EFTA00224444.pdf

U.S. ATTORNEY'S OFFICE SOUTHERN DISTRICT OF FLORIDA INDICTMENT/INFORMATION/RULE 20 APPROVAL COVER SHEET UNITED STATES OF AMERICA LIONS USAO NO. 2006R01181 U AUSA JEFFREY EPSTEIN AUSA Delivered to Supervisor 6/8/09 10:00 p.m. Date Time Defendants./ AF AUSA (if any) CHECK ALL OF THE FOLLOWING WHICH APPLY TO THIS CASE: X Indictment (Superseding ) Information (Indictment Waiver Attached) SEALED RULE 20 OCDETF - FC/FLS/ Operation FIRREA Case CORRUPTION Case (Federal/State/Local Official) PSN Case PSN Defendant (Name(s)) X PSC (Project Safe Childhood) Case VIOLENT CRIME Case OTHER (Credit card fraud, money laundering, illegal re-entry) VICTIM/WITNESS CASE: NO _ YES X (MUST check either yes or no) ESTIMATED NUMBER OF VICTIMS: Persons 33 Banks/Corps. Govt. ESTIMATED NUMBER OF WITNESSES: 40 (Persons subpoenaed) AUSA KING participated in this case/had supervisory authority over this case Reactive Case No Prosecution Memorandum Attached: X Yes Asset Forfeiture Count: X Yes No (With concurrence of NF AUSA) N/A (If yes, copy of indictment to Chief, Asset Forfeiture Division) Arrest Warrant(s) Attached X Yes Not Required Press Release Attached: Yes Not Required Yes TBut SEALED-DO NOT RELEASE UNTIL AUTHORIZED Date and Time of Presentation: Tuesday. June 16. 2009 We have reviewed the attached indictment/information with regard to legal sufficiency and find it will withstand a motion to dismiss for failure to state a crime. Final Approval Rtn'd for Revisions action Deputy Chief Date/Time Date/Time A il/6 Section Chief Dafetrime Date/Time /7 Dat Date/Time ,fr r puty Chief, Criminal Division Data/Time Date/Time First Assistant U.S. Attorney in Roctuity0) DaWrime Date/Time United States Attorney contiowtodi Date/Time Date/Time (lbw VOW EXHIBIT 86 Case No. 08-80736-CV-MARRA P-011701 EFTA00224444  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. IN RE SEALED INDICTMENT MOTION TO SEAL NOW COMES the United States of America, by and through its undersigned attorney, and respectfully requests that the indictment, arrest warrants, this motion, and any resulting Order be SEALED until the arrest of the defendants or until further order of this Court, excepting the United States Attorney's Office and federal law enforcement agencies, which may obtain copies of any indictment, arrest warrant, or other sealed document for purposes of arrest, extradition, or any other necessary cause, for the reason that the named defendants may flee, evidence may be destroyed, the integrity of the ongoing investigation might be compromised, and the safety of certain witnesses could be compromised should knowledge of this indictment become public. Respectfully submitted, JEFFREY H. SLOMAN ACTING UNITED STATES ATTORNEY By: ASSISTANT UNITED STATES ATTORNEY Florida Bar No. 500 East Broward Boulevard, 7th Floor Ft Lauderdale. FL 33394 Telephone: Facsimile: Case No. 08-80736-CV-MARRA P-011702 EFTA00224445  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. IN RE SEALED INDICTMENT SEALED ORDER The United States of America, having applied to this Court for an Order sealing the indictment, arrest warrants, its motion to seal, and this Order and the Court finding good cause: IT IS HEREBY ORDERED that the indictment, arrest warrants, and this Order shall be filed under seal until the arrest of the defendants or until further order of this Court, however, the United States Attorney's Office and any federal law enforcement agency may obtain copies of any indictment, arrest warrant, or other sealed document for purposcs of arrest, extradition, or any other necessary cause. DONE AND ORDERED in chambers at West Palm Beach, Florida, this day of June. 2009. LINNEA R. JOHNSON UNITED STATES MAGISTRATE JUDGE cc: AUSA Case No. 08-80736-CV-MARRA P-011703 EFTA00224446  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 18 U.S.C. § 371 18 U.S.C. § 1591(aX1) 18 U.S.C. § 1591(aX2) 18 U.S.C. § 2422(6) 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 2423(6) UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, a/k/a ' and Defendants. INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defendant JEFFREY EPSTEIN employed defendants afIcia `1 " and to perform, among other things, services as personal assistants. Case No. 08-80736-CV-MARRA P-011704 EFTA00224447  2. Defendants JEFFREY EPSTEIN and paid and ■. to perform, among other things, recruiting services. 3. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El Brillo Way"). 4. 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. 5. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 6. Defendant JEFFREY EPSTEIN was the principal owner ofIlyperion Air. Inc.. a Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation and ownership of a Gulfstream G-1 159B aircraft bearing tail number N909JE. 7. 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. 8. Pursuant to Florida Statutes Section 794.05, a "person 24 years ofage 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 2 Case No. 08-80736-CV-MARRA P-011705 EFTA00224448 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." 9. Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5Xc X2), 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 ofage 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. 10. Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6Xb), an adult "who [']ntentionally touches a person under 16 years of age in a lewd or lascivious manner or siolic its 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. II. