{"efta_number": "EFTA00021252", "page_count": 14, "url": "https://epstein-data.com/EFTA00021252", "pdf_url": "https://epstein-data.com/pdf/EFTA00021252.pdf", "pages": [{"efta_number": "EFTA00021252", "page_number": 0, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \n \n \nx \nUNITED STATES OF AMERICA \nINDICTMENT \n19 Cr. \nJEFFREY EPSTEIN, \nDefendant. \nThe Grand Jury charges: \nOVERVIEW \n1. \nAs set forth herein, over the course of many years, \nJEFFREY EPSTEIN, the defendant, sexually exploited and abused \ndozens of minor girls at his homes in Manhattan, New York, and \nPalm Beach, Florida, among other locations. \n2. \nIn particular, from at least in or about 2002, up to \nand including at least in or about 2005, JEFFREY EPSTEIN, the \ndefendant, enticed and recruited, and caused to be enticed and \nrecruited, minor girls to visit his mansion in Manhattan, New \nYork (the \"New York Residence\") and his estate in Palm Beach, \nFlorida (the \"Palm Beach Residence\") to engage in sex acts with \nhim, after which he would give the victims hundreds of dollars \nin cash. Moreover, and in order to maintain and increase his \nsupply of victims, EPSTEIN also paid certain of his victims to \nrecruit additional minor girls to be similarly abused by \nEPSTEIN. In this way, EPSTEIN created a vast network of \nEFTA00021252\n", "char_count": 1102}, {"efta_number": "EFTA00021252", "page_number": 1, "text_content": "underage victims for him to sexually exploit, often on a daily \nbasis, in locations including New York and Palm Beach. \n3. \nThe victims described herein were as young as 14 years \nold at the time they were abused by JEFFREY EPSTEIN, the \ndefendant, and were, for various reasons, often particularly \nvulnerable to exploitation. Moreover, EPSTEIN, who \nintentionally sought out minors, knew that many of victims were \nin fact under the age of 18, including because, in some \ninstances, victims expressly told him that they were underage. \n4. \nIn creating and maintaining this network of minor \nvictims in multiple states to sexually abuse and exploit, \nJEFFREY EPSTEIN, the defendant, worked with others, including \nemployees and associates who facilitated his conduct by, among \nother things, contacting victims and scheduling their sexual \nencounters with EPSTEIN at the New York Residence and at the \nPalm Beach Residence. \nFACTUAL BACKGROUND \n5. \nDuring all time periods charged in this Indictment, \nJEFFREY EPSTEIN, the defendant, was a financier with multiple \nresidences in the continental United States, including the New \nYork Residence and the Palm Beach Residence. \n6. \nBeginning in at least 2002, JEFFREY EPSTEIN, the \ndefendant, enticed and recruited, and caused to be enticed and \nrecruited, dozens of minor girls to engage in sex acts with him, \n2 \nEFTA00021253\n", "char_count": 1376}, {"efta_number": "EFTA00021252", "page_number": 2, "text_content": "after which EPSTEIN paid the victims hundreds of dollars in \ncash, at the New York Residence and the Palm Beach Residence. \n7. \nIn both New York and Florida, JEFFREY EPSTEIN, the \ndefendant, perpetuated this abuse in similar ways. Victims were \ninitially recruited to provide \"massages\" to EPSTEIN, which \nwould be performed nude or partially nude, became increasingly \nsexual in nature, and would typically include one or more sex \nacts. EPSTEIN paid his victims hundreds of dollars in cash for \neach encounter. Moreover, EPSTEIN actively encouraged certain \nof his victims to recruit additional minor girls to be similarly \nsexually abused. EPSTEIN incentivized his victims to become \nrecruiters by paying these victim-recruiters hundreds of dollars \nfor each minor girl that they brought to EPSTEIN to be sexually \nabused. In so doing, EPSTEIN maintained a steady supply of new \nvictims to exploit. \nThe New York Residence \n8. \nAt all times relevant to this Indictment, JEFFREY \nEPSTEIN, the defendant, possessed and controlled a multi-story \nprivate residence on the Upper East Side of Manhattan, New York, \ni.e., the New York Residence. Between at least in or about 2002 \nand in or about 2005, EPSTEIN abused numerous minor victims at \nthe New York Residence by causing these victims to be recruited \nto engage in sex acts with him, after which EPSTEIN would \nprovide the victims with hundreds of dollars in cash. \n3 \nEFTA00021254\n", "char_count": 1436}, {"efta_number": "EFTA00021252", "page_number": 3, "text_content": "9. \nWhen a victim arrived at the New York Residence, she \nwould be escorted to a room with a massage table, where she \nwould perform a massage on JEFFREY EPSTEIN, the defendant. The \nvictims, who were as young as 14 years of age, were told by \nEPSTEIN or other individuals to partially or fully undress \nbefore beginning the \"massage.