EFTA01703052.pdf

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 18 U.S.C. § 371 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 1591(aX2) 18 U.S.C. § 2422(b) 18 U.S.C. § 2423(b) 18 U.S.C. § 1591(aX1) UNITEIl STATES OF AMERICA vs. JE EPSTEIN, and Defendants. INDICTMENT T1 e Grand Jury charges that: BACKGRgUND i A all times relevant to this Indictment: 1.1 Defendant JEFFREY EPSTEIN employed defendants and to perform, allda among other things, services as personal assistants. EFTA01703052  2. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida. 3. 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. 4. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 5. Defendant JEFFREY EPSTEIN was a 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. 6. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of Hyperion Air, Inc., and had the power to direct all of its operations. 7. 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 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 activity does 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." 2 EFTA01703053  8. Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult "who intentionally 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 but less than 16 years of age. 9. 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. 10. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who: (1) [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 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. 11. Pursuant to Florida Statutes Section 800.04(2), "[n]either the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]." 3 EFTA01703054  12. 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]." 13. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical licensure. 14. During the period of their involvement with the Defendants, Jane Does # 3 and 10 attended in Palm Beach County. 15. During the periods of their involvement with the Defendants, Jane Does # 5, 6, 8, 12, 13, 14, 15, 16, 17, 18, and 19 attended in Palm Beach County. 16. During the period of her involvement with the Defendants, Jane Doe #7 attended in Palm Beach County. 17. During the period of her involvement with the Defendants, Jane Doe #9 attended in Palm Beach County. 18. During the period of her involvement with the Defendants, Jane Doe #11 attended in Palm Beach County. COUNT 1 (Conspiracy: 18 U.S.C. § 371) 4 EFTA01703055  19. Paragraphs 1 through 19 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 20. 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, i and 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 interstate 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(b). Purpose and Object of the Conspiracy 21. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way, Palm Beach, Florida 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 5 EFTA01703056  22. 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 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 to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. (b) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, and a/k/a 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, and a/lcia` 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 a/k/a would make payments to, or cause payments to be made to, the recruiters for bringing additional 6 EFTA01703057  steQ af jk.s .(Qocs 1t t G ecC31 yvt. ety 0 A\ \( br‘ o (5) In or around 2001, Defendant placed a telephone call to a telephone used by Jane Doc #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way. In or aro 02, Defe (7) In or around 209, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who would be interested in engaging in similar activities with him. (8) In or around 2003, Defendant took nude photographs ofJane Doe #2, who was then a sixteen-year-old girl. (9) In or around 2003, Defendant made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. (10) In or around 2003, Defendant told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked to take nude photographs ofJane Doe #2. (1c$-)n or around 2003, Defendant JEFFREY EPSTEIN in the presence ofJane Doe #2, who was then a sixteen-year-old girl. ich ierte 12) ,4In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2, who was then a sixteen-year-old girl. 8 EFTA01703058 minor females to 358 El Brillo Way to engage in lewd conduct with Defendant JEFFREY EPSTEIN. (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 satisfy Defendant JEFFREY EPSTEIN's prurient interests. Overt Acta 23. 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: c (1) In 2001, Defendant '—'-Jane Doe #2 eretherlaishem-si OCc ck matermtraisty upstairs to Dcfeadant JEFFREY EPSTEIN's bedroom at 358 El Brillo 0 4( ay. 2) In the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in with Jane Doe #1, who was then a seventeen-year-old girl, in the presence of Jane Doc #2, who was then a fourteen-year-old girl. (3) In Itsl ' oll iMkendant JEFFREY EPSTEIN n the presence of Jane Doe #2, who was then a fourteen-year-old girl. (4) IntirMtdant A— JEFFREY EPSTEIN made a payment of OL( CA $300 to Jane Doe #2 7 9 Ct • v o r eh a cat*. va. 2-OC I Dalet-haat\. 17 TAP EP4cul ti ed Oott 2-, wt.* te4ks '34/-Vsf•- ly Y ea.( s' °N.