{"efta_number": "EFTA00224636", "page_count": 92, "url": "https://epstein-data.com/EFTA00224636", "pdf_url": "https://epstein-data.com/pdf/EFTA00224636.pdf", "pages": [{"efta_number": "EFTA00224636", "page_number": 0, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nFirst AuLstant U.S. 4liortrty \n99 NE thStreti \nMiam& FL 31132 \nDELIVERY BY FEDERAL EXPRESS \nJune 3, 2008 \nHonorable Mark Filip \nOffice of the Deputy Attorney General \nUnited States Department of Justice \n950 Pennsylvania Avenue, N.W. \nWashington, D.C. 20530 \nRe: \nJeffrey Epstein \nDear Judge Filip, \nJeffrey Epstein was a part-time resident of Palm Beach County, Florida.' In 2006, the Federal \nBureau of Investigation began investi tin alle ations that over a two-year period, Epstein paid \napproximately 28 minor females \nto come to his house for \nsexual favors? In July 2006, the matter was presented to AUSA \nof our West \nPalm Beach branch office to pursue a formal criminal investigation. That investigation resulted in \nthe discovery of approximately one dozen additional minor victims. Over the last several months, \napproximately six more minor victims hive been identified. \nAUSA \nhas been ready to present an indictment to a West Palm Beach federal grand \njury since May 2007. The prosecution memorandum and proposed indictment have been extensively \nreviewed and re-reviewed by Southern District of Florida (SDFL) Deputy Chief of the Criminal \n'Epstein has not resided in Palm Beach since he learned of the instant investigation. \n2 Epstein's sexual conduct with the victims included: instructing them to massage and pinch his \nnipples, masturbating in their presence, digitily penetrating them, using a vibrator on their vaginas, \nengaging in oral sex with them, having the victims perform oral sex on Epstein's adult girlfriend, and \nengaging in sexual intercourse, all in exchange for money, ranging from $200 to $1,000 per session. \nConfidential sod Privileged — Attorney Work Product \nEXHIBIT B-123 \nEFTA00224636\n", "char_count": 1811}, {"efta_number": "EFTA00224636", "page_number": 1, "text_content": "Division \nhi f o the Criminal Division \n, First Assistant United \nStates Attorney \n, United States Attorney R. Alexander Acosta as well as various \nmembers of the Child Exploitation \ne i \nSectio (CEOS) at the Department of Justice \nincluding, but not limited to its Chief, \n. Many of these legal and factual issues \nhave been discussed \nroved by Deputy Assistant Attorney General for the Criminal Division \nand the Assistant Attorney General for the Criminal Division (AAG) \n(DAAG) \nAlice S. Fisher, as well as the Criminal Division's Appellate Section and the Office of Enforcement \nOperations regarding the petit policy. \nBy May 2007, AUSA \nbe an seekin approval from her supervisors to indict \nEpstein. Her immediate supervisor was \n. Mr. \nhad served as the Chief of the \nPublic Integrity Section at DOJ as well as in several supervisory positions in the SDFL. By mid-\n2006, he had returned to his position as the. Deputy Chief of the Criminal Division in West Palm \nBeach (head of the West Palm Beach branch office), after serving as the interim Chief of the Public \nIntegrity Section at DOJ at the request of AAG Fisher. By October 2007 Mr. \nwould leave \ncommand were \nCriminal Division Chief, First Assistant USA \nthe SDFL to become AG Fi her's Chief of Staffs Above Mr. \nin the SDK's chain of \nand finally, \nU.S. Attorney Acosta. \nPrior to seeking approval to return an indictment, Epstein's legal team had been actively \nworking to convince this Office that such action was not warranted. For example, at the end of 2006, \nformer Ill \nAttorney and EOUSAExecutiveiiirr Guy Lewis contacted former colleagues \nAUSA \nand, later Deputy Criminal Chief \nwhen he learned that they were handling \nor involved in supervising the federal investigation of Epstein. In December, former SDFL AUSA \nLilly Ann Sanchez and \ncourt also contacted AUSA \nto set a meeting. In advance \nof that meeting, AUSA \nrequested documents but that request was refused. Ms. Sanchez \nthen contacted AUSA \n, who agreed to meet \n... [truncated, 3172 chars — for the full page use /api/corpus/document/EFTA00224636/1 or ?id=EFTA00224636&page=1]", "char_count": 3172}, {"efta_number": "EFTA00224636", "page_number": 2, "text_content": "with Criminal Division Chief \nthat time, the proposed initial indictment \npackage had been reviewed and approved by Mr. \nin West Palm Beach and by attorneys with \nCEOS; however, it awaited review by Mr. \nand FAUSA \n. The SDFL deferred \npresenting the indictment to the grand jury to accommodate the Epstein legal team's request for a \nmeeting. We also agreed to wait several weeks for that meeting to occur to allow four of Epstein's \nattorneys to be present and also provided counsel with a list of the statutes that were the subject of \nthe investigation. \nOn June 26, 2007, Mr. \nMr. M, \nAUSA \nand FAUSA—, and two \nFBI agents met with Alan Dershowitz, Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. During \nthat meeting, Professor Dershowitz and other members of the defense team presented legal and \nfactual arguments against a federal indictment. Counsel for the defense also requested the \nopportunity to present written arguments, which was granted. The arguments and written materials \nprovided by the defense were examined by the SDFL and rejected. \nOn July 31, 2007, Mr. \nMr. =, \nAUSA\n, and FAUSA \n, and two \nFBI agents met with Roy Black, Gerald Lefcourt, and Lilly Ann Sanchez. On that date, the SDFL \npresented a written sheet of terms that would satisfy the SDFL's federal interest in the case and \ndiscussed the substance of those terms. See Tab A. One of those terms was: \nEpstein agrees that, if any of the victims identified in the federal investigation file \nsuit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction of the U.S. \nDistrict Court for the Southern District of Florida over his person and the subject \nmatter. Epstein will not contest that the identified victims are persons who, while \nminors, were victims of violations of Title 18, United States Code, §§ 2422 and/or \n2423. \nDuring that meeting, the focus was on Mr. Epstein's unwillingness to spend time in prison, and \nvarious suggestions were raised by defense counsel, including the propos\n... [truncated, 3233 chars — for the full page use /api/corpus/document/EFTA00224636/2 or ?id=EFTA00224636&page=2]", "char_count": 3233}, {"efta_number": "EFTA00224636", "page_number": 3, "text_content": "of Mr. Epstein's proposal, in my extensive experience in these types of cases, the \nvictims prefer a quick resolution with compensation for damages and will always \nsupport any disposition that eliminates the need for trial. \nSee attached Tab B, August 2, 2007 letter from Lilly Ann Sanchez to SDFL Criminal Division Chief \np.2, fn 1. Ironically, it is Epstein's \"national\" attorneys who are now representing to the \nDeputy Attorney General of the United States in their May 19, 2008 letter that: \nPerhaps most troubling, the USAO in Miami, as a condition of deferring prosecution, \nrequired a commingling of substantive federal criminal law with a proposed civil \nremedy engineered in a way that appears intended to profit particular lawyers in \nprivate practice in South Florida with personal relationships to some of the \nprosecutors involved. \nNot only did Epstein's lawyers like the idea of using 18 U.S.C. § 2255 to compensate the victims \nbut, they also sought to make their non-incarcerative state proposal even more attractive by offering \npayments to \"a charitable organization benefitting victims of sexual assault,\" \"law enforcement \ninvestigative costs\" and \"Court and probationary costs.\" Id. at p. 2. \nEpstein's counsel, still dissatisfied with the Office's review of the case, demanded to meet \nwith U.S. Attorney Acosta and to have the opportunity to meet with someone in Washington, D.C. \nTo accommodate Roy Black, the meeting was put off until September 7, 2007, de ite the fact that \nthe indictment was ready for prefer \no t \nh grand jury. In the interim, AUSA \nand the \ninvestigators met with tltiwC\nf \nto review, yet again, the evidence an ega theories \nof prosecution. Chief \nstrongly supported the proposed indictment and even offered to \njoin the trial team and provide additional support from CEOS. \nOn September 7, 2007, U.S. Attorney Acosta met with Kirkland & Ellis partners hi \nLefkowitz \nrd. \nKen Starr and Ms. Sanchez, along with Chief \nand AUSAsNigga\n \nand FAUSA \n\"Me\n... [truncated, 3079 chars — for the full page use /api/corpus/document/EFTA00224636/3 or ?id=EFTA00224636&page=3]", "char_count": 3079}, {"efta_number": "EFTA00224636", "page_number": 4, "text_content": "II \nThe issue of the inclusion of a restitution-type remedy for the victims pursuant to 18 U.S.C. \n§ 2255 inoilically raised and discussed at the September \nmeeting, and Mt Starr thanked \nAUSA \nfor bringing it to his attention as a novel approach to allowing the victims to receive \nessentially federal restitution while allowing a plea to a state charge. After considering everything \nsaid and written by Epstein's legal team, and after conferring with Chief \n, U.S. Attorney \nAcosta informed Epstein's counsel that the SDFL still intended to proceed to indictment. Since \ncounsel indicated a desire to appeal the matter to the Attorney General, the Deputy Attorney General, \nor the Assistant Attorney General for the Criminal Division, U.S. Attorney Acosta agreed to delay \nthe presentation of the indictment for two weeks to allow them to speak with someone in \nWashington, D.C., if they so chose. \nInstead, Mr. Epstein elected to negotiate thearosecution A \nment, and on September \n12, 2007, counsel for the SDFL (AUSAs \n, and \nand counsel for Epstein \n(Messrs. Lefcourt, Leficowitz, and Goldber e \net with Palm Beach County State Attorney Barry \nKrisher and Assistant State Attorney \nto discuss a plea to an Information in the \nstate court that would satisfy the federal interest in the case. As noted on the term sheet of July 31\" \n(Tab A), one of those essential terms was a guilty plea to a charge requiring sex offender registration. \nDuring that meeting, the issue of sex offender registration was raised, and Mr. Goldberger told the \nfederal prosecutors that there was no problem, Mr. Epstein would plead guilty to the charge of \nprocurement of minors for prostitution (Fl. Stat. 796.03), which was one of the statutes listed on the \noriginal term sheet. Although the SDFL had wanted Epstein to plead guilty to three different \noffenses, we agreed to this compromise' Of course, the SDFL later learned that, at the time Mr. \nGoldberger made that statement, he incorrectly believed, based u\n... [truncated, 3770 chars — for the full page use /api/corpus/document/EFTA00224636/4 or ?id=EFTA00224636&page=4]", "char_count": 3770}, {"efta_number": "EFTA00224636", "page_number": 5, "text_content": "I. a \na conviction for a federal offense. And, third, it was the U.S. Attorney's belief that the SDFL should \nnot be put in the position of administering a restitution fund. Our § 2255 proposal put the victims \nin the same position that they would have been in if we had proceeded to trial and convicted Epstein \nof his crimes, with the exception that the victims were provided with counsel. The appointment of \ncounsel was not such a benefit to the victims but, rather, was done, in part, to benefit Epstein by \nallowing him to try to privately negotiate a group resolution of all claims with one attorney. Epstein \nand his lawyers agreed with this alternative. \nThe negotiation of the Agreement was lengthy and difficult. Mr. Lefkowitz and AUSA \nwent through several drafts of both a federal plea agreement and a Non-Prosecution \nAgreement. Throughout these negotiations, when a member of the defense team was dissatisfied \nwith the SDFL's position, it was repeatedly appealed throughout the Office. So several members of \nthe defense team spoke with the chain of command regarding the terms of the Agreement, including \nthe § 2255 provisions. At the eleventh hour, when Epstein's legal team realized that Fl. Stat. 796.03 \nwould require him to register as a sex offender, they sought to change the most essential term of the \nagreement - a term that Messrs. Goldberger, Lefkowitz, and Lefcourt had specifically agreed to at \nthe September 12:' meeting with the State Attorney's Office - asking to allow Epstein to plead to a \ncharge that would not require registration. When this was rejected, several members of the defense \nteam appealed directly to U.S. Attorney Acosta which also failed. When that failed, according to \npress reports, apparently Mr. Lefcourt \"leaked\" a letter intended for the U.S. Attorney to the press \ncontaining the reasons why he/Lefcourt did not believe Epstein should have to register. See October \n9, 2007 New York Post article attached at Tab C. \nPrior to signing the\n... [truncated, 3817 chars — for the full page use /api/corpus/document/EFTA00224636/5 or ?id=EFTA00224636&page=5]", "char_count": 3817}, {"efta_number": "EFTA00224636", "page_number": 6, "text_content": "Agreement with the Palm Beach County State Attorney's Office and the Judge of the I5°' Judicial \nCircuit and \"that the failure to do so will be a breach of the agreement' (emphasis added). To this \nday, the SDFL has never divulged its evidence to Epstein's lawyers. \nWithin a week of the execution of the Agreement, the SDFL unilaterally proposed to divest \nits right to select the attorney representative for the victims. Contrary to Messrs. Starr and Whitley's \nrecent assertion that this was \"engineered in a way that appears intended to profit particular lawyers \nin private practice in South Florida with personal relationships to some of the prosecutors involved,\" \nit was done to avoid even the appearance of favoritism in the selection of the attorney representative. \nAs a result, the parties executed an addendum which documented the SDFL's right to assign the \nselection of an attorney representative to an independent third-party. A copy of the October 29,2007 \nAddendum is attached hereto as Tab E. The parties subsequently agreed that retired Federal District \nCourt Jude Edward B. \nshould be that independent third-pasty/special master. Ultimately, \nJudge \nselected Robert C. Josefsberg of the law firm of Podhurst, Orseck, Josefsberg, et a1.10\nDuring this same time frame, Epstein lawyer Jay Lefkowitz sought to delay the entry of his guilty \nplea and sentence. After the SDFL accommodated his request (from October 26\"' to November 20th), \nMr. Starr began taking issue with the methodology of compensation, notification to the victims, and \nthe issues that had been previously considered and rejected during negotiations, i.e., that the conduct \ndoes not require registration and the contemplated state and federal statutes have no applicability to \nthe instant matter. \nIn response to Mr. Starr's protests, the SDFL offered numerous and various reasonable \nmodifications and accommodations which ultimately resulted in U.S. Attorney Acosta's December \n19, 2007 letter to Lilly Ann S\n... [truncated, 3349 chars — for the full page use /api/corpus/document/EFTA00224636/6 or ?id=EFTA00224636&page=6]", "char_count": 3349}, {"efta_number": "EFTA00224636", "page_number": 7, "text_content": "Mr. Starr also objected to the SDFL's intention to notify the victims pursuant to 18 U.S.C. \n§ 3771. In response to Mr. Starr's concerns, USA Acosta again consulted with DAAG \nwho advised him to make the following proposal: \"[w]e will defer to the discretion of the State \nAttorney regarding whether he wishes to provide victims with notice of the state proceedings, \nalthough we will provide him with the information necessary to do so if he wishes.\" These proposals \nwere immediately rejected by Epstein in Mr. Leflcowitz's December 26, 2007 correspondence to \nUSA Acosta. \nAt our December 14, 2007 meeting at the U.S. Attorney's Office in Miami, counsel for \nEpstein articulated that it was a \"profound injustice\" to require Epstein to register as a sex offender \nand reiterated that no federal crime, especially 18 U.S.C. § 2422(b), had been committed since the \nstatute is only violated if a telephone or means of interstate commerce is used to do the persuading \nor inducing. This particular attack on this statute had been previously raised and thoroughly \nconsidered and rejected by the SDFL and CEOS prior to the execution of the Agreement. Epstein's \nlawyers also argued that the facts were inapplicable to the contemplated state statutes and that he \nshould not have been allowed to have been induced into the Agreement because the facts were not \nwhat he understood them to be. To reiterate, the SDFL has never divulged its evidence to anyone on \nthe Epstein legal team. Once counsel for Epstein failed to persuade us that federal involvement was \ninappropriate, they mounted an aggressive campaign to defer federal prosecution. When we refused \nto compromise on anything except the length of incarceration, they finally executed the Non-\nProsecution Agreement. \nSubsequent to the December 14, 2007 meeting, the SDFL received three letters from Mr. \nLetkowitz and/or Mr. Starr which expanded on some of the themes announced in the December 14\" \nmeeting. Essentially, trying to portray the\n... [truncated, 3828 chars — for the full page use /api/corpus/document/EFTA00224636/7 or ?id=EFTA00224636&page=7]", "char_count": 3828}, {"efta_number": "EFTA00224636", "page_number": 8, "text_content": "SDFL to proceed with a federal prosecution of Mr. Epstein. CEOS Section Chief \nconcluded that \"federal prosecution \nimproper or inappropriate.\"See attached May 15, \n2008 letter from CEOS Section Chief \nto Jay Lefkowitz. On May 19, 2008, I notified Mr. \nLefkowitz that the SDFL would give Epstein a full two weeks (close of business on Monday, June \n2, 2008) to comply with the terms and conditions of the Non-Prosecution Agreement, as modified \nby the USA's December 10 letter to Ms. Sanchez.