EFTA00192670.pdf

GRAND JURY PRESENTATION OPERATION LEAP YEAR I. INTRODUCTION A. New Indictment 1. Summarize Changes 2. Summarize Current Charges 3. Review Law/Instructions 4. Go through legal allegations in introduction B. Summarize How the Evidence Will Be Presented 1. Chart 2. Break Overt Acts into Two Categories: a. Meetings/Sexual Activity — Grouped by victim — Testimony re Interviews with the Girls b. Flights — Manifests C. Take Questions D. Call Special Agent Kuyrkendall H. RETURN DOCUMENTS RECEIVED IN RESPONSE TO SUBPOENAS ISSUED SINCE THE LAST DOCUMENT RETURN. A. Have additional subpoenas been issued on behalf of this grand jury regarding Operation Leap Year? And have documents been received in response to those subpoenas? What subpoenas were issued and what items were received? Did you bring those records with you today? KUYRICENDALL SUBSTANTIVE TESTIMONY A. Hand out summary chart 1. Review renumbering of Jane Does a. S/A Kuyrkendall: Can you explain to the grand jury how the Jane Does have been renumbered? (They were numbered to try to appear in a more chronological order depending on their Page 1 of 11 EFTA00192670  first known contact with Mr. Epstein) b. S/A Kuyrkendall: Which of these girls has the grand jury already heard testimony about? 2. • Go over how chart is organized a. S/A Kuyrkendall: What does each column refer to? 3. Generally review references to transcript pages a. S/A Kuyrkendall: What does the list of transcript pages refer to? How was that list created? B. Go through the allegations in the Introductory Section of the Indictment. Summarize evidence that hasn't already been presented (I think just the high school allegations) C. Hand out flight chart 1. What does this chart refer to? What does each column mean? 2. Flip to a few overt acts and read the text aloud. What is the evidence in support of these allegations? (Flight manifests) 3. Remind the grand jury how the flight manifests were obtained. 4. So, for each flight referenced in the overt acts, what evidence was relied upon? And did you bring those flight manifests with you? Let's mark those manifests as Composite Grand Jury Exhibit Number JE-1. 5. There are several dozen manifests contained within Exhibit IE-1. Have you marked in any way the manifests related to the flights referenced in the indictment? And in reviewing those manifests, what information will the grand jurors find? [Airplane used. Date. Departure airport. Arrival airport. Arrival time. Passenger names.] D. Discuss telephone records 1. Flip to a few overt acts and read the text aloud. What is the evidence in support of these allegations? (Telephone records) Page 2 of 11 EFTA00192671  2. Remind the grand jury how the telephone records were obtained and whose telephone records were obtained. Were there any records that you tried to obtain that you couldn't? 3. Have you pulled the telephone records that contain the telephone calls referred to in the indictment? And did you bring them with you? Have you marked in any way the telephone bills that reference the calls listed in the indictment? And in reviewing those billing records, what information will the grand juror's find? (Telephone number called. Time and date of call. Call length.) TAKE A BREAK BEGIN TESTIMONY REGARDING THE GIRLS IV. JANE DOES 1 and 2 • A. Who is Jane Doe #1? 1. Has she been interviewed? In addition to her statements, who else provided information regarding Jane Doe #1? 2. During what period of time did Jane Doe #1 have contact with JE? 3. How old was she during that time frame? 4. How did she meet JE? 5. And what sexual activity was she involved in with JE? 6. Did she recruit anyone to go to JE's home? B. Who is Jane Doe #2? I. Has she been interviewed? In addition to her statements, who else provided information regarding Jane Doe #2? 2. During what period of time did Jane Doe #2 have contact with JE? 3. How old was she during that time frame? Page 3 of 11 EFTA00192672  4. How did she meet JE? 5. And what sexual activity was she involved in with JE? 6. How much was she paid for performing sexual massages for JE? 7. Did she recruit any of the other Jane Does to go to JE's home? 8. Please take us through the evidence supporting the overt acts related to Jane Doe #2. 