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c). an adult "who: (1) [']ntentionally masturbates: (2) [']ntentionally exposes the genitals in a lewd or lascivious manner: or (3) Intentionally 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 3 Case No. 08-80736-CV-MARRA P-011706 EFTA00224449 16 years of age, commits lewd or lascivious exhibition." which is a felony of the second degree. 12. Pursuant to Florida Statutes Section 800.04(2), "inIcither the victim's lack of chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.041.- 13. Pursuant to Florida Statutes Section 800.04(3), "it'll': 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 800.041." 14. Pursuant to Florida Statutes Section 800.02, a "person who commits any unnatural and lascivious act with another person commits a misdemeanor of the second degree." 15. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical license. 16. During the period of her involvement with the Defendants. Jane Doe #4 attended and in Palm Beach County. 17. During the period of her involvement with the Defendants. Jane Doe it 5 attended in Palm Beach County. 4 Case No. 08-80736-CV-MARRA P-011707 EFTA00224450  18. During the period of their involvement with the Defendants, Jane Does # 6, 8, and 12 attended in Palm Beach County. 19. During the period of her involvement with the Defendants, Jane Doe #7 attended in Palm Beach County. 20. During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 17, 18, and 19 attended in Palm Beach County. 21. During the period of her involvement with the Defendants, Jane Doe #10 attended in Palm Beach County. 22. During the period of her involvement with the Defendants, Jane Doe #11 attended in Palm Beach County. 23. During the period of her involvement with the Defendants, Jane Doe #I3 attended in Palm Beach County. COUNT 1 (Conspiracy: 18 U.S.C. § 371) 24. Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 25. 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, 5 Case No. 08-80736-CV-MARRA P-011708 EFTA00224451  JEFFREY EPSTEIN, SARAH a/k/Fale 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 IS, United States Code, Section 2422(b). Purpose and Object of the Conspiracy 26. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way 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 27. 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 pan of the conspiracy that Defendants a/k/a ' and other participants would contact minor females via the use of cellular and other telephones to 6 Case No. 08-80736-CV-MARRA P-011709 EFTA00224452 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, a/k/a ' and other participants 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, a/k/a " ' and other participants 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, a/k/a ".1 " and other participants would make payments to, or cause payments to be made to, the recruiters for bringing additional 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. 7 Case No. 08-80736-CV-MARRA P-011710 EFTA00224453  Overt Act 28. 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, and elsewhere: Jane Does #1 and #2 (I) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity with Jane Doe 14 I. who was then a sev enteen-y ear-old girl, in the presence of Jane Doe 42, who was then a fourteen-year-old girl. CO In or around 2001. Defendant led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (4) In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, who was then a fourteen-years-old girl, to pinch his nipples while he masturbated. (5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. (6) In or around 2001, Defendant placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe 42 to travel to 358 El Brillo Way. 8 Case No. 08-80736-CV-MARRA P-011711 EFTA00224454  (7) In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse with an unidentified female in the presence of Jane Doe #2, who was then a fourteen- year-old girl. (8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN's presence. (9) On or about March 11, 2003,Defendant JEFFREY EPSTEINreviewed a written telephone message prepared by one ofhis employees regarding a telephone call received from Jane Doe #2. (10) In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who would be interested in engaging in similar sexual activities with him. (11) In or around 2003,Defendant -took nude photographs of Jane Doe #2, who was then a sixteen-year-old girl. (12) In or around 2003, Defendant made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. (13) In or around 2003, Defendant told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked to take nude photographs ofJane Doe #2. 9 Case No. 08-80736-CV-MARRA P-011712 EFTA00224455  (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a sixteen-year-old girl. (15) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a sixteen-year-old girl. (16) 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. (17) On or about April 23, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. (18) On or about May 2, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #2. Jane Poe #3 (19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #3, who was then a fifteen-year-old girl. (20) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. (21) On or about October 26, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. 