\" Therefore, despite the fact that the investigation \nhas identified several more victims, the SDFL is still offering Epstein the opportunity to comply with \nthe terms and conditions of the Non-Prosecution Agreement. \nThe SDFL was recently notified that the Office of the Deputy Attorney General has agreed \nto consider additional allegations not considered by CEOS which were recently raised in \ncorrespondence by two former high-ranking members of the Department of Justice - Ken Starr and \nJoe Whitley. On May 28,2008,1 notified Mr. Letkowitz by e-mail that the SDFL has postponed the \nJune 2, 2008 deadline until the DAG's Office has completed its review of this matter. Their \ncorrespondence to the DAG alleges that the SDFL's investigation lacks integrity because it has \nleaked \"highly ill \nal aspects\" of the investigation and negotiations to the New York Times \nand that FAUSA \ndirected some of the victims to my former law firm. They also claim that \nthe \"unprecedented extension of federal law\" by the SDFL suggests that this is politically motivated \nbecause Epstein is a prominent figure with \"c\n ties to former President Clinton.\" Messrs. Starr \nand Whitley go on to claim that FAUSA \nunilaterally, arbitrarily and unnecessarily imposed \na June 2, 2008 deadline in order to prevent Epstein from seeking your Office's review and that \"the \nunnecessary deadline is even more problematic because Mr. Epstein's effort to reconcile the state \ncharge and sentence with the terms of the Agreement requ\n... [truncated, 3228 chars — for the full page use /api/corpus/document/EFTA00224636/8 or ?id=EFTA00224636&page=8]", "char_count": 3228}, {"efta_number": "EFTA00224636", "page_number": 9, "text_content": "A. \nThe Morning ofJanuary 2, 2008. \nAUSA \nbegan his conversation with Mr. Thomas by explaining that he was the \nacting PIO for the week and that he had received Mr.Thomas's December 31, 2007 e-mail requesting \nan interview and asking for comments on the following five statements.\" First, \"that in the summer \nof 2005 the palm \nlice de rtment referred the Epstein case to you.\" Second, \"that the case \nis being overseen by \n, and above him, R. Alexander Acosta.\" Third, \"that Mr. Acosta \nhas made child pornography a focus are [sic) for your office.\" Fourth, \"that this summer your office \ngave Mr. Epstein an ultimatum: plead guilty to a charge that would require him to register as a sex \noffender, or the government would release a 52 page indictment, charging him with crimes that could \ninclude procuring sex for a third party or engaging in sexual tourism. Both of these charges carry jail \nsentences of as much as 15 years.\" Fifth, \"that your office S. \nEpstein and his lawyers: we are \nready to pull the trigger!\" Sixth, \"I also wanted to ask Mr. \nabout his role in a case involving \nJonathan Zirulnikoff and his daughter earlier this year!' \nAt the outset, \nsaid that he could not comment on any specific pending matters and \nthat he would do his best to answer some of his questions. Thomas said that his questions were \nbased, in part, upon conversations that he had already had with members of Mr. Epstein's defense \nteam, prior published reports of a pending State case against Mr. Epstein and public information \navailable through the State Court system. \nrefused to answer the first question. As to the second question, \ntold him \nthat any matter arising out of conduct in Palm Beach County, was prosecuted by our West Palm \nBeach branch office. He also told him that as First Assistant, the FAUSA had supervisory authority \nover all AUSAs throughout the District. In turn, the FAUSA answered directly to the U.S. Attorney. \nIn response to the third \ndiscussed the difference between c\n... [truncated, 3314 chars — for the full page use /api/corpus/document/EFTA00224636/9 or ?id=EFTA00224636&page=9]", "char_count": 3314}, {"efta_number": "EFTA00224636", "page_number": 10, "text_content": "Nor would he discuss anything about who might or might not be representing Mr. Epstein. \ntold Mr. Thomas that he should not allow himself to be spun one way or the other in response to \nstatements Mr. Thomas said he had received from attorneys who said that they represented Mr. \nEpstein. \nended the conversation by telling Mr. Thomas that he would check further into \nhis sixth and final topic and get back to him later in the day. \nB. \nAfternoon ofJanuary 2, 2008. \ninformed Mr. Thomas that in regard to his sixth topic, the SDFL had no reason \nto question FAUSA \njudgment or integrity. He also said that this particular subject matter \nwas a private matter that FAUSA \ndid not want to discuss with him.\" Mr. Thomas told him \nthat if he had any further questions, he would call back. \nC. \nAfternoon ofJanuary 3, 2008. \nThis call was in response to a voice mail message that Mr. Thomas had left regarding legal \nissues involving specific state and federal statutes. Specifically, Mr. Thomas had some questions \nabout the burden of proof and strict liability in some state and federal statutes that governed illegal \nsexual activity. Again, \ntold him that he would not discuss any specific cases, but that he \nwould assist him in understanding the statutes about which he had some questions. \nexplained that some statutes contained defenses that must be proven by a defendant, while there were \nother statutes that did not require a defendant to affirmatively prove a defense. The discussion \ncentered around Title 18, United States Code, § 2423(g). Once again, Mr. Thomas told \nthat if he had any further questions, he would call back. \nD. \nAfternoon ofJanuary 4, 2008. \nThis was another call in response to a voice mail message that Mr. Thomas had left regarding \nsome additional questions. \nprefaced the conversation by saying that he would not discuss \nany specific cases. The conversation centered around three specific statutes, 18 United States Code, \n§ 2422(b), 18 United States Code, § 1591,\n... [truncated, 3287 chars — for the full page use /api/corpus/document/EFTA00224636/10 or ?id=EFTA00224636&page=10]", "char_count": 3287}, {"efta_number": "EFTA00224636", "page_number": 11, "text_content": "burden of proof and the applicability of affirmative defenses. They discussed the difference between \nan attempt and a substantive charge pursuant to § 2422(b) and how that affected the government's \nburden of proof vis-a-vis the age of a child. They also discussed the fact that a charge pursuant to \n§ 1591 required the government to prove that the defendant had actual knowledge of the age of the \nvictim. Finally, they discussed the fact that if the government was charging a defendant with \ntraveling to engage in prostitution, pursuant to § 2423(b), there was an affirmative defense available \nto the defendant regarding the reasonable belief of the defendant about the age of the victim. \nE. \nAfternoon of January 7, 2008, \nThis final call was made after the U.S. Attorney and FAUSA \nbad received a call from \na member of Mr. Epstein's defense team alleging that the SDFL had provided case specific \ninformation to the media. \ncalled Mr. Thomas who acknowledged that both before and \nafter each of the above-mentioned conversations, he had also called attorneys who were representing \nMr. Epstein on his pending State charges. Mr. Thomas also acknowledged that all of our prior \nconversations had been about general legal issu an t at \nnever spoke about any specific \ncase. Since the January 7, 2008 conversation, \nhas not had any further contact with Mr. \nThomas. \n2. \n(May 5, 2001- October 1, 2001). \nSeven years ago, I resigned from the SDFL for private practice. Less than five months later, \nI resigned from the law firm and returned to the SDFL. Public records reflect the following: on May \n8, 2001, articles of a \nent w e fi \nwith the Florida Division of \nrations to reflect that \nthe firm name of ' \n' was changed to ` \n' on \nMay 7, 2001. I joined the firm at that time and remained a non-equity partner until on or a ut \nOctober 1, 2001. At that time, 1 resigned from the firm and returned to the SDFL. Since I never had \nan equity interest in the firm, I never retained an interest \n... [truncated, 3131 chars — for the full page use /api/corpus/document/EFTA00224636/11 or ?id=EFTA00224636&page=11]", "char_count": 3131}, {"efta_number": "EFTA00224636", "page_number": 12, "text_content": "week against Jeffrey Epstein. He said that his clients were frustrated with the lack of progress of the \nstate's investigation and wanted to know whether the SDFL could file criminal charges even though \nthe state was looking into the matter. I told Herman that I would not answer any question related to \nEpstein — hypothetical or otherwise. I asked him how his clients retained him and he said that it was \nthrough another lawyer. I then specifically asked him whether the referral was the result of anyone \nin law enforcement contacting him and/or the other lawyer. He said \"no.