9. What did Jane Doe #2 say about whether JE knew her age? 10. Who would contact Jane Doe #2 to make appointments? How would she be contacted? 11. Does your testimony cover the evidence supporting the allegations in overt acts 1 through 18? 12. Let's refer to Count 2. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #2 to engage in commercial sex acts knowing that she was under 18? JANE DOE #3 ( W.) A. Who is Jane Doe #3? Have you testified about her previously? B. Has she been interviewed? C. During what period of time did Jane Doe #3 have contact with JET D. How old was she during that time frame? E. How did she meet JE? F. And what sexual activity was she involved in with JET G. How much was she paid? H. Did she recruit anyone to go to JE's home? What did she tell you about Page 4 of 11 EFTA00192673  JE's recruiting requests? Were there girls whom Jane Doe #3 brought to Epstein's home whom he didn't like? Did he allow them to massage him? I. Did he ever become frustrated when JD#3 wasn't able to find a young girl for him? J. Does your testimony cover the evidence supporting the allegations in overt acts 19 through 31? K. Let's refer to Count 12. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #3 to engage in prostitution and in sexual activity for which a person can be charged with a criminal offense? [Florida violations — Jane Doe #3 was under the age of 16 when she *as involved with Epstein, so he could be charged with lewd and lascivious molestation, lewd and lascivious conduct, and lewd and lascivious exhibition based upon his touching of Jane Doe #3's breasts and genitals, his solicitation of Jane Doe #3 to commit a lewd and lascivious act, and his masturbation and exposure of his genitals in her presence.] VI. JANE DOES #4, 5, and 6 MI Ha C., and NM P.) A. Who are Jane Does #4, 5, and 67 Have you testified about them previously? B. Have they been interviewed? In addition to their statements, who else provided information regarding Jane Does #4, 5, and 6? C. During what period of time did Jane Does #4, 5, and 6 have contact with JE? D. How old were they during that time frame? E. What sexual activity did Jane Does #4 and #5 engage in with JE? F. Did either of them take anyone else to JE's home? G. What sexual activity was Jane Doe #6 involved in with JE? H. Did she take anyone else to JE's home? Page 5 of 11 EFTA00192674  I. Does your testimony cover the evidence supporting the allegations in overt acts 32-45? J. Let's refer to Count 3. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #4 to engage in commercial sex acts knowing that she was under 18? K. Let's refer to Count 13. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #4 to engage in prostitution? VII. TESTIMONY REGARDING GIRLS ALREADY COVERED IN GRAND JURY - JANE DOES 9, 10, 14, 15, 16 (Alex,liala,..1, and ) A. JANE DOE #9 (Alex H.) 1. Who is Jane Doe #9? Have you testified about her previously? a. Is there anything that you want to clarify or add regarding your earlier testimony? 2. Please remind the grand jury, during what period of tune did Jane Doe #9 have contact with JE? 3 How old was she during that time frame? 4. And please summarize the sexual activity that Jane Doe #9 was involved in with JE? a. Was she involved in sexual activity with any of the other defendants? 5. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 66-73, 75-77, 80-83, and 90? 6. Let's refer to Count 4. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #9 to engage in Page 6 of 11 EFTA00192675  commercial sex acts knowing that she was under 18? 7. Let's refer to Count 15. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #9 to engage in prostitution and in sexual activity for which a person can be charged with an offense? How many telephone calls have you been able to document between Jane Doe #9 and Kellen? 8. What was the activity for which a person could be charged with an offense [Vaginal intercourse between an adult over 24 and a 16 or 17 year old minor — violates Fl. Stat. 794.05] B. JANE DOE #10 (B.) 1. Who is Jane Doe #10? Have you testified about her previously? a. Is there anything that you want to clarify or add regarding your earlier testimony? 