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PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS
CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e)
MEMORANDUM
TO: Geoffrey S. Berman. U.S. Attorn
FROM: AUSAs
DATE: December 19, 2019
RE: Investigation into Potential Co-Conspirators of Jeffrey Epstein
This memorandum details the investigative steps taken since the indictment of Jeffrey
Epstein in this District on July 2, 2019 and analyzes the extent to which certain of Epstein's
associates and employees may or may not be criminally liable for their conduct during their
employment with Epstein.
I. Background
On July 2, 2019, a federal grand jury in the Southern District of New York returned a
sealed indictment (the "Indictment") charging Jeffrey Epstein with one count of sex trafficking
of minors, in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex
trafficking of minors, in violation of 18 U.S.C. § 371.
The prosecution memorandum in support of that indictment detailed the evidence
gathered regarding Epstein and his associates during our Office's pre-indictment investigation.
That evidence revealed that beginning in at least 2002, Epstein enticed and recruited dozens of
minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in
cash. He undertook this activity in at least two different locations, including his mansion in
Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the
"Palm Beach Residence"). In both New York and Florida. Epstein perpetuated this abuse in
similar ways. Victims were initially recruited to provide "massages" to Epstein, which would be
performed nude or partially nude, would become increasingly sexual in nature, and would
typically include one or more sex acts, including groping and direct or indirect contact with
victims' genitals. Epstein paid his victims hundreds of dollars in cash for each separate
encounter.
Moreover, Epstein actively encouraged certain of his victims to recruit additional girls to
be similarly sexually abused. He incentivized his victims to become recruiters by paying these
victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion.
Epstein created a vast network of underage victims — as young as 14 — in locations including
New York and Palm Beach. In creating and maintaining a network of minor victims whom he
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