\" During the encounter, EPSTEIN \nwould escalate the nature and scope of physical contact with his \nvictim to include, among other things, sex acts such as groping \nand direct and indirect contact with the victims' genitals. \nEPSTEIN typically would also masturbate during these sexualized \nencounters, ask victims to touch him while he masturbated, and \ntouch victims' genitals with his hands or with sex toys. \n10. In connection with each sexual encounter, JEFFREY \nEPSTEIN, the defendant, or one of his employees or associates, \npaid the victim in cash. Victims typically were paid hundreds \nof dollars for each encounter. \n11. JEFFREY EPSTEIN, the defendant, knew that certain of \nhis victims were underage, including because certain victims \ntold him their age. Further, once these minor victims were \nrecruited, many were abused by EPSTEIN on multiple subsequent \noccasions at the New York Residence. EPSTEIN sometimes \npersonally contacted victims to schedule appointments for \n\"massages\" at the New York Residence. In other instances, \nEPSTEIN directed employees and associates, including a New York-\n4 \nEFTA00021255\n", "char_count": 1458}, {"efta_number": "EFTA00021252", "page_number": 4, "text_content": "based employee (\"Employee-1\"), to communicate with victims via \nphone to arrange for these victims to return to the New York \nResidence for additional sexual encounters with EPSTEIN. \n12. Additionally, and to further facilitate his ability to \nabuse minor girls in New York, JEFFREY EPSTEIN, the defendant, \nasked and enticed certain of his victims to recruit additional \nminor girls to perform \"massages\" and similarly engage in sex \nacts with EPSTEIN. When a victim would recruit another minor \ngirl for EPSTEIN, he paid both the victim-recruiter and the new \nvictim hundreds of dollars in cash. Through these victim-\nrecruiters, EPSTEIN gained access to and was able to abuse \ndozens of additional minor girls. \n13. In particular, certain recruiters brought dozens of \nadditional minor girls to the New York Residence to give \n\"massages\" to and engage in sex acts with JEFFREY EPSTEIN, the \ndefendant. EPSTEIN encouraged victims to recruit additional \nminor girls by offering to pay these victim-recruiters for every \nadditional minor girl they brought to EPSTEIN to be sexually \nabused. When a victim-recruiter accompanied a new minor victim \nto the New York Residence to be exploited by EPSTEIN, both the \nvictim-recruiter and the new minor victim were paid hundreds of \ndollars by EPSTEIN for each encounter. In addition, certain \nvictim-recruiters routinely scheduled these encounters through \n5 \nEFTA00021256\n", "char_count": 1417}, {"efta_number": "EFTA00021252", "page_number": 5, "text_content": "Employee-1, who sometimes asked the recruiters to bring a \nspecific minor girl for EPSTEIN. \nThe Palm Beach Residence \n14. In addition to recruiting and abusing minor girls in \nNew York, JEFFREY EPSTEIN, the defendant, created a similar \nnetwork of minor girls to victimize in Palm Beach, Florida, \nwhere EPSTEIN owned, possessed and controlled another large \nresidence, i.e., the Palm Beach Residence. EPSTEIN frequently \ntraveled from New York to Palm Beach by private jet, including \non occasions in which an employee or associate would ensure that \nminor victims were available for encounters upon his return to \nFlorida. \n15. At the Palm Beach Residence, JEFFREY EPSTEIN, the \ndefendant, engaged in a similar course of abusive conduct. \nWhen a victim initially arrived at the Palm Beach Residence, she \nwould be escorted to a room, sometimes by an employee of \nEPSTEIN's, including, at times, two assistants who, as described \nherein, were also responsible for scheduling the sexual \nencounters with minor victims (\"Employee-2\" and \"Employee-3\"). \nOnce inside, the victim would provide a nude or semi-nude \nmassage for EPSTEIN, who would himself typically be naked. \nDuring these encounters, EPSTEIN would escalate the nature and \nscope of the physical contact to include sex acts such as \ngroping and direct and indirect contact with the victims' \n6 \nEFTA00021257\n", "char_count": 1370}, {"efta_number": "EFTA00021252", "page_number": 6, "text_content": "genitals. EPSTEIN would also typically masturbate during these \nencounters, ask victims to touch him while he masturbated, and \ntouch victims' genitals with his hands or with sex toys. \n16. In connection with each sexual encounter, JEFFREY \nEPSTEIN, the defendant, or one of his employees or associates, \npaid the victim in cash. Victims typically were paid hundreds \nof dollars for each