2. Please remind the grand jury, during what period of time did Jane Doe #10 have contact with JE? 3. How old was she during that time frame? 4. Please summarize the sexual activity that Jane Doe #10 was involved in with JE? 5. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 67, 74, 78-79, 81, 84-89, 147? 6. Let's refer to Count 5. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #10 to engage in commercial sex acts knowing that she was under 18? 7. Let's refer to Count 16. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #10 to engage in prostitution? How many telephone calls have you been able to Page 7 of 11 EFTA00192676  document between Jane Doe #10 and Kellen? VIII. OTHER BACKGROUND INFO A. Background re defendants and intro section — February 6, 2007 NK Transcript and May 8, 2007 NK Transcript pp. 17-end. B. ASK ABOUT ITEMS TO BE BROUGHT FOR FINAL PRESENTATION - MASSAGE BEDS!!! JANE DOE #14 la E.) 1. Who is Jane Doe #14? Have you testified about her previously? a. Is there anything that you want to clarify or add regarding your earlier testimony? 2. Please remind the grand jury, during what period of time did Jane Doe #14 have contact with JE? 3. How old was she during that time frame? 4. Please summarize the sexual activity that Jane Doe #14 was involved in with JE? 5. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 112-131? 6. Let's refer to Count 8, Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #14 to engage in commercial sex acts knowing that she was under 18? 7. Let's refer to Count 19. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #14 to engage in prostitution and in sexual activity for which a person can be charged with an offense? How many telephone calls have you been able to document between Jane Doe Nand Kellen? Page 8 of 11 EFTA00192677  a. How old was Jane Doe #14 during this period? And what is the sexual activity that she and JE engaged in that also violated Fl. Stat. 794.05? [Sexual intercourse btwn adult over 24 and a minor.] D. JANE DOE #15 (=NZ.) 1. Who is Jane Doe #15? Have you testified about her previously? a. Is there anything that you want to clarify or add regarding your earlier testimony? 2. Please remind the grand jury, during what period of time did Jane Doe #15 have contact with JE? 3. How old was she during that time frame? 4. Please summarize the sexual activity that she was involved in with JE? 5. Does your prior testimony and testimony here today cover the evidence supporting the allegations in overt acts 132-148, 175? 6. Let's refer to Count 9. Is the evidence you just summarized the basis for the allegation that JE, SK, and Adriana Ross procured Jane Doe #15 to engage in commercial sex acts knowing that she was under 18? 7. Let's refer to Count 20. Is the evidence you just summarized the basis for the allegation that JE, SK, and Adriana Ross used a facility of interstate commerce to persuade, induce, and entice Jane Doe #15 to engage in prostitution? How many telephone calls have you been able to document between Jane Doe #15 and Kellen? And how many telephone calls between Jane Doe #15 and Ross? E. JANE DOE #16 al D.) 1. Who is Jane Doe #16? Have you testified about her previously? Page 9 of 11 EFTA00192678  a. Is there anything that you want to clarify or add regarding your earlier testimony? 2. Please remind the grand jury, during what period of time did Jane Doe #16 have contact with JE? 3. How old was she during that time frame? 4. Please summarize the sexual activity that Jane Doe #16 was involved in with JE? 5. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 90, 149-151, and 156-181? 6. Let's refer to Count 10. Is the evidence you just summarized the basis for the allegation that JE, SK, Adriana Ross, and Nadia Marcinkova procured Jane Doe #16 to engage in commercial sex acts knowing that she was under 18? 