& +0 EFTA01703059 .;b, t- or zbo #±2 ps+L1/4v. (_•.1C4- kie-4 AL•14-C-0.1"\ _ y cow- - ti krit\ EFTA01703060  (Te k 40V\` / ) no f t (.. (fn. oo1 4/...vc(....4.3 6 or C., v.:, 1-...P)°1) (13) In or around 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. (14) In or around 200), JEFFREY EPSTEIN engaged in / (4- with an unidentified female in the presence of Jane Doe #2, who was then a year-old girl. • °Dews1 4/ (1 5) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane v-a-p;w_\. Doe #2, who was then a stx4esh-yea.414-girl, for allowing an unidentified female to perform on Jane Doe #2 in EPSTEIN's presence. (16) In or around dairpIrf 2003, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #4, who was then a fifteen-year-old girl. (17) In or around t 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe ti4. (18) In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe #4, who was then a sixteen- or seventeen-year-old girl, to an adult female and to the adult female's (19) Ina' around 2004, Defendant JEFFREY EPSTEIN placed a of an adult female in the presence of Jane Doe #4, who was then sixteen- or seventeen-year-old girl. EFTA01703061  (20) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of 200 to Jane Doe /M. (21) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe (22) In or around 2004, Defendant JEFFREY EPSTEIN placed a of Jane Doe #4, who was then a sixteen- or seventeen-year-old girl. 2(a- 29 (231 In or around the first half of 2004, Defendant JEFFREY EPSTEIN -iskaikais"" offered to pay Jane Doe #6 to bring additional girls to 358 El Brillo Way. , ‘0, "(a) In or around ra 2004, Defendant made a payment of S200 to Jane Doe #6 for recruiting a minor female to travel to 358 El Brillo Way. lo t 25) In or around the Mnet half of 2004, Defendant JEFFREY EPSTEIN Jane Doe #8, who was then a seventeen-year-old girl. 26) On or about March 11, 2004, Defendants JEFFREY EPSTEIN, =I and traveled from Teterboro, New Jersey, to (./ Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. 0444 k raA. 0 icL7- 10 EFTA01703062  Ci v cA. V14 / (9... 2_00 3 Ci s\--4t Tatra &-e_4t(c) A e brk tcici-exun Qr %ex)-ekcirca elp 5 r( • EFTA01703063  0 G r °Ai\ c. cc ) N p ivt4fckl 27) In or around March 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #5, who was then a seventeen-year-old girl, to travel to 358 El Brillo Way, Palm Beach, Florida. (28) In or around March 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #5, who was then a seventeen-year-old girl (29) In or around March 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Ja (3 On or about May , 2004, Defendant Beach County,-For laabc:rd the Boeing (31) On or about May 14, 2004, Defendants JEFFREY EPSTEIN, and traveled from Canada to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (32) On or about May 14, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #6. (33) In or around May 2004, Defendant led Jane Doe #6 from the kitchen at 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. 11 EFTA01703064  (34) In or around May 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #6, who was then a sixteen-year-old girl. (35) In or around May 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe O. c—Sx (36) On or about June 11, 2004, Defendants JEFFREY EPSTEIN and traveled I go, IIlino to Palm Beach County, Florida L.— aboard the Gulfstream aircraft owned y H erion Air, Inc. (37) On or about June I._1, \N 0 , Defendant made one or II 6 rajz' el ) more telephone calls to a telephtt use ki Jane Doe #6. (38) On or about June 20, 2i 04 pcfendant made one or V'fr ) 5morc telephone calls to a telephWu d by Jane Doe #6. (39) On or about 2004 Defendants JEFFREY EPSTEIN and trave Lffom the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (40) On or about July 4, 2004, Defendants JEFFREY EPSTEIN, and traveled from Aspen, Colorado to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (41) On or about July 4, 2004, Defendant made one or more telephone calls to a telephone used by Jane Doe #7. 12 EFTA01703065  (42) In or around July 2004, Defendant JEFFREY EPSTEIN led Jane Doe #3, who was then a fifteen-year-old girl, and Jane Doe #7, who was then a sixteen- years-old girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (43) In or around July 2004, Defendant JEFFREY EPSTEIN the presence of Jane Doe #7, who was then a sixteen-year-old girl. (44) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #7, who was then a sixteen-year-old girl, (45) In or around July 2004, Defendant JEFFREY EPSTEIN EMcif Jane Doe #7, who was then a sixteen-year-old girl. (46) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #7. (47) In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe #7 that if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN's home, bad things could happen to her. (48) In or around July 2004, Defendant JEFFREY EPSTEIN of Jane Doe #8, who was then a seventeen-year-old girl. (49) In or around July 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #8, who was then a seventeen-year-old girl. 13 EFTA01703066  0 t) orvii 14/-- (50) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of 5200 to Jane Doc #8. (51) On or about July 15, 2004, Defendant placed one or (7\e', more telephone calls to a telephone used by Jane Doc #7. 7.4? .