10 Case No. 08-80736-CV-MARRA P-011713 EFTA00224456  (22) On or about October 30, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #3. (23) In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe #3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and to touch the adult female's breasts. (24) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of an adult female in the presence ofJane Doe #3, who was then a sixteen- or seventeen-year-old girl. (25) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3. (26) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #3 to rub his nipples. (27) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. (28) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way. II Case No. 08-80736-CV-MARRA P-011714 EFTA00224457  (29) On or about November 8, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #3 that read: "I have a female for him." (30) On or about January 14, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #3. (31) On or about January 29,2005, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doe #3 that read: "1have a female for him." Jane Does #4. #5. and #6 (32) In or around the first half of 2004, Defendant led Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (33) In or around the first half of 2004, Defendant JEFFREY EPSTEIN learned that Jane Doe #4 was seventeen years old when he asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. (34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, and Jane Doe #5, who was then a seventeen-year-old girl. 12 Case No. 08-80736-CV-MARRA P-011715 EFTA00224458  (35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his nipples. (36) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her clothing. (37) In or around the first half of 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doc N4, who was then a seventeen-year-old girl. (38) In or around the first halfof 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #4. (39) In or around the first hal for 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #5. (40) In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #6 what high school she attended. (41) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone. (42) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl. 13 Case No. 08-80736-CV-MARRA P-011716 EFTA00224459  (43) In or around the first half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #6, who was then a sixteen-year-old girl. (44) In or around the first half of 2004, Defendant JEFFREY EPSTEIN placed a large vibrating massager on the vagina of Jane Doe #6, who was then a sixteen-year-old girl. (45) In or around the first half of 2004, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #6. Jane Does #7 and #8 (46) In or around July 2004, Defendant JEFFREY EPSTEIN led.., who was then a fifteen-year-old girl, and Jane Doc #7, who was then a sixteen-year-old girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom. (47) On or about July 4, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #7. (48) On or about July 5, 2004, Defendant placed a telephone call to a telephone used by.. (49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #8, who was then a seventeen-year-old girl. 14 Case No. 08-80736-CV-MARRA P-011717 EFTA00224460  (50) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #8, who was then a seventeen-year-old girl. (51) In or around July 2004, Defendant JEFFREY EPSTEIN paid approximately $200 to Jane Doe #8. (52) In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to M. for recruiting Jane Doc #8 to travel to 358 El Brill° Way. (53) In or around July 2004, Defendant told Jane Doe #8 that Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a friend. (54) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #7. (55) On or about July IS, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. (56) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by (57) On or about July 16. 2004. Defendant placed one or more telephone calls to a telephone used by Jane Doe #7. (58) On or about July 16, 2004, Defendant placed a telephone call to a telephone used by 15 Case No. 08-80736-CV-MARRA P-011718 EFTA00224461  (59) On or about July 17, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from.. that read: "Me & [Jane Doe #7] can come tomorrow any time or I ] alone". (60) In or around July 2004. Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #7, who was then a sixteen-year-old girl. (61) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #7, who was then a sixteen-year-old girl, to rub his nipples. (62) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #7, who was then a sixteen-year-old girl. (63) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #7. (64) 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. (65) On or about July 24, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. Jane Does #9 and #1Q (66) On or about July 15, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. 16 Case No. 08-80736-CV-MARRA P-011719 EFTA00224462  (67) On or about July 16, 2004, Defendant caused Jane Doe #9 to make a telephone call to a telephone used by Jane Doe #10. (68) On or about July 17, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (69) On or about July 18, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (70) On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (71) In or around July 2004, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #9, who was then a seventeen-year-old girl. (72) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #9, who was then a seventeen-year-old girl. (73) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #9. (74) On or about July 22, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #10. (75) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and engaged in oral sex and sexual intercourse in the presence of Jane Doe #9, who was then a seventeen-year-old girl. 17 Case No. 08-80736-CV-MARRA P-011720 EFTA00224463  (76) In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly inserted his penis into the vagina of Jane Doe #9, who was then a seventeen- year-old girl. (77) In or around the last hal f o f 2004,Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #9. (78) In or around the last half of 2004, Defendant JEFFREY EPSTEIN rubbed the vagina of Jane Doe #10, who was then a seventeen-year-old girl. (79) In or around the last halfof2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #10. (80) On or about November 28, 2004, Defendant JEFFREY EPSTEIN arranged for one ofhis employees to provide an envelope filled with cash to Jane Doe #9. (81) On or about December 4, 2004, Defendant provided a written message to Defendant JEFFREY EPSTEIN regarding Jane Does # 9 and 10. stating: "[Jane Doe #101 would like to work ® 4:00 pm if possible. [[Jane Doe #9) is scheduled for 5:00 today.) the movie is ® 7:30". (82) On or about December 29, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #9. (83) On or about December 30, 2004. Defendants JEFFREY EPSTEIN and caused the purchase ofBroadway tickets as an eighteenth birthday gift for Jane Doe #9. 18 Case No. 08-80736-CV-MARRA P-011721 EFTA00224464  (84) In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen- year-old girl. (85) In or around the last half of 2004 orJanuary 2005, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #10, who was then a seventeen-year-old girl. (86) On or about January 14, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (87) On or about January 27, 2005, Defendant a/k/a " placed one or more telephone calls to a telephone used by Jane Doe #10. (88) On or about January 28, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (89) On or about February 1, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (90) In or around February 2005, Defendant JEFFREY EPSTEIN caused a payment of S200 to be made to Jane Doe #9 for recruiting Jane Doe #I6 to travel to 358 El Brillo Way. 19 Case No. 08-80736-CV-MARRA P-011722 EFTA00224465  Jane Doe #11 (91) In or around the summer of 2004, Defendant led Jane Doe #II and ■. from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's master bedroom suite. (92) In or around the summer of2004, Defendant JEFFREY EPSTEIN paid $200 to M. for bringing Jane Doe #Il to 358 El Brillo Way. (93) In or around the summer of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence ofJane Doe #11, who was then a fifteen- or sixteen-year- old girl. (94) In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doc #11 to rub his chest and pinch his nipples while he masturbated. (95) In or around the summer of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doc #11 to write her telephone number on a notepad in his master bedroom suite. (96) In or around the summer of 2004, Defendant JEFFREY EPSTEIN learned Jane Doe #11's true age when he asked Jane Doe #11 how old she was and she responded truthfully. (97) In or around the summer of2004, Defendant JEFFREY EPSTEIN told Jane Doc #11 that he did not care how old she was and that he did not like girls older than eighteen. 20 Case No. 08-80736-CV-MARRA P-011723 EFTA00224466  (98) In or around the second half of 2004. Defendant JEFFREY EPSTEIN placed a vibrating massager on the vagina of Jane Doe #11, who was then a sixteen- year-old girl. (99) In or around the second half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated the vagina of Janc Doc #11, who was then a sixteen-year-old girl. (100) On or about August 6, 2004, Defendant placed a telephone call to a telephone used by Janc Doe #11. (101) On or about August 18, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. (102) On or about October 29, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #11. (103) On or about November 5, 2004, Defendant placed a telephone call to a telephone used by Janc Doe # 11. (104) On or about February 14, 2005, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from Jane Doc #11 that read: "Please! Call her back". (105) On or about February 14, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #11. (106) On or about February 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doe # I I. 21 Case No. 08-80736-CV-MARRA P-011724 EFTA00224467  (107) On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe N11. (108) In or around the second half of 2005 or the first quarter of 2006. Defendant JEFFREY EPSTEIN offered to pay $400 to Jane Doe #11, who was then a sixteen-year-old girl, if she would engage in oral sex, or $500 or more if she would engage in sexual intercourse. (109) In or around the second half of 2005, Defendant JEFFREY EPSTEIN offered to pay $100 to Jane Doe #11 if she would bring other girls to 358 El Brillo Way. Jane Does #12 and #13 (110) On or about August 2, 2004, Defendant JEFFREY EPSTEIN reviewed a written telephone message prepared by one of his employees regarding a telephone call received from M. and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #13) too". (111) On or about August 21, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #I3. (112) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence ofJane Doc #I2, who was then a seventeen-year-old girl. (113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doc #I2, who was then a seventeen-year-old girl. 22 Case No. 08-80736-CV-MARRA P-011725 EFTA00224468  (114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to place a massaging device on the vagina of Jane Doe #12, who was then a seventeen-year-old girl. (115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #I2. (116) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #12, who was then a seventeen-year-old girl, about her