7. Let's refer to Count 21. Is the evidence you just summarized the basis for the allegation that JE, SK, Adrian Ross, and Nadia Marcinkova used a facility of interstate commerce to persuade, induce, and entice Jane Doe #16 to engage in prostitution and in sexual activity for which a person can be charged with an offense? a. How many telephone calls have you been able to document between Jane Doe #16 and Kellen? Between Jane Doe #16 and Ross? And between Jane Doe #16 and Marcinkova? 8. What was the sexual activity that Jane Doe #16 and JE engaged in that also violated Fl. Stat. 794.05? [Sexual intercourse between an adult over 24 and a minor] IX. PRIOR DRUG USE/MENTAL HEALTH ISSUES A. Today we have discussed 11 victims — Jane Does 1 through 6, 9, 10, and 14 through 16. Are you aware of whether any of them have used illicit drugs or have had mental health issues? Please summarize. Page 10 of 11 EFTA00192679 B. Now, with respect to each of those girls, can you summarize for the grand jury your efforts to independently corroborate their statements? What physical evidence corroborates their statements to law enforcement? Page 11 of 11 EFTA00192680 E. JANE DOE # 16 a D.) and JANE DOE # 17 MIS D.) 1. Who is Jane Doe # 16? Have you testified about her previously? a. Is there anything that you want to clarify or add regarding your earlier testimony? 2. Please remind the grand jury, during what period of time did Jane Doe # 16 have contact with JE? 3. How old was she during that time frame? 4. Please summarize the sexual activity that Jane Doe # 16 was involved in with JE? 5. Did Jane Doe # 16 recruit anyone to go to JE's home? JANE DOE # 17 a D.) 6. Who is Jane Doe # 17? Have you testified about her previously? 7. Has she been interviewed? 8. During what period of time did Jane Doe # 17 have contact with JE? 9. How old was she during that time frame? 10. How did she meet JE? 11. And what sexual activity was she involved in with JE? 12. How much was she paid? 13. Did she recruit anyone to go to JE's home? JANE DOE # 16 HE D.) and JANE DOE # 17 al. D.) 14. Does your prior testimony and your testimony today cover the evidence supporting the allegations and overt acts 90, 149-151 and 156-181? 15. Let's refer to Count 10. Is the evidence you just summarized the basis for the allegation that JE, SK, AR and NM procured Jane Doe # 16 to engage in commercial sex acts knowing that she was under 18? 16. Let's refer to Count 21. Is the evidence you just summarized the basis for the allegation that JE, SK, AR and NM used a facility of interstate commerce to EFTA00192681  persuade, induce and entice Jane Doe # 16 to engage in prostitution and in sexual activity for which a person can be charged with an offense? a. How many telephone calls have you been able to document between Jane Doe # 16 and Kellen? Between Jane Doe # 16 and Ross? And between Jane Doe # 16 and Marcinkova? 17. What was the sexual activity that Jane Doe # 16 and JE engaged in that also violated Fl. Stat. 794.05? (Sexual intercourse between an adult over 24 and a minor) 18. Does your prior testimony and your testimony today cover the evidence supporting the allegations and overt acts 150-155? 19. Let's refer to Count 22. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe # 17 to engage in prostitution and in sexual activity for which a person can be charged with an offense? EFTA00192682 F. JANE DOE # 7 EMI L.) 1. Who is Jane Doe # 7? Have you testified about her previously? 2. Has she been interviewed? 3. During what period of time did Jane Doe #1have contact with JE? 4. How old was she during that time frame? 5. How did she meet JE? 6. And what sexual activity was she involved in with JE? 7. How much was she paid? 8. Did she recruit anyone to go to JE's home? 9. Does your testimony cover the evidence supporting the allegations in overt acts 46, 47, 54, 57, 59-64? I3 10. Let's refer to Countili%Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe # 7 to engage in prostitution and in sexual activity for which a person can be charged with an offense? How many telephone calls have you been able to document between Jane Doe # 7 and Kellen? lit; 01 Tcd-wr Mil tor Yr_cietu: anrAt_ ejjjt EFTA00192683 G. JANE DOE # 8 lalit E.) 1. Who is Jane Doe # 8? Have you testified about her previously? 