//. ri) On or about July 15, 2004, Defendant placed one or ay- CkiAA4)- more telephone calls to a telephone used by Jane Doe #8. (53) On or about July 16, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. (54) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, and traveled from Teterboro. New Jersey to Palm Bcach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (55) On or about July 16, 2004, Defendant caused Jane Doe #8 to make one or more telephone calls to a telephone used by Jane Doe #9. ga, (56) On or about July 17, 2004, Defendant more telephone calls to a telephone used by Jane Doe #8. placed one or (57) On or about July 18, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #6. 14 EFTA01703067  (58) On or about July 18, 2004, Defendant placed one or Q,CL more telephone calls to a telephone used by Jane Doe #8. (59) On or about July 22, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doc #6. (60) On or about July 22, 2004, Defendant placed a - telephone call to a telephone used by Jane Doe #8. (61) On or about July 22, 2004, Defendant placed one or more telephone calls to a telephone used by Jane Doe #9. (62) On or about July 22, 2004, Defendants JEFFREY EPSTEIN, a and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (63) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and engaged in n the presence Ler of Jane Doe O. who was then a seventeen-year-old girl. (64) In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly of Jane Doe #8, who was then a seventeen- year-old girl. (65) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 or more to Jane Doe #8. 15 EFTA01703068  (66) In or around the last half of 2004, Defendant JEFFREY EPSTEIN r year-old girl. Jane Doe #9, who was then a seventeen- e f.( endues. cr% r- 0 • - k„.LA-Sf LA CA-‘f Ow c) 44C4 4..en-en tut3s (67) In or around the last half of 2004, efendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #9. wi S o Tc".-b •N. SCV44+cab-r-yeAtd& Z.Ve wko (68) In or around the last half of 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #10, who was then a seventeen-year-old girl. (69) In or around the last half of 2004, Defendant JEFFREY EPSTEIN Jane Doe h10, who was then a seventeen-year-old girl. (70) In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to of Jane Doe #10, who was then a seventeen-year-old girl. (71) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #10. (72) In or around the last half of 2004, Defendant led Jane Doe #I3 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (73) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked VJane Doe #13 to provide her telephone number. (74) In or around the last half of 2004, Defendant JEFFREY EPSTEIN (- instructed Jane Doe #13, who was then a seventeen-year-old girl, 16 EFTA01703069 C I:in. at " -": 3 A \ 'let 4 ea( -S \ La S t ,/t +t-c- Se krto. -Ir cateN - y ask s k c . EFTA01703070  (75) In or around the last half of 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #I3, who was then a seventeen-year old girl. (76) In or around the last hal f of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #13. (77) On or about August 19, 2004, Defendants JEFFREY EPSTEIN and traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (78) On or about August 21, 2004, Defendant placed one or more calls to a telephone used by Jane Doe #11. (79) On or about August 25, 2004, Defendants JEFFREY EPSTEIN, CO and traveled from Ecuador to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (80) In or around the last quarter of 2004, Defendant caused Jane Doe #5 to place a telephone call to Jane Doe #12. (81) In or around the last quarter of 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #5 to travel with Jane Doe #12 to 358 El L.---- Brillo Way. (82) In or around the last quarter of 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #12, who was then a sixteen-year-old girl. (83) In or around the last quarter of 2004, Defendant JEFFREY EPSTEIN of Jane Doe #12, who was then a sixteen-year-old girl. 17 EFTA01703071  (84) In or around the last quarter of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doc #12. (85) In or around the last quarter of 2004, Defendant JEFFREY EPSTEIN caused a payment to be made to Jane Doe #5 for recruiting Jane Doc #12 to travel to 358 El Brillo Way. (86) On or about October 2, 2004, Defendants JEFFREY EPSTEN, and traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (87) On or about October 29, 2004, Defendants JEFFREY EPSTEIN, , and traveled from Teterboro, New Jersey to Palm Bcach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, INC. (88) In or around the cnd of 2004, Defendant led Jane Doe #19, who was then a sixteen-year-old girl, from the kitchen of 358 El Brillo Way, upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (89) In or around the end of 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #19, who was then a sixteen-year-old girl. (90) In or around the end of 2004, Defendant JEFFREY EPSTF,IN made a payment of $200 to Jane Doe #19. 