\" At the conclusion of the \nconversation, I reiterated and confirmed with him that I had refused to answer any questions he asked \nof me. I immediately documented this conversation an informed the U.S. Attorney who informed \nLitigation Counsel and Ethics Advisor \n. AUSA ■ \nopined that he did not see a \nconflict. As soon as I -became aware of these allegations, I reported myself to the Office of \nProfessional Regulation on or about April 21, 2008. \n3. \nThe Alleged Unprecedented Extension of Federal Law and the Allegations of \nPolitical Motivation for the Prosecution. \nIt is my hope that this letter has sufficiently explained how thoroughly this matter has been \nreviewed, how seriously the issues have been considered, and how additional delays may adversely \naffect the case going forward and, more importantly, the victims. I have attached the proposed draft \nindictment for you to consider the nature and gravity of the crimes. See Tab G. You are invited to \nevaluat w \ner I, along with U.S. Attorney A\nminal DivisiSiefs \nand, later \nDeputy Criminal Division Chiefs \nfollowed by \nand AUSA \nhave somehow steered this investigation toward \"an unprecedented extension of federal \nlaw\"despite being simultaneously and/or subsequently reviewed by CEOS, DAAG \n, and \nAAG Fisher. I also hope that the reputations of the above-mentioned professional prosecutors \ncombined with the documented layers of methodical and \n... [truncated, 3744 chars — for the full page use /api/corpus/document/EFTA00224636/12 or ?id=EFTA00224636&page=12]", "char_count": 3744}, {"efta_number": "EFTA00224636", "page_number": 13, "text_content": "throughout this case, particularly after their attempts at legal persuasion failed. Throughout the case, \ncounsel have misrepresented the facts of the case to our Office, CEOS, and the press. For example, \nEpstein's counsel reference to this case as \"precedent-shattering,\" suggests that all of the victims \nwere at least 16 years old, and that the conduct \"was purely local in nature.\" The SDFL has \nprosecuted several \"sex tourism\" cases where the \"john\" communicated via telephone with an \nundercover \"pimp\" in the SDFL to meet minor females to engage in prostitution. All were charged \nand convicted of violating 18 U.S.C. § 1591. The SDFL has charged and convicted a 21-year-old \nman of violating 18 U.S.C. § 2423 when he traveled to Florida to meet his 14-year-old girlfriend and \nlater digitally penetrated her. The SDFL has prosecuted numerous violations of 18 U.S.C. § 2422 \nwhere the \"facility of interstate commerce\" — generally the intemet and telephones — are used by a \ndefendant and an undercover pretending to be the parent of a minor, to arrange for a meeting that the \ndefendant hopes will result in sexual activity. There is nothing extraordinary about Epstein's case \nexcept the large number of victims involved. \nEpstein's counsel neglected to inform you that the age range of the victims includes girls as \nyoung as 14, and glosses over the fact that Epstein did not simply engage in \"solo self-pleasuring\" \nin front of the victims. Instead, with each visit, he pressured the victims to allow him to engage in \nmore and more sexual activity — fondling breasts and vaginas, digital penetration, use of a vibrator \non their vaginas, performing oral sex on them, having them perform oral sex on his adult girlfriend, \nand engaging in sexual intercourse. Counsel also neglected to inform you that many girls did \naffirmatively tell Epstein their true ages and he told several that he \"did not care about age.\" \nEpstein's conduct was not \"purely local.\" He and his assistants called \n... [truncated, 3718 chars — for the full page use /api/corpus/document/EFTA00224636/13 or ?id=EFTA00224636&page=13]", "char_count": 3718}, {"efta_number": "EFTA00224636", "page_number": 14, "text_content": "Epstein's counsel have repeatedly attacked the SDFL and the FBI for classifying the victims \nas \"victims.\" As you know, all Justice Department employees have the obligation to identify victims \nand to notify them of their rights. \"Victims\" are defined by law, not by self-selection. The girls \nwhom have been identified by the FBI and the SDFL fall within the legal definition — they were all \nminors who engaged in illicit sexual activity with Jeffrey Epstein, at his request, in exchange for \nmoney. From interviewing them, the FBI Special Agents, the FBI Victim-Witness Coordinator, and \nAUSA \nall feel confident that they suffered harm, in a multitude of ways, by their \ninteraction with Epstein. \nFinally, in contrast to Epstein's counsel allegation that my June 2, 2008 deadline was \n\"arbitrary, unfair, and unprecedented,\" please consider that Mr. Lefkowitz has known since February \nthat in the event that CEOS disagreed with his position, Epstein would be given one-week to comply \nwith the Non-Prosecution Agreement. Subsequent to the receipt of CEOS Section Chief \nMay 15, 2008 letter, I notified Mr. Lefkowitz that Epstein would have a MI two-weeks \nto comply with the Non-Prosecution Agreement as modified by the December 19' letter to Ms. \nSanchez. We believe it is finally time to shift the focus from Epstein's due process rights to treating \nhim like all other similarly situated criminal defendants and perhaps, most importantly, to consider \nthe rights of his victims. Continued delays adversely effect the case and the victims in the following \nways: \n(1) \nat the time of the offenses, the victims ranged in age from 14 to 17 years old. The \nchange in physical appearance of many of the victims since then has been dramatic. \nEpstein has been claiming that he did not know they were minors. Obviously, the \nolder they look when the case is at issue, the harder it will be to overcome that \ndefense; \n(2) \nit allows Epstein's lawyers to conduct depositions of the victims in the pe\n... [truncated, 3062 chars — for the full page use /api/corpus/document/EFTA00224636/14 or ?id=EFTA00224636&page=14]", "char_count": 3062}, {"efta_number": "EFTA00224636", "page_number": 15, "text_content": "On behalf of the SDFL and the victims in this case, please expedite the review and decision \nof the issues under consideration. \nSincerely, \nR. Alexander Acosta \nUnited States Attorney \nEnds. \ncc: \nChief \nAssistant U.S. Attorney \nAssistant U.S. Attorney \nBy: \nFirst Assistant United States Attorney \nConfidential and Privileged — Attorney Work Product \n-16-\nEFTA00224651\n", "char_count": 371}, {"efta_number": "EFTA00224636", "page_number": 16, "text_content": "CONFIDENTIAL PLEA NEGOTIATIONS \nTERMS OF EPSTEIN NON-PROSECUTION AGREEMENT \n■ \nEpstein pleads guilty (not nolo contendere) to an Information filed by the \nPalm Beach County State Attorney's Office charging him with: \n(a) \nlewd and lascivious battery on a child, in violation of Fl. Stat. \n800.04(4); \n(b) \nsolicitation of minors to engage in prostitution, in violation of Fl. \nStat. 796.03; and \n(c) \nengaging in sexual activity with minors at least sixteen years of age, \nin violation of Fl. Stat. 794.05. \n■ \nEpstein and the State Attorney's Office make a joint, binding \nrecommendation that Epstein serve at least two years in prison, without any \nopportunity for withholding adjudication or sentencing; and without \nprobation or community control in lieu of imprisonment. \n■ \nEpstein agrees to waive all challenges to the information filed by the State \nand the right to appeal. \n■ \nEpstein agrees that, if any of the victims identified in the federal \ninvestigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest \nthe jurisdiction of the U.S. District Court for the Southern District of \nFlorida over his person and the subject matter. Epstein will not contest that \nthe identified victims are persons who, while minors, were victims of \nviolations of Title 18, United States Code, Sections(s) 2422 and/or 2423. \n■ \nAfter Epstein enters his state court plea and is sentenced, the FBI and the \nU.S. Attorney's Office will close their investigations. \nEFTA00224652\n", "char_count": 1486}, {"efta_number": "EFTA00224636", "page_number": 17, "text_content": "cy g FOWLERWHITE \nBURNETT \nMUMM • FORT LAUDERDALE • WEST PALM BEACH • ST. PETERSBURG \nAugust 2, 2007 \nMr. \nChief, Criminal Division \nUnited States Attorney's Office \nSouthern District of Florida \n99 NE 4 Street \nMiami, Florida 33132 \nRe: Jeffrey Epstein \nESPIINIO SANTO PLAZA \nFOurnEENTII FLOOR \n1 395 BRICKELL AVE Nur \nMIAMI FLORIDA 3313 I \nTELEPHONE \nFACSImitE \nYNAV.FOWLERoATIITE.COM \nLILLY ANN SANCHEZ \nDIRECT PRONE NO.: \nDIRECT FACSIMILE No.: \nDear.: \nAs we discussed at Tuesday's meeting, and consistent with our view that no \nfederal prosecution should lie in this matter, Mr. Epstein is prepared to resolve this \nmatter via a state forum. We are in receipt of your memo regarding same and as the \ndynamics of the meeting did not allow for us to fully detail our proposal, we do so \nnow. We believe that our respective positions are not very far apart and that a \nmutually agreeable resolution can be reached that will accomplish the interests of the \nUnited States Attorney's Office as well as those of the community. \nWe welcomed your recognition that a state prison sentence is neither \nappropriate for, nor acceptable to, Mr. Epstein, as the dangers of the state prison \nsystem pose risks that are clearly untenable. We acknowledge that your suggestion \nof a plea to two federal misdemeanors was an attempt to resolve this dilemma. Our \nproposal is significantly punitive, and if implemented, would, we believe, leave little \ndoubt that the federal interest was demonstrably vindicated. \nThe Florida state judicial system, unlike the federal system, provides for \nnumerous types of onerous sanctions after a defendant is remanded to the custody of \nthe state. The sentence is tailored to the needs of the local community and the risk \nposed by a specific defendant. After a great deal of thought, our proposal consists \nof both a severe supervised custody, with an assurance that any violation would result \nin the immediate implementation of the two year period of incarceration. We must \n... [truncated, 2483 chars — for the full page use /api/corpus/document/EFTA00224636/17 or ?id=EFTA00224636&page=17]", "char_count": 2483}, {"efta_number": "EFTA00224636", "page_number": 18, "text_content": "Page 2 \nThe following proposal is offered as an assurance to the community that the \ngoals of appropriate punishment and rehabilitation arc attained. \nWe will agree to a sentence of two years in state prison pursuant to Florida \nStatute 948.012(2) which permits a split sentence whereby Mr. Epstein will be \nsentenced to a term of supervised custody, followed by a period of incarceration. \nSupervised custody in the state system includes potential daily surveillance, \nadministered by officers with restricted case loads. Supervised custody is an \nindividualized program in which the freedom of Mr. Epstein is limited to the \nconfines of his residence with specific sanctions imposed and enforced. See Florida \nStatute 948.001(2). Should Mr. Epstein successfully complete the terms and \nconditions of his custody, the Judge will eliminate the incarcerative portion of the \nsentence. If Mr. Epstein, however, fails to comply with the conditions of his \nsupervised custody. The period of incarceration will be immediately implemented. \nWe, therefore, propose the following: \nTwo years supervised custody with the following mandatory and special \nconditions: \no Confinement to home \no Report to a community control officer at least once a week or more \noften as directed by the officer \no Permit a community control officer to visit him unannounced at home \nat any time, day or night \no Obtain psychological counseling \no No unsupervised contact with all the victims in the instant case \n• \nPerform community service \no Payment of Restitution \no Application of 18 U.S.C. § 2255' \n• \nPayment of a contribution of a defined amount to a charitable \norganization benefitting victims of sexual assault \no Payment of Court and probationary costs \no Payment of law enforcement investigative costs \no Submit to random drug testing \no Refrain from associating with persons engaged in criminal activities \no Refrain from committing any new law offenses \no Any other specific conditions that the Office may deem n\n... [truncated, 2858 chars — for the full page use /api/corpus/document/EFTA00224636/18 or ?id=EFTA00224636&page=18]", "char_count": 2858}, {"efta_number": "EFTA00224636", "page_number": 19, "text_content": "Page 3 \no Mandatory conditions as provided in Florida Statute § 948.03 \no Special conditions as stated above \nIf the terms of supervised custody and probation are successfully completed, \nthen the two years of state prison is eliminated. \nThis proposal provides for the two year imposition of the state prison sentence \nif any violation of the supervised custody or probation occurs. Accordingly, the \nOffice's position that Mr. Epstein agree to a resolution that includes jail time is \nsatisfied by this proposal. It would immediately bring closure to a matter that has \nbeen pending for over two years, allows Mr. Epstein to commence with his sentence, \nand, most significantly, allow the victims to move forward with their lives. We are \nin process of scheduling a meeting with R. Alexander Acosta, United States \nAttorney, to further discuss this matter. \nSincerely, \nLilly Ann Sanchez \ncc. \nR. Alexander Acosta \nGerald Lefcourt \nRoy Black \nFOWLER WHITE BURNETT P.A.\nEFTA00224655\n", "char_count": 984}, {"efta_number": "EFTA00224636", "page_number": 20, "text_content": "Page I of I \nEPSTEIN EYES SEX-RAP RELIEF \nBusiness-\nBundle-A-Day \nG I VEAW/LY \nFilter daily to win an bc \ninn-edibleprim \nfor your \n9 r.O's a nov»\nbuaines\nValued at \nmore than \n'550! \nkbxne. \n4 \nEnter:inv., \n. October 9, 2007 - LAWYERS for Jeffrey Epstein - the billionaire Manhattan \nEa investment manager who's agreed to plead guilty to soliciting underage \nprostitutes at his Palm Beach mansion in exchange for just 18 months in the \nstammer - are mulling asking federal prosecutors to drop their demand that he \nregister as a sex offender. In a letter drafted, but not sent, to U.S. Attorney \nAlexander Costa and obtained by Page Six, Epstein's lawyer, Gerald \nLefcourt, writes, \"Doing so will have a profound impact [on Epstein) both \nimmediately and forever after. Not only will he be restricted to a wholly \ninappropriate penal facility, but he will be required for the rest of his life to \naccount for his whereabouts.\" Epstein, a former business partner of Daily \nNews owner Mort Zuckerman, pleaded guilty to a state charge in exchange \nfor the feds' dropping their probe into possible federal criminal violations. \nLefcourt argues that only the feds have demanded that Epstein register, \n\"despite the fact that the state was of the view that Mr. Epstein's conduct did \nnot warrant registration.\" A rep for Epstein had no comment. \nNEW YORK POST Isa registered Uedemerk of NYP Holdings, kle. NYPOST.COM, NYPOSTONLINE.COM, and \nNEWYORKPOST.COM \nere trademarks or NYP Holdings. Inc. \nCopyright 2008 NYP Holdings, Inc. All rights reserved \nhttp://www.nypost.com/php/p friendly/print.php/url=http://www.nypost.com/seven/1009200... 6/3/2008 \nEFTA00224656\n", "char_count": 1659}, {"efta_number": "EFTA00224636", "page_number": 21, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nNON-PROSECUTION AGREEMENT \nIT APPEARING that the City of Palm Beach Police Department and the State \nAttorney's Office for the 15th Judicial Circuit in and for Palm Beach County (hereinafter, \nthe \"State Attorney's Office\") have conducted an investigation into the conduct of Jeffrey \nEpstein (hereinafter \"Epstein\"); \nIT APPEARING that the State Attorney's Office has charged Epstein by indictment \nwith solicitation of prostitution, in violation of Florida Statutes Section 796.07; \nIT APPEARING that the United States Attorney's Office and the Federal Bureau of \nInvestigation have conducted their own investigation into Epstein's background and any \noffenses that may have been committed by Epstein against the United States from in or \naround 2001 through in or around September 2007, including: \n(1) \nknowingly and willfully conspiring with others known and unknown to \ncommit an offense against the United States, that is, to use a facility or means \nof interstate or foreign commerce to knowingly persuade, induce, or entice \nminor females to engage in prostitution, in violation of Title 18, United States \nCode, Section 2422(b); all in violation of Title 18, United States Code, Section \n37 I ; \n(2) \nknowingly and willfully conspiring with others known and unknown to travel \nin interstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(9, with minor females, in violation of Title 18, \nUnited States Code, Section 2423(6); all in violation of Title 18, United States \nCode, Section 2423(c); \n(3) \nusing a facility or means of interstate or foreign commerce to knowingly \npersuade, induce, or entice minor females to engage in prostitution; in \nviolation of Title IS, United States Code, Sections 2422(b) and 2; \n(4) \ntraveling in interstate commerce for the purpose of engaging in illicit sexual \nconduct, as defined in 18 U.S.C. § 2423(9, with minor females; in violation \nPage 1 of 7 \nEFTA00224\n... [truncated, 2004 chars — for the full page use /api/corpus/document/EFTA00224636/21 or ?id=EFTA00224636&page=21]", "char_count": 2004}, {"efta_number": "EFTA00224636", "page_number": 22, "text_content": "of Title 18, United States Code, Section 2423(b); and \n(5) \nknowingly, in and affecting interstate and foreign commerce, recruiting, \nenticing, and obtaining by any means a person, knowing that the person had \nnot attained the age of 18 years and would be caused to engage in a \ncommercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title \n18, United States Code, Sections 1591(aXI) and 2; and \nIT APPEARING that Epstein seeks to resolve globally his state and federal criminal \nliability and Epstein understands and acknowledges that, in exchange for the benefits \nprovided by this agreement, he agrees to comply with its terms, including undertaking certain \nactions with the State Attorney's Office; \nIT APPEARING, after an investigation of the offenses and Epstein's background by \nboth State and Federal law enforcement agencies, and after due consultation with the State \nAttorney's Office, that the interests of the United States, the State of Florida, and the \nDefendant will be served by the following procedure; \nTHEREFORE, on the authority of R. Alexander Acosta, United States Attorney for \nthe Southern District of Florida, prosecution in this District for these offenses shall be \ndeferred in favor of prosecution by the State of Florida, provided that Epstein abides by the \nfollowing conditions and the requirements of this Agreement set forth below. \nIf the United States Attorney should determine, based on reliable evidence, that, \nduring the period of the Agreement, Epstein willfully violated any of