2. Has she been interviewed? 3. During what period of time did Jane Doe # 8 have contact with JE? 4. How old was she during that lime frame? 5. How did she meet JE? 6. And what sexual activity was she involved in with JE? 7. How much was she paid? 8. Did she recruit anyone to go to JE's home? 9. Does your testimony cover the evidence supporting the allegations in overt acts 49-53, 55, 65? EFTA00192684 JANE DOE # 12 Ell= S.) 1. Who is Jane Doe # 12? Have you testified about her previously? 2. Has she been interviewed? 3. During what period of time did Jane Doe # 12 have contact with JE? 4. How old was she during that time frame? 5. How did she meet JE? 6. And what sexual activity was she involved in with YE? 7. How much was she paid? 8. Did she recruit anyone to go to JB's home? 9. Does your testimony cover the evidence supporting the allegations in overt acts 96, 98-104? 10. Let's refer to Count 06. Is the evidence you just summarized the basis for the allegation that YE, and SK procured Jane Doe # 12 to engage in commercial sex acts knowing that she was under 18? 11. Let's refer to Count 17. Is the evidence you just summarized the basis for the allegation that 3E, and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe # 12 to engage in prostitution and in sexual activity • for which a person can be charged with an offense? a. How many telephone calls have you been able to document between Jane Doe # 12 and Kellen? EFTA00192685 I. JANE DOE # 13 (al.) 1. Who is Jane Doe 11 13? Have you testified about her previously? 2. Has she been interviewed? 3. During what period of time did Jane Doe 11 13 have contact with JE? 4. How old was she during that time frame? 5. How did she meet JE? 6. And what sexual activity was she involved in with JE? 7. How much was she paid? 8. Did she recruit anyone to go to JE's home? 9. Does your testimony cover the evidence supporting the allegations in overt acts 96, 97, 104-111? 10. Let's refer to Count 07. Is the evidence you just summarized the basis for the allegation that JE, and SK procured Jane Doe # 13 to engage in commercial sex acts knowing that she was under 18? 11. Let's refer to Count 18. Is the evidence you just summarized the basis for the allegation that JE, and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe # 13 to engage in prostitution and in sexual activity for which a person can be charged with an offense? a. How many telephone calls have you been able to document between Jane Doe # 13 and Kellen? EFTA00192686 J. JANE DOE # 18 MEI A.) 1. Who is Jane Doe # 18? Have you testified about her previously? 2. Has she been interviewed? 3. During what period of time did Jane Doe # 18 have contact with JE? 4. How old was she during that time frame? 5. How did she meet JE? 6. And what sexual activity was she involved in with M? 7. How much was she paid? 8. Did she recruit anyone to go to JEs home? 9. Does your testimony cover the evidence supporting the allegations in overt acts 182-188, 190? 10. Let's refer to Count 23. Is the evidence you just summarized the basis for the allegation that M, and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe # 18 to engage in prostitution and in sexual activity for which a person can be charged with an offense? a. How many telephone calls have you been able to document between Jane Doe # 18 and Kellen? EFTA00192687 K. JANE DOE # 19 Mt H.) 1. Who is Jane Doe # 19? Have you testified about her previously? 2. Has she been interviewed? 3. During what period of time did Jane Doe # 19 have contact with JE? 4. How old was the during that time frame? 