18 EFTA01703072  n or around the end of 2004, Defendant placed a teleP one call to a telephone used by Janc Doc 0/5 to arrange for Jane Doe #19 to travel to 358 El Brillo Way. (92) On or about November 10,2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (93) On or about November 18, 2004, Defendants JEFFREY EPSTEIN, a/Ida and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (94) In or around December 2004, Defendant caused Jane Doe #I2 to place a telephone call to Jane Doe #15. &Sint In or around December 2004, Defendant JEFFREY EPSTEIN Ow otc ..asaisposiamiliErf yment of S100 to Jane Doe #12 for bringing Jane Doe #15 to 358 El Brillo Way. (96) In or around December 2004, Defendant led Jane Doe #15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (97) In or around December 2004, Defendant JEFFREY EPSTEIN in the presence of Jane Doe #15, who was then a sixteen-year-old girl. (98) In or around December 2004, Defendant JEFFREY EPSTEIN ofJane Doe #15, who was then a sixteen-year-old girl. 19 EFTA01703073  In or around December 2004, Defendant JEFFREY EPSTEIN o ane oe 15, who was then a sixteen-year-old girl. (100) In or around December 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe 415, who was then a sixteen-year-old girl. (101) On or about December 3, 2004, Defendants JEFFREY EPSTEIN, and a/k/a " traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (102) On or about December 4, 2004, Defendant provided a written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 8 and 9, stating: "[Jane Doe #9] would like to work @ 4:00 pm if possible. [[Jane Doe #8] is scheduled for 5:00 today.] the movie is @ 7:30". (103) On or about December 6, 2004, Defendant placed one or more calls to a telephone used by Jane Doe #14. (104) On or about December 13, 2004, Defendant JEFFREY EPSTEIN traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (105) On or about December 17, 2004, Defendants JEFFREY EPSTEIN and traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstrcam aircraft owned by Hyperion Air, Inc. 20 EFTA01703074  fq (106) On or about December 18, 2004, Defendant eatteed place one or more telephone calls to a telephone used by Jane Doe (t0- In or around the last half of 2004 or January 2005, Defendant placed al_ ofiarre-Dote_p_t_who was then a seventee ear-old girl, in the presence of Defendant JEFFREY EPSTEIN. (108) In or a last half of 2 nuary-2005,Delendanal efendant JEFFREY EPSTEIN performed'- in the presence of Jane Doe #9, who was then a seventeen-year-old girl. (109) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN Jane Doc #13, who was then a seventeen- year-old girl. (110) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #13. (111) On or about December 29, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. (112) On or about December 30, 2004, Defendant used a credit card to purchase Broadway tickets as an eighteenth birthday gift for Jane Doe #8. (113) On or about January 1, 2005, Defendants JEFFREY EPSTEIN,M. an raveled from Anguilla, British West Indies 21 EFTA01703075  to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (114) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed aafJane Doc #13, who was then a seventeen- V — year-old girl. (115) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged in with Jane Doe 413, who was then a seventeen-year-old t — girl. (116) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN performed on Jane Doe #13, who was then a seventeen-year-old girl. (117) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $600 to Jane Doe #13. (118) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #17 to place a telephone call to Jane Doe #18 to ask her to travel to 358 El Brillo Way. (119) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN °mac/ c14/ e fret e4 prat to Jane Doe #17 for recruiting Jane Doe #18 to travel to 358 El Brillo Way. (120) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN in the presence of Jane Doe 418, who was then a sixteen-year-old girl. 22 EFTA01703076  (121) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doc #18, who was then a sixteen-year-old girl, to remove all of her clothing. (122) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a of Jane Doe #18, who was then a sixteen- year-old girl. (123) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN Vr made a payment of $200 to Jane Doe #18, who was then a sixteen-year-old girl. (124) In or around the first half of 2005, Defendant made a payment of $200 to Jane Doe #6 for recruiting another minor female to travel to 358 El Brillo Way. (125) In or around the first half of 2005, Defendant led Jane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (126) In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe 414, who was then a seventeen-year-old girl, (127) In or around the first half of 2005, Defendant JEFFREY EPSTEIN of Jane Doe #14. (128) In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #I4. V". 23 EFTA01703077  (129) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN lof Jane Doe #I7, who was then a seventeen- year-old girl. (130) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN lof Jane Doe #17, who was then ✓ a seventeen-year-old girl. (131) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Janc Doc #17, who was then a seventeen-year-old girl, how old she was. CYD*Ci cal s. 4 war /7 (132) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN with Defendan in the v „.. presence of Jane Doe #17, who was then a seventeen-year-old girl. (133) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #17, who was then a seventeen-year-old girl, to MEof Defendant (134) On or about January 6, 2005, Defendant JEFFREY EPSTEIN traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc. (135) On or about January 7, 2005, Defendant placed one or more calls to a telephone used by Jane Doe #14. 