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