5. How did she meet JE? 6. And what sexual activity was she involved in with JE? 7. How much was she paid? 8. Did she recruit anyone to go to JE's home? 9. Does your testimony cover the evidence supporting the allegations in overt acts 189-190? EFTA00192688  4-(z_flos OPERATION LEAP YEAR REVISED INDICTMENT SUMMARY CHART (by victiml New Jane Old DOB Range of activity Overt Acts Substantive GJ Transcript Pages Doe # Jane dates Counts Doe # 1 n/a August 1983 1998 - 2003 1 n/a 2 n/a January 1987 2001 to 2003 1-18 2 5/8/07 NK Transcript pp. 6-7 3 n/a October 1987 2003 19-31 12 4 n/a August 1986 2004 32-38, 41 3 5 n/a October 1986 2004 32, 34, 39 n/a 6 n/a June 1987 2004 40-45 n/a 7 12 April 1988 7/04 46, 47, 54, 57, 13, 26 59-64 8 n/a November 1986 7/04 - 11/04 49-53, 55, 65 14, 26 9 6 December 1986 7/04 - 12/04 66-73, 75-77, 80- 4, 15, 26 5/22/07 NK Transcript 83, 90 pp. 16-27 10 7 February 1987 7/04 - 11/05 67, 74, 78-79, 81, 5, 16, 26 5/22/07 NK Transcript 84-89, 147 pp. 25-37 11 n/a October 1986 2004-2005 91-95 n/a 12 14 April 1987 8/04 - 2/05 96, 98-104 6, 17 CONFIDENTIAL & PRIVILEGED 1 ATTORNEY WORK PRODUCT EFTA00192689  New Jane Old DOB Range of activity Overt Acts Substantive GJ Transcript Pages Doe # Jane dates Counts Doe # 13 13 May 1987 8/04 -5/05 96, 97, 104-111 7, 18 14 5 June 1987 11/04 - 3/05 112-131 N'34 - 1, 27 5/22/07 NK Transcript pp. 4-13 15 3 June 1987 12/04 - 6/5/05 132-148, 175 \lil, 27 3/20/07 NK Transcript pp. 4-22 5/15/07 NK Transcript 3-17 Transcript pp. 23-25, 27-28 16 8 October 1987 2/05 - 10/05 '0, 149-151, 156- . \1 ),*2.1, 27, 28, 5/22/07 NK Transcript 181 29 pp. 39-47 17 9 April 1988 2/05 - 3/05 150-155 \.22 18 n/a February 1986 8/03 - 3/04 182-188, 190 23 19 n/a May 1986 3/04 189-190 n/a T.M. n/a July 1988 2003-2005 48, 52, 56, 58,59 n/a 5/8/07 MC. Transcript pp. 3-12 A.F. n/a n/a n/a 182 n/a Transcript pp. 5-13, 27 5/8/07 NK Transcript pp. 24-25 CONFIDENTIAL & PRIVILEGED 2 ATTORNEY WORK PRODUCT EFTA00192690 EFTA00192691 A-/2_q/c)? UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No: 18 U.S.C. § 371 18 U.S.C. § 1591(a)(1) 18 U.S.C. § 1591(a)(2) 18 U.S.C. § 2422(6) 18 U.S.C. § 2423(e) 18 U.S.C. § 2423(d) 18 U.S.C. § 2423(b) UNITED STATES OF AMERICA vs. JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a "Adriana Mucinska," and NADIA MARCINKOVA, Defendants. INDICTMENT The Grand Jury charges that: BACKGROUND At all times relevant to this Indictment: 1. Defendant JEFFREY EPSTEIN employed defendants SARAH KELLEN, ADRIANA ROSS, a/k/a "Adriana Mucinska," and NADIA MARCINKOVA to perform, among other things, services as personal assistants. EFTA00192692 2. Defendant JEFFREY EPSTEIN employed L.G. to perform, among other things, services as a personal assistant. 3! '3 Defendants JEFFREY EPSTEIN and SARAH KELLEN paid T.M., H.R., and A.F. to perform, among other things, recruiting services. 4. 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"). 5. Defendant JEFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as "the New York residence"). 6. 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 aircrifttearing tail number N908JE. A; L_ 7. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations. 8. Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., a Delaware corporation. Hyperion Air, Inc.'s solebusiness activities related to the operation h and ownership of a Gulfstream G-1159B aiit..afttearing tail number N909JE. 9. 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. EFTA00192693 10. 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 deg*." 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]-iqr a bona fide belief that such person is over the specified age [shall] 1- , be a defense." 11. Pursuant to Florida Statutes Sections 800.04(5Xa) 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 agglio 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. 12. Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who [i]ntentionally touches a person under 16 yearA 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. 3 EFTA00192694 13.. 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. 14. 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]." 15. 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 canno4e raised as a defense in a prosecution under [Section 800.04]." 16. 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." 17. Defendant JEFFREY EPSTEIN wasover the age of 24 and did not have any medical license. 4 EFTA00192695 18. During the period of her involvement with the Defendants, Jane Doe #4 attended Wellington High School and Palm Beach Central High School in Palm Beach County:: • 19. During the period of her involvement with the Defendants, Jane Doe #5 attended Wellington High School in Palm Beach County. 