the conditions of this \nAgreement, then the United States Attorney may, within ninety (90) days following the \nexpiration of the term of home confinement discussed below, provide Epstein with timely \nnotice specifying the condition(s) of the Agreement that he has violated, and shall initiate its \nprosecution on any offense within sixty (60) days' of giving notice of the violation. Any \nnotice provided to Epstein pursuant to this paragraph shall be provided\n... [truncated, 2636 chars — for the full page use /api/corpus/document/EFTA00224636/22 or ?id=EFTA00224636&page=22]", "char_count": 2636}, {"efta_number": "EFTA00224636", "page_number": 23, "text_content": "Terms of the Agreement: \nI. \nEpstein shall plead guilty (not nolo contendere) to the Indictment as \ncurrently pending against him in the 15th Judicial Circuit in and for \nPalm Beach County (Case No. 2006-c1009495AXXXMB) charging \none (1) count of solicitation of prostitution, in violation of Ft. Stat. § \n796.07. In addition, Epstein shall plead guilty to an Information filed \nby the State Attorney's Office charging Epstein with an offense that \nrequires him to register as a sex offender, that is, the solicitation of \nminors to engage in prostitution, in violation of Florida Statutes Section \n796.03; \n2. \nEpstein shall make a binding recommendation that the Court impose a \nthirty (30) month sentence to be divided as follows: \n(a) \nEpstein shall be sentenced to consecutive terms of twelve (12) \nmonths and six (6) months in county jail for all charges, without \nany opportunity for withholding adjudication or sentencing, and \nwithout probation or community control \nin lieu of \nimprisonment; and \n(b) \nEpstein shall be sentenced to a term of twelve (12) months of \ncommunity control consecutive to his two terms in county jail \nas described in Term 2(a), supra. \n3. \nThis agreement is contingent upon a Judge of the 15th Judicial Circuit \naccepting and executing the sentence agreed upon between the State \nAttorney's Office and Epstein, the details of which are set forth in this \nagreement. \n4. \nThe terms contained in paragraphs I and 2, supra, do not foreclose \nEpstein and the State Attorney's Office from agreeing to recommend \nany additional charge(s) or any additional term(s) of probation and/or \nincarceration. \n5. \nEpstein shall waive all challenges to the Information filed by the State \nAttorney's Office and shall waive the right to appeal his conviction and \nsentence, except a sentence that exceeds what is set forth in paragraph \n(2), sup-a. \n6. \nEpstein shall provide to the U.S. Attorney's Office copies of all \nPage 3 of 7 \nEFTA00224659\n", "char_count": 1967}, {"efta_number": "EFTA00224636", "page_number": 24, "text_content": "proposed agreements with the State Attorney's Office prior to entering \ninto those agreements. \n7. \nThe United States shall provide Epstein's attorneys with a list of \nindividuals whom it has identified as victims, as defined in 18 U.S.C. \n§ 2255, after Epstein has signed this agreement and been sentenced. \nUpon the execution of this agreement, the United States, in consultation \nwith and subject to the good faith approval of Epstein's counsel, shall \nselect an attorney representative for these persons, who shall be paid for \nby Epstein. Epstein's counsel may contact the identified individuals \nthrough that representative. \n8. \nIf any of the individuals referred to in paragraph (7), supra, elects to \nfile suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the \njurisdiction of the United States District Court for the Southern District \nof Florida over his person and/or the subject matter, and Epstein waives \nhis right to contest liability and also waives his right to contest damages \nup to an amount as agreed to between the identified individual and \nEpstein, so long as the identified individual elects to proceed \nexclusively under 18 U.S.C. § 2255, and agrees to waive any other \nclaim for damages, whether pursuant to state, federal, or common law. \nNotwithstanding this waiver, as to those individuals whose names \nappear on the list provided by the United States, Epstein's signature on \nthis agreement, his waivers and failures to contest liability and such \ndamages in any suit arc not to be construed as an admission of any \ncriminal or civil liability. \n9. \nEpstein's signature on this agreement also is not to be construed as an \nadmission of civil or criminal liability or a waiver of any jurisdictional \nor other defense as to any person whose name does not appear on the \nlist provided by the United States. \n10. \nExcept as to those individuals who elect to proceed exclusively under \n18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's \nsi\n... [truncated, 2419 chars — for the full page use /api/corpus/document/EFTA00224636/24 or ?id=EFTA00224636&page=24]", "char_count": 2419}, {"efta_number": "EFTA00224636", "page_number": 25, "text_content": "sentenced not later than October 26, 2007. The United States has no \nobjection to Epstein self-reporting to begin serving his sentence not \nlater than January 4, 2008. \n12. \nEpstein agrees that he will not be afforded any benefits with respect to \ngain time, other than the rights, opportunities, and benefits as any other \ninmate, including but not limited to, eligibility for gain time credit \nbased on standard rules and regulations that apply in the State of \nFlorida. At the United States' request, Epstein agrees to provide an \naccounting of the gain time he earned during his period of \nincarceration. \n13. \nThe parties anticipate that this agreement will not be made part of any \npublic record. If the United States receives a Freedom of Information \nAct request or any compulsory process commanding the disclosure of \nthe agreement, it will provide notice to Epstein before making that \ndisclosure. \nEpstein understands that the United States Attorney has no authority to require the \nState Attorney's Office to abide by any terms of this agreement. Epstein understands that \nit is his obligation to undertake discussions with the State Attorney's Office and to use his \nbest efforts to ensure compliance with these procedures, which compliance will be necessary \nto satisfy the United States' interest. Epstein also understands that it is his obligation to use \nhis best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding \nrecommendation regarding the sentence to be imposed, and understands that the failure to \ndo so will be a breach of the agreement. \nIn consideration of Epstein's agreement to plead guilty and to provide compensation \nin the manner described above, if Epstein successfully fulfills all of the terms and conditions \nof this agreement, the United States also agrees that it will not institute any criminal c \nes \na ainst an \ntential co-cons irators of E \n' \nding but not limited to \nor \n. Further, upon execution of this \nagreement an\n... [truncated, 2793 chars — for the full page use /api/corpus/document/EFTA00224636/25 or ?id=EFTA00224636&page=25]", "char_count": 2793}, {"efta_number": "EFTA00224636", "page_number": 26, "text_content": "By signing this agreement, Epstein asserts and certifies that each of these terms is \nmaterial to this agreement and is supported by independent consideration and that a breach \nof any one of these conditions allows the United States to elect to terminate the agreement \nand to investigate and prosecute Epstein and any other individual or entity for any and all \nfederal offenses. \nBy signing this agreement, Epstein asserts and certifies that he is aware of the fact that \nthe Sixth Amendment to the Constitution of the United States provides that in all criminal \nprosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further \nis aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court \nmay dismiss an indictment, information, or complaint for unnecessary delay in presenting \na charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein \nhereby requests that the United States Attorney for the Southern District of Florida defer such \nprosecution. Epstein agrees and consents that any delay from the date of this Agreement to \nthe date of initiation of prosecution, as provided for in the terms expressed herein, shall be \ndeemed to be a necessary delay at his own request, and he hereby waives any defense to such \nprosecution on the ground that such delay operated to deny him rights under Rule 48(b) of \nthe Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the \nUnited States to a speedy trial or to bar the prosecution by reason of the running of the statute \nof limitations for a period of months equal to the period between the signing of this \nagreement and the breach of this agreement as to those offenses that were the subject of the \ngrand jury's investigation. Epstein further asserts and certifies that he understands that the \nFifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all \nfelonies must be charged in an \n... [truncated, 2406 chars — for the full page use /api/corpus/document/EFTA00224636/26 or ?id=EFTA00224636&page=26]", "char_count": 2406}, {"efta_number": "EFTA00224636", "page_number": 27, "text_content": "By signing this agreement, Epstein asserts