encounter. \n17. JEFFREY EPSTEIN, the defendant, knew that certain of \nhis victims were underage, including because certain victims \ntold him their age. In addition, as with New York-based \nvictims, many Florida victims, once recruited, were abused by \nJEFFREY EPSTEIN, the defendant, on multiple additional \noccasions. \n18. JEFFREY EPSTEIN, the defendant, who during the \nrelevant time period was frequently in New York, would arrange \nfor Employee-2 or other employees to contact victims by phone in \nadvance of EPSTEIN's return to Florida to ensure appointments \nwere scheduled for when he arrived. In particular, in certain \ninstances, Employee-2 placed phone calls to minor victims in \nFlorida to schedule encounters at the Palm Beach Residence. At \nthe time of certain of those phone calls, EPSTEIN and Employee-2 \nwere in New York, New York. Additionally, certain of the \nindividuals victimized at the Palm Beach Residence were \ncontacted by phone by Employee-3 to schedule these encounters. \n7 \nEFTA00021258\n", "char_count": 1403}, {"efta_number": "EFTA00021252", "page_number": 7, "text_content": "19. Moreover, as in New York, to ensure a steady stream of \nminor victims, JEFFREY EPSTEIN, the defendant, asked and enticed \ncertain victims in Florida to recruit other minor girls to \nengage in sex acts. EPSTEIN paid hundreds of dollars to victim-\nrecruiters for each additional minor girl they brought to the \nPalm Beach Residence to be sexually abused by EPSTEIN. \nSTATUTORY ALLEGATIONS \nCOUNT ONE \n(Sex Trafficking Conspiracy) \n20. From at least in or about 2002, up to and including in \nor about 2005, in the Southern District of New York and \nelsewhere, JEFFREY EPSTEIN, the defendant, and others known and \nunknown, willfully and knowingly did combine, conspire, \nconfederate, and agree together and with each other to commit an \noffense against the United States, to wit, sex trafficking of \nminors, in violation of Title 18, United States Code, Section \n1591(a) and (b). \n21. It was a part and object of the conspiracy that \nJEFFREY EPSTEIN, the defendant, and others known and unknown, \nwould and did, in and affecting interstate and foreign commerce, \nrecruit, entice, harbor, transport, provide, and obtain, by any \nmeans a person, and to benefit, financially and by receiving \nanything of value, from participation in a venture which has \nengaged in any such act, knowing that the person had not \n8 \nEFTA00021259\n", "char_count": 1327}, {"efta_number": "EFTA00021252", "page_number": 8, "text_content": "attained the age of 18 years and would be caused to engage in a \ncommercial sex act, in violation of Title 18, United States \nCode, Sections 1591(a) and (b)(2). \nOvert Acts \n22. In furtherance of the conspiracy and to effect the \nillegal object thereof, the following overt acts, among others, \nwere committed in the Southern District of New York and \nelsewhere: \na. \nIn or about 2004, JEFFREY EPSTEIN, the defendant, \nenticed and recruited multiple minor victims, including minor \nvictims identified herein as Minor Victim-1, Minor Victim-2, and \nMinor Victim-3, to engage in sex acts with EPSTEIN at his \nresidences in Manhattan, New York, and Palm Beach, Florida, \nafter which he provided them with hundreds of dollars in cash, \nrespectively, for each encounter. \nb. \nIn or about 2002, Minor Victim-1 was recruited to \nengage in sex acts with EPSTEIN and was repeatedly sexually \nabused by EPSTEIN at the New York Residence over a period of \nyears, and was paid hundreds of dollars for each encounter. \nEPSTEIN also encouraged and enticed Minor Victim-1 to recruit \nother girls to engage in sex acts, which she did, and was paid \nhundreds of dollars for each additional girl she brought to \nEPSTEIN. EPSTEIN asked Minor Victim-1 how old she was, and \nMinor Victim-1 answered truthfully. \n9 \nEFTA00021260\n", "char_count": 1307}, {"efta_number": "EFTA00021252", "page_number": 9, "text_content": "c. \nIn or about 2004, Employee-1, located in the \nSouthern District of New York, and on behalf of EPSTEIN, placed \na telephone call to Minor Victim-1 in order to schedule an \nappointment for Minor Victim-1 to engage in paid sex acts with \nEPSTEIN. \nd. \nIn or about 2004, Minor Victim-2 was recruited to \nengage in sex acts with EPSTEIN and was repeatedly sexually \nabused by EPSTEIN at the Palm Beach Residence over a period of \nyears, and was paid hundreds of dollars after each encounter. \nEPSTEIN also encouraged and enticed Minor Victim-2 to recruit \nother girls to engage in sex acts, which she did, and was paid \nhundreds of dollars for each additional girl she brought to \nEPSTEIN. \ne. \nIn or about 2005, Employee-2, located in the \nSouthern