age. (117) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #12 that he would take her to Los Angeles when she turned eighteen. (118) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and caused Jane Doe #12 to recruit Jane Doe #13 to travel to 358 El Brillo Way. (119) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #13, who was then a seventeen-year-old girl. (120) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #I3, who was then a seventeen-year- old girl. (121) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #13. (122) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #13, who was then a seventeen-year-old girl. 23 Case No. 08-80736-CV-MARRA P-011726 EFTA00224469  (123) In or around the last haI f of2004,Defendant JEFFREY EPSTEIN asked Jane Doe #I3, who was then a seventeen-year-old girl, about her age. (124) In or around the last hal f of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #13 that he wanted to take her to Paris but he could not because Jane Doe #13 was not yet eighteen years old. (125) In or around the last halfof 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #I3 to bring her friends to his home, especially - girls who looked like [Jane Doe #13]." Jane Doe #14 (126) In or around the last half of 2004. 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. (127) In or around the last halfof2004, Defendant JEFFREY EPSTEIN asked Jane Doe #14 to provide her telephone number. (128) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples. (129) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence oflane Doe #I4, who was then a seventeen-year old girl. (130) In or around the last halfof2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe N14. 24 Case No. 08-80736-CV-MARRA P-011727 EFTA00224470  (131) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeen- year-old girl. (132) In or around the end of 2004 and the beginning of 2005. Defendant JEFFREY EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl, whether she had any plans for her eighteenth birthday and acknowledged that she had not yet turned eighteen. (133) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #I4. (134) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #14, who was then a seventeen- year-old girl. (135) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doc #14, who was then a seventeen-year-old girl. (136) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl. (137) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $600 to Jane Doe #14. (138) On or about January 8, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #I4. 25 Case No. 08-80736-CV-MARRA P-011728 EFTA00224471  (139) On or about January 9, 2005, Defendant a/k/a " placed a telephone call to a telephone used by Jane Doe #I4. (140) On or about January 26, 2005, Defendant a/k/a " reviewed a written telephone message prepared by one of Defendant JEFFREY EPSTEIN's employees regarding a call received from Jane Doe #14 that read: "She is confirming for 5:30". (141) On or about January 26, 2005, Defendant a/k/a " placed a telephone call to a telephone used by Jane Doe #14. (142) On or about February 1, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. (143) On or about March 1, 2005, Defendant a/k/a " placed a telephone call to a telephone used by Jane Doe #I4. (144) On or about March 21, 2005, Defendant a/k/a " placed a telephone call to a telephone used by Jane Doe #I4. (145) On or about March 29, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #14. Jane Doe NS (146) On or about December 6, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. (147) On or about December 14, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #15. 26 Case No. 08-80736-CV-MARRA P-011729 EFTA00224472  (148) In or around the first half of 2005, 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. (149) In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #I5, who was then a seventeen-year-old girl, to pinch his nipples while he masturbated. (ISO) In or around the first half of 2005, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doc #I5. (151) In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doc #15. (152) On or about January 7, 2005, Defendant a/k/a ' placed a telephone call to a telephone used by Jane Doe #15. (153) On or about February 4, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. (154) On or about February 10, 2005, Defendant placed a telephone call to a telephone used by Janc Doc #I5. (155) On or about February 21, 2005, Defendant placed a telephone call to a telephone used by Jane Doc #15. (156) On or about February 24. 2005, Defendant placed a telephone call to a telephone used by Jane Doe #15. 27 Case No. 08-80736-CV-MARRA P-011730 EFTA00224473  (157) On or about March 17, 2005. Defendant placed a telephone call to a telephone used by Jane Doe #I5. (158) On or about March 30, 2005. Defendant placed a telephone call to a telephone used by Jane Doe #I5. (159) On or about March 31, 2005, Defendant placed a telephone call to a telephone used by Jane Doe #I5. (160) On or about March 31, 2005, Defendant ailda " placed a telephone call to a telephone used by Jane Doe #15. (161) On or about April 1, 2005, Defendant JEFFREY EPSTEIN reviewed a note prepared by one of his employees that read: "10:30 [Jane Doe #15]/Pane Doe #10j on Fri around 2Oclock". (162) In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane Doe #15 with a gift of Secret lingerie for her eighteenth birthday. Jane Does #16 & #17 (163) In or around February 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #I6, who was then a seventeen-year-old girl. (164) In or a