and certifies that the above has been read \nand explained to him. Epstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nIL ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \n \nBy: \nDated:  ild9-\nDated: \nDated: \nASSISTANT U.S. ATTORNEY \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nLILLY ANN SANCHI3Z, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nPage 7 of 7 \nlb\nEFTA00224663\n", "char_count": 485}, {"efta_number": "EFTA00224636", "page_number": 28, "text_content": "By signing this agreement, Epstein asserts and certifies that the above has been read \nand explained to him. Epstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \n \nBy: \nASSISTANT U.S. ATTORNEY \nDated: \nDated:  71 2-4f/ 07 \nDated: \nJEFFREY EPSTEIN \nRfLt) \nFCS\nA-h/C* \nUNSEL TO JEFF \nY EPSTEIN \nLILLY ANN SANCHEZ, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nPage 7 of 7 \nEFTA00224664\n", "char_count": 499}, {"efta_number": "EFTA00224636", "page_number": 29, "text_content": "By signing this agreement, Epstein asserts and certifies that the above has been read \nand explained to hint. Epstein hereby states that he understands the conditions of this Non-\nProsecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated: \n \nBy: \nASSISTANT U.S. ATTORNEY \nDated: \nJEFFREY EPSTEIN \nDated: \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nDated:q:\n'-\nESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nPage 7 of 7 \nEFTA00224665\n", "char_count": 478}, {"efta_number": "EFTA00224636", "page_number": 30, "text_content": "IN RE: \nINVESTIGATION OF \nJEFFREY EPSTEIN \nADDENDUM TO THE NON-PROSECUTION AGREEMENT \nIT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 \nof the Non-Prosecution Agreement (hereinafter \"paragraph 7\"), that agreement is modified as \nfollows: \n7A. \nThe United States has the right to assign to an independent third-party the responsibility \nfor consulting with and, subject to the good faith approval of Epstein's counsel, selecting \nthe attorney representative for the individuals identified under the Agreement. If the \nUnited States elects to assign this responsibility to an independent third-party, both the \nUnited States and Epstein retain the right to make good faith objections to the attorney \nrepresentative suggested by the independent third-party prior to the final designation of \nthe attorney representative. \n7B. \nThe parties will jointly prepare a short written submission to the Independent third-party \nregarding the role of the attorney representative and regarding Epstein's Agreement to \npay such attorney representative his or her regular customary hourly rate for representing \nsuch victims subject to the provisions of paragraph C, infra. \n7C. \nPursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney \nrepresentative selected by the independent third party. This provision, however, shall not \nobligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, \nif after consideration of potential settlements, an attorney representative elects to file a \ncontested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested \nremedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney \nrepresentative, as opposed to any statutory or other obligations to pay reasonable \nattorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney \nrepresentative, shall cease. \nEFTA00224666\n", "char_count": 1967}, {"efta_number": "EFTA00224636", "page_number": 31, "text_content": "Ey signing this Addendum, Epstein asserts and certifies that the abovo has been read and \nexplained to him. Epstein hereby, states that he understands the clarifications to the Non-\nProsecution Agreement and agrees to comply with them. \nIL ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated:  /040 /07 \nDated:  /IV \nr ig —\nDated: \nDated: \nMOJA' \nBy: \nA9 9 A \n.S. A \nY \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nLILLY ANN SANCHEZ, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nEFTA00224667\n", "char_count": 485}, {"efta_number": "EFTA00224636", "page_number": 32, "text_content": "By signing this Addendum, Epstein asserts and certifies that the above has been read and \nexplained to him. Epstein hereby states that he understands the clarifications to the Non-\nProsecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nDated:  it 007 \nBy: \nDated: \nDated: \nASSISTANT U.S. ATTORNEY \nJEFFREY EPSTEIN \nRALD LEFCO \nESQ. \nCOUNSEL TO JEFF \nY EPSTEIN \nLILLY ANN SANCHEZ, ESQ. \nATTORNEY FOR JEFFREY EPSTEIN \nEFTA00224668\n", "char_count": 474}, {"efta_number": "EFTA00224636", "page_number": 33, "text_content": "By signing this Addendum, Epstein asserts and certifies that the above has been read and \nexplained to him. Epstein hereby states that he understands the clarifications to the Non-\nProsecution Agreement and agrees to comply with them. \nR. ALEXANDER ACOSTA \nST L \nATTO \nY \nDated:  /D \n0/0 \nBy: \n14 ASSISTANT U.S. ATTORNEY \nDated: \nDated: \nDated: if:k_2\n(73--\nf4L4W \nJEFFREY EPSTEIN \nGERALD LEFCOURT, ESQ. \nCOUNSEL TO JEFFREY EPSTEIN \nLILLY A \nANCHEZ, ES \nATTORNEY FOR JEFFREY EPSTEIN \nEFTA00224669\n", "char_count": 497}, {"efta_number": "EFTA00224636", "page_number": 34, "text_content": "U.S. Department of Justice \nUnited States Attorney \nSouthern District of Florida \nIt ALEXANDER ACOSTA \nUNITED STAVES ATTORNEY \nDELIVERY BY FACSIMILE \nLilly Ann Sanchez \nFowler White Burnett, PA \n1395 Brickell Ave, le Floor \nMiami, FL 33131 \nRe: \nJeffrey Epstein \nDear Ms. Sanchez: \n99 N E I Street \nMontt FL 11111 \n- Telephone \n• Facsantk \nDecember 19, 2007 \nI write to follow up on the December 146 meeting between defense counsel and the Epstein \nprosecutors, as well as our First Assistant, the Miami FBI Special Agent in Charge and myself I I \nwrite to you because I am not certain who among the defense team is the appropriate recipient of this \nletter. I address issues raised by several members of the defense team, and would thus ask that you \nplease provide a copy of this letter to all appropriate defense team members. \nFirst, I would like to address the Section 2255 issue.2 As I stated in my December e letter, \nmy understanding is that the Non-Prosecution Agreement entered into between this Office and Mr. \nEpstein responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal \nliability. Under this Agreement, this District has agreed to defer prosecution for enumerated sections \nOver the past two weeks, we have received several hundred pages of arguments and exhibits from defense counsel. \nThis is not the forum to respond to the several items raised, and our silence should not be interpret as agreement; I \nwould, however, like to address one issue. Your December I r h letter states that as a result of defense counsel \nobjections to the appointment process, the USAO proposed an addendum to the Agreement to provide for the use of \nan independent third party selector. As I recall this matter, before I had any knowledge of defense counsel \nobjections, I sua sponte proposed the Addendum to Mr. LeOcowitz at an October meeting in Paint Beach. I did this \nin an attempt to avoid what I foresaw would likely be a litigious selection process. It\n... [truncated, 2491 chars — for the full page use /api/corpus/document/EFTA00224636/34 or ?id=EFTA00224636&page=34]", "char_count": 2491}, {"efta_number": "EFTA00224636", "page_number": 35, "text_content": "of Title 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies \nthree general federal interests: (1) that Mr. Epstein plead guilty to a \"registerablc\" state offense; (2) \nthat this state plea include a binding recommendation for a sufficient term of imprisonment; and (3) \nthat the Agreement not harm the interests of his victims. \nWith this in mind, I have considered defense counsel arguments regarding the Section 2255 \nportions of the Agreement. As I previously observed, our intent has been to place the victims in the \nsame position as they would have been had Mr. Epstein been convicted at trial. No more; no less. \nFrom our meeting, it appears that the defense agrees that this was the intent. During the course of \nnegotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously, \nappear far from simple to understand. I would thus propose that we solve our disagreements over \ninterpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7 \nand 8 with the following language: \n\"Any person, who while a minor, was a victim of a violation of an offense enumerated in \nTitle 18, United States Code, Section 2255, will have the same rights to proceed under \nSection 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an \nenumerated offense. For purposes of implementing this paragraph, the United States shall \nprovide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an \nIndictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority \ninterpreting this provision, including any authority determining which evidentiary burdens if \nany a plaintiff must meet, shall consider that it is the intent of the parties to place these \nidentified victims in the same position as they would have been had Mr. Epstein been \nconvicted at trial. No more; no less.