District of New York, and on behalf of EPSTEIN, placed \na telephone call to Minor Victim-2 in order to schedule an \nappointment for Minor Victim-2 to engage in paid sex acts with \nEPSTEIN at the Palm Beach Residence. \nf. \nIn or about 2005, Minor Victim-3 was recruited to \nengage in sex acts with EPSTEIN and was repeatedly sexually \nabused by EPSTEIN at the Palm Beach Residence over a period of \nyears, and was paid hundreds of dollars for each encounter. \nEPSTEIN also encouraged and enticed Minor Victim-2 to recruit \nother girls to engage in sex acts, which she did, and was paid \n10 \nEFTA00021261\n", "char_count": 1352}, {"efta_number": "EFTA00021252", "page_number": 10, "text_content": "hundreds of dollars for each additional girl she brought to \nEPSTEIN. EPSTEIN asked Minor Victim-3 how old she was, and \nMinor Victim-3 answered truthfully. \ng• \nIn or about 2005, Employee-2, located in the \nSouthern District of New York, and on behalf of EPSTEIN, placed \na telephone call to Minor Victim-3 in order to schedule an \nappointment for Minor Victim-3 to engage in paid sex acts with \nEPSTEIN at the Palm Beach Residence. \nh. \nIn or about 2004, Employee-3 placed a phone call \nto Minor Victim-3 in order to schedule an appointment for Minor \nVictim-3 to engage in paid sex acts with EPSTEIN at the Palm \nBeach Residence. \n(Title 18, United States Code, Section 371.) \nCOUNT TWO \n(Sex Trafficking) \n23. From at least in or about 2002, up to and including in \nor about 2005, in the Southern District of New York and \nelsewhere, JEFFREY EPSTEIN, the defendant, willfully and \nknowingly, in and affecting interstate and foreign commerce, did \nrecruit, entice, harbor, transport, provide, and obtain by any \nmeans a person, knowing that the person had not attained the age \nof 18 years and would be caused to engage in a commercial sex \nact, and did aid and abet the same, to wit, EPSTEIN recruited, \nenticed, harbored, transported, provided, and obtained numerous \n11 \nEFTA00021262\n", "char_count": 1290}, {"efta_number": "EFTA00021252", "page_number": 11, "text_content": "individuals who were less than 18 years old, including but not \nlimited to Minor Victim-1, as described above, and who were then \ncaused to engage in at least one commercial sex act in \nManhattan, New York. \n(Title 18, United States Code, Sections \n(b)(2), and 2.) \nFORFEITURE ALLEGATIONS \n24. As a result of committing the offense alleged in Count \nTwo of this Indictment, JEFFREY EPSTEIN, the defendant, shall \nforfeit to the United States, \nStates Code, Section 1594(d), \nthat was used, or intended to \nthe commission of the offense \nproperty, real \n1591(a), \npursuant to Title 18, United \nany property, real and personal, \nbe used to commit or to facilitate \nalleged in Count One, and any \nand personal, constituting or derived from, any \nproceeds obtained, directly or indirectly, as a result of the \noffense alleged in Count One, or any property traceable to such \nproperty, and the following specific property: \na. \nThe lot or parcel of land, together with its \nbuildings, appurtenances, improvements, fixtures, attachments \nand easements, located at 9 East 71st Street, New York, New \nYork, with block number 1386 and lot number 10, owned by \nMaple, Inc. \n12 \nEFTA00021263\n", "char_count": 1181}, {"efta_number": "EFTA00021252", "page_number": 12, "text_content": "Substitute Asset Provision \n25. If any of the above-described forfeitable property, as \na result of any act or omission of the defendant: \n(a) cannot be located upon the exercise of due diligence; \n(b) has been transferred or sold to, or deposited with, a \nthird person; \n(c) has been placed beyond the jurisdiction of the Court; \n(d) has been substantially diminished in value; or \n(e) has been commingled with other property which cannot \nbe subdivided without difficulty; \nit is the intent of the United States, pursuant to 18 U.S.C. \n2253(b), 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c), to seek \nforfeiture of any other property of the defendant up to the \nvalue of the above forfeitable property. \n(Title 18, United States Code, Sections 981 and 1594; and \nTitle 28, United States Code, Section 2461.) \nFOREPERSON \nGEOFFREY S. BERMAN \nUnited States Attorney \n13 \nEFTA00021264\n", "char_count": 881}, {"efta_number": "EFTA00021252", "page_number": 13, "text_content": "Form No. USA-33s-274 (Ed. 9-25-58) \nUNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF NEW YORK \nUNITED STATES OF AMERICA \nv. \nJEFFREY EPSTEIN \nDefendant. \nINDICTMENT \n(18 U.S.C. §§ 371, 1591(a), (b)(2), \nand 2) \nGEOFFREY S. BERMAN \nUnited States Attorney \nForeperson \n14 \nEFTA00021265\n", "char_count": 286}]}