24 EFTA01703078 Jersey to Palm Beach County, Florida, aboard the Gulfstrcam aircraft owned by Hyperion Air, Inc. 168) In or around hileramleaft, Pendant JEFFREY EPST Jane Doe #1 I, who was then a seventeen-year-old girl. (169) On or about March 1, 2005, Defendant ailda placed one or more telephone calls to a telephone used by Jane Doe #13. (170) On or about March 4, 2005, Defendants JEFFREY EPSTEIN, a/k/al " andl traveled L---- from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (171) On or about March 16, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #13. (172) On or about March 17, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #14. (173) On or about March 18, 2005, Defendant JEFFREY EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (174) On or about March 18, 2005, Defendant left a telephone message for Defendant JEFFREY EPSTEIN regarding Jane Doe #6, stating: "Is it ok if [Jane Doe #6] will come at 5?" 29 EFTA01703079  (143) On or about January 28, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #9. (144) In or around the February 2005, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #8 for recruiting Jane Doe #.61,4 to travel to 358 El Brillo Way. $ (145) In or around Feltmmeeriiii4s Defendants JEFFREY EPSTEIN and caused Jane Doe 4-10 to recruit Jane Doe #11 to travel to 358 El Brillo Way. 4 1-^N., LA+. t'"'"•••4 (1 2d dif (146) In or around r-'- , efendant JEFFREY EPSTEIN of Janc Doe 411, who was then a seventeen-year-old girl. 4-tc o -tow+ k- c.^ (147) In or around fegatorpillibi, fend'Ant JEFFREY EPSTEIN of Jane Doe #11, who was thcn a seventeen-year-old girl. 1414 —Pe Ot itt /LW -- acto 4 148) -fondant JEFFREY EPSTEIN made a payment of $200 to Jane Doe 411. (149) On or about February 1, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #13. (150) On or about February 1, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #9. 26 EFTA01703080  (151) On or about February 3, 2005, Defendants JEFFREY EPSTEIN, and traveled from Columbus, Ohio, to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (152) On or about February 4, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe 414. (153) On or about February 6, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #5 to make one or more telephone calls to Jane Doe #16. (154) On or about February 6, 2005, Defendants JEFFREY EPSTEIN and caused Jane Doe #5 to transport Jane Doc #16 to 358 El Brillo Way, Palm Beach, Florida. (155) On or about February 6, 2005, Defendant JEFFREY EPSTEIN lofJane Doe 416, who was then a fourteen-year-old girl. (156) On or about February 6, 2005, Defendant JEFFREY EPSTEIN Jane Doe #16, who was then a fourteen-year-old girl. (157) On or about February 6, 2005, Defendant JEFFREY EPSTEIN placed of Jane Doe 416, who was then a fourteen-year-old \/. girl. (158) On or about February 6, 2005, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #16. 27 EFTA01703081  (159) On or about February 6, 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #5. (160) On or about February 10, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #13. (161) On or about February 10, 2005, Defendants JEFFREY EPSTEIN, a/k/a " and raveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (162) On or about February 10, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #14. (163) On or about February 21, 2005, Defendant placed one or more telephone calls to a telephone used by Jane (164) On or about February 21, 2005, Defendants and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. (165) On or about February 23, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #4. CC,,.) (166) On or about February 24, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #14. (167) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, and traveled from Teterboro, New 28 EFTA01703082  (136) On or about January 8. 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #13. (137) On or about January 9, 2005, Defendant aqua 'placed one or more telephone calls to a telephone used by Jane Doe #13. (138) On or about January 14, 2005, Defendant placed telephone call to a telephone used by Jane Doe #4. (139) On or about January 14, 2005, Defendants JEFFREY EPSTEIN, a/k/a " and traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE. INC. (140) On or about January 14, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #9. (141) On or about January 19, 2005, Defendants JEFFREY EPSTEIN, a/k/a "I and traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. (142) On or about January 27, 2005, Defendant a/k/a ' placed one or more telephone calls to a telephone used by Jane Doe #9. 25 EFTA01703083  (175) On or about March 21, 2005, Defendant a/kJa placed one or more telephone calls to a telephone used by Jane Doe #13. (176) On or about March 29, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #6. (177) On or about March 29, 2005, Defendantl placed one or more telephone calls to a telephone used by Jane Doe #5. (178) On or about March 29, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #13. (179) On or about March 30, 2005, Defendant placed one or more calls to a telephone used by Jane Doe #5. (180) On or about March 30, 2005, Defendant placed one , or more telephone calls to a telephone used by Jane Doe #14. (181) On or about March 31, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #14. (182) On or about March 31, 2005, Defendant iplaced one or more calls to a telephone used by Jane Doe #5. (183) On or about March 31,