U.S. Department of Justice United States Attorney Southern District of New York Prosecution Memorandum Privileged and Confidential — Attorney Work Product Do Not Disseminate Outside of the SDNY USAO USAO #: United States v. Epstein, 19 Cr. ( ) June 11, 2019 This memorandum seeks authorization to charge JEFFREY EPSTEIN with one count of sex trafficking of children and one count of conspiracy to commit sex trafficking of children. These charges arise from a years-long scheme to recruit and entice minor girls into engaging in commercial sex acts, specifically sexualized massages and related sexual activity in exchange for money, in locations including Manhattan and Palm Beach, Florida. The proposed indictment is attached hereto, and this memorandum is submitted to provide additional factual background and relevant legal analysis. 1. Overview The Scheme For a period of years, from at least 2002 through approximately 2005, Epstein engaged in a pattern of enticing minor girls to engage in paid sex acts.' This conduct was in part revealed through a previous federal investigation into Epstein by the U.S. Attorney's Office and FBI in the Southern District of Florida ("SDFL"), which resulted in a 2007 non-prosecution agreement,2 and was further investigated and revealed thorough our investigation, which began in late 2018. As detailed below, the SDNY is not bound by the SDFL non-prosecution agreement; moreover, while our investigation and charges cover some conduct and victims initially identified by the SDFL investigation, our charges also include conduct and victims who were not interviewed during that prior investigation, including individuals who were victimized solely in New York. Based on our review of interview reports from the historical case file and from victim interviews in media, we have reason to believe that Epstein's conduct traces back at least to the 1990s. However, because the victims we have interviewed were not abused during