20. During the period of their involvement with the Defendants, Jane Does # 6, 8 and 12 attended Palm Beach Central High School in Palm Beach County. 71. During- the period of her involvement with the Defendants, Jane Doe #7 attended William T. Dwyer High School in Palm Beach County. 22. During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 17, 18, and 19 attended Royal Palm Beach High School in Palm Beach County. 23. During the period of er involvement with the Defendants, Jane Doe #10 attended Lake Worth High School in Palm Beach County. 24. During the period of her involvement with the Defendants, Jane Doe #11 attended the Professional Performing Arts School, a public high school, located in New York, New York. 25. During the period of her involventent with the Defendants, Jane Doe #13 attended John I. Leonard High School in Palm Beach County. 5 EFTA00192696 COUNT 1. (Conspiracy: 18 U.S.C. § 371) 26.,, Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 27. 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, SARAH ICELLBN, ADRIANA ROSS, a/k/a "Adriana Mucinska," and NADIA MARCINKOVA, 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 dr 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(6). Purpose and Object of the Conspiracy 28. It was the purpose and object of the rc6nspiracy to procure females under the age of 18 to travel to 358 El Brillo Way and the New York residence 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. 6 EFTA00192697 Manner and Means 29. 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 SARAH KELLEN, ADRIANA ROSS, a/k/a "Adriana Mucinska," NADIA MARCINKOVA, and other participants 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 and the New York residence to allow Ddin-dant JEFFREY EPSTEIN to engage in lewd conduct with them. (b) It was fitrther a part of the conspiracy that Defendants JEFFREY EPSTEIN, SARAH KELLEN, and ADRIANA ROSS, a/k/a "Adriana Mucinska," NADIA MARCINKOVA, and other participants would make payments to, or cause payments to be made to, minor females in exchangtihr engaging in lewd conduct. (c) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a "Adriana Mucinska," 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, SARAH KELLEN, ADRIANA ROSS, a/k/a "Adriana Mucinska," and other participants would make payments to, or cause payments to be made to, the recruiters for 7 EFTA00192698 bringing additional minor females to 358 El Brillo Way and the New York residence 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 NADIA MARCINKOVA to satisfy Defendant JEFFREY EPSTEIN's prurient interests. Overt Acts 30. In furtherance of this conspiracy and to effect the objects thereof, there was committed by at leastane'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 (1) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity wit bane Doe #1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl. (2) In or around 2001, Defendant SARAH KELLEN 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, DefendaniJEFFREY 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 fourteen years' old, to.pinch his nipples while he masturbated. 8 EFTA00192699 (5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. (6) In or around 2001, Defendant SARAH ICELLEN 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. (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 Iv eh 11, 2003, an employee of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's review 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 activities with him. (11) In or around 2003, Defendant SARAH KELLEN took nude photographs of Jane Doe #2, who was then a sixteen-year-old girl. EFTA00192700 (12) In or around 2003, Defendant SARAH KELLEN made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. ; (13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked KELLEN to take nude photographs ofJane Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Janc,Doe #2, who was then a sixteen-year-old girl. (15) In oraround 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 SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #2 to make an appointment fo