 
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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EFTA01250044

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 10 of 15 
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 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 
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EFTA 00095971 
EFTA01250045

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 11 of 15 
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, Minor Victim-2 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 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 sex acts with 
EPSTEIN. 
f. 
In or about 2005, Minor 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 Minor Victim-3 how old she was, and Minor 
Victim-3 answered truthfully. 
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EFTA_00095972 
EFTA01250046

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 12 of 15 
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 1 
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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EFTA01250047

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 13 of 15 
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 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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EFTA01250048

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 14 of 15 
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. § 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.) 
13 
GE2E4 11(1. 
BERMAN 
United States Attorney 
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EFTA01250049

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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
(18 U.S.C. SS 371, 1591(a), (b)(2), 
and 2) 
GEOFFREY S. BERMAN 
United States Attorney 
WWL01-00....4an 
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