\" \nSecond, I would like to address the issue of \n... [truncated, 3438 chars — for the full page use /api/corpus/document/EFTA00224636/35 or ?id=EFTA00224636&page=35]", "char_count": 3438}, {"efta_number": "EFTA00224636", "page_number": 36, "text_content": "Finally, I would like to address a more general point. Our Agreement was first signed on \nSeptember 24th, 2007. Pursuant to paragraph 11, Mr. Epstein was to use his best efforts to enter his \nguilty plea and be sentenced no later than October 26, 2007. As outlined in correspondence between \nour prosecutors and defense counsel, this deadline came and went. Our prosecutors reiterated to \ndefense counsel several limes their concerns regarding delays, and in fact, asked me several weeks \nago to declare the Agreement in breach because of those delays. 1 resisted that invitation. 1 share \nthis fact because it is background to my frustration with what appears to be an 11'\" hour appeal, \nweeks before the now scheduled January 4'h plea date. \nThis said, the issues raised are important and must be fully vetted irrespective of timeliness \nconcerns. We hope to preserve the January 4ih date. I understand that defense counsel shares our \ndesire not to move that appearance and will work with our office to expedite this process over the \nnext several days. With this in mind, and in the event that defense counsel may wish to seek review \nof our determinations in Washington D.C., I spoke this past Monday with the Assistant Attorney \nGeneral Fisher, to inform her of a possible appeal, to ask her to grant the potential request for review, \nand to in fact review this case in an expedited manner to attempt to preserve the January 46 plea date. \nI want to again reiterate that it is not the intention of this Office ever to force the hand of a \ndefendant to enter into an agreement against his wishes. Your client has the right to proceed to trial, \nand he should do so if he believes that he did not commit the elements of the charged offense. \nI will respond to the pending issues shortly. In the interim, I would ask that you \ncommunicate your position with respect to the sections 2255 and 3371 issues as quickly as possible. \nSincerely, \nR. ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \ncc: \nAlice \n... [truncated, 2089 chars — for the full page use /api/corpus/document/EFTA00224636/36 or ?id=EFTA00224636&page=36]", "char_count": 2089}, {"efta_number": "EFTA00224636", "page_number": 37, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCase No: \n18 U.S.C. § 371 \n18 U.S.C. § 1591(aX1) \n18 U.S.C. § 1591(aX2) \n18 U.S.C. § 2422(6) \n18 U.S.C. § 2423(e) \n18 U.S.C. § 2423(d) \n18 U.S.C. § 2423(6) \nUNITED STATES &AMERICA \nvs. \nJEFFREY EPSTEIN, \nand \nDefendants. \nA \nINDICTMENT \nThe Grand Jury charges that: \nBACKGROUND\nAt all times relevant to this Indictment: \n1. \nDefendant JEFFREY EPSTEIN employed defendants \nanda \nand \namong other things, services as personal assistants. \nto perform, \nEFTA00224673\n", "char_count": 523}, {"efta_number": "EFTA00224636", "page_number": 38, "text_content": "UNITED STATES DISTRICT COURT \nSOUTHERN DISTRICT OF FLORIDA \nCase No: \n18 U.S.C. § 371 \n18 U.S.C. § 1591(a)(1) \n18 U.S.C. § 1591(a)(2) \n18 U.S.C. § 2422(b) \n18 U.S.C. § 2423(e) \n18 U.S.C. § 2423(d) \n18 U.S.C. § 2423(b) \nUNWED STATES CRAMERICA \nvs. \nJEFFREY EPSTEIN, \ndt\nMr,\" \nand \nDefendants. \nA \nINDICTMENT \nThe Grand Jury charges that: \nBACKGROUND \nAt all times relevant to this Indictment: \nI. \nDefendant JEFFREY EPSTEIN employed defendants \naikia ‘O' \nand \nto perform, \namong other things, services as personal assistants. \nEFTA00224674\n", "char_count": 540}, {"efta_number": "EFTA00224636", "page_number": 39, "text_content": "2. \nDefendant JEFFREY EPSTEIN. employed L.G. to perform, among other \nthings, services as a personal assistant. \nDefendants JEFFREY EPSTEIN and \nand \nIII. to perform, among other things, recruiting services. \n4. \nDefendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, \nPalm Beach, Florida, in the Southern District of Florida (hereinafter referred to as \"358 El \nBrillo Way\"). \n5. \nDefendant JEFFREY EPSTEIN owned a property located at 9 East 71st Street, \nNew York, New York (hereinafter referred to as \"the New York residence\"). \n6. \nDefendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a \nDelaware corporation. JEGE, INC.'s sole business activities related to the operation and \nownership of a Boeing 727-31 aircrift,bearing tail number N908JE. \n7. \nDefendant JEFFREY EPSTEIN served as president, sole director, and sole \nshareholder of JEGE, INC., and had the power to direct all of its operations. \n8. \nDefendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., \na Delaware corporation. Hyperion Air, Inc.'s sole business activities related to the operation \nand ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE. \n9. \nDefendant JEFFREY EPSTEIN served as president, sole director, and sole \nshareholder of Hyperion Air, Inc., and had the power to direct all of its operations. \nEFTA00224675\n", "char_count": 1360}, {"efta_number": "EFTA00224636", "page_number": 40, "text_content": "10. \nPursuant to Florida Statutes Section 794.05, a \"person 24 years of age or older \nwho engages in sexual activity with a person 16 or 17 years of age commits a felony of the \nsecond clegipe.\" For purposes of \"this section, `sexual activity' means oral, anal, or vaginal \npenetration by, or union with, the sexual organ of another; however, sexual activity does not \ninclude an act done for a bona fide medical purpose.\" Florida Statutes Section 794.021 states \nthat \"ignorance of the age [of the victim] is no defense,\" and that neither \"misrepresentation \nof age by [the victim] nor a bona fide belief that such person is over the specified age [shall] \nbe a defense.\" \n11. \nPursuant to Florida Statutes Sections 800.04(5Xa) and 800.04(5)(cX2), an adult \n\"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, \nor buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or \nentices a person under 16 years of ageta so touch the perpetrator, commits lewd or lascivious \nmolestation,\" which is a felony of the second degree if the victim is 12 years of age or older \nbut less than 16 years of age. \n12. \nPursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6Xb), an adult \n\"who [iintentionally touches a person under 16 y rA of age in a lewd or lascivious manner \nor [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd \nor lascivious conduct,\" which is a felony of the second degree. \n3 \nrr \nEFTA00224676\n", "char_count": 1528}, {"efta_number": "EFTA00224636", "page_number": 41, "text_content": "13. \nPursuant to Florida Statutes Sections 800.04(7)(a) and 80Q.04(7Xc), an adult \n\"who: (1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or \n. \n• \nlascivious Manner; or (3) [i]ntentionally commits any other sexual act that does not involve \nactual physical or sexual contact with the victim, including, but not limited to . . . the \nsimulation of any act involving sexual activity in the presence of a victim who is less than \n16 years of age, commits lewd or lascivious exhibition,\" which is a felony of the second \ndegree. \n14. \nPursuant to Florida Statutes Section 800.04(2), \"[n]either the victim's lack of \nchastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04].\" \n15. \nPursuant to Florida Statutes Section 800.04(3), \"[t]he perpetrator's ignorance \nof the victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona \nfide belief of the victim's age cannolbe raised as a defense in a prosecution under [Section \n800.04].\" \n16. \nPursuant to Florida Statutes Section 800.02, a \"person who commits any \nunnatural and lascivious act with another person commits a misdemeanor of the second \ndegree.\" \n- • \n17. \nDefendant JEFFREY EPSTEIN was\n the age of 24 and did not have any \nmedical license. \n4 \nEFTA00224677\n", "char_count": 1315}, {"efta_number": "EFTA00224636", "page_number": 42, "text_content": "18. \nDuring the period of her involvement with the Defendants, Jane Doe #4 \nattended =MINIM \nand =SEIM= \nin Palm Beach \nCounty... \n19. \nDuring the period of her involvement with the Defendants, Jane Doe #5 \nattended \nin Palm Beach County. \n20. \nDuring the period of their involvement with the Defendants, Jane Does # 6, 8 \nand 12 attended \nin Palm Beach County. \n21. \nDuring the period of her involvement with the Defendants, Jane Doe #7 \nattended \nin Palm Beach County. \n22. \nDuring the periods of their involvement with the Defendants, Jane Does # 9, \n14, 15, 16, 17, 18, and 19 attended \nin Palm Beach County. \n23. \nDuring the period of \ninvolvement with the Defendants, Jane Doe #10 \nattended \nin Palm Beach County. \n24. \nDuring the period of her involvement with the Defendants, Jane Doe #11 \nattended the \nMI \na public high school, located in New \nYork, New York. \n25. \nDuring the period of her involvement with the Defendants, Jane Doe #I3 \nattended \nin Palm Beach County. \n5 \nEFTA00224678\n", "char_count": 997}, {"efta_number": "EFTA00224636", "page_number": 43, "text_content": "COUNT 1 \n(Conspiracy: 18 U.S.C. § 371) \n26.. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n27. \nFrom at least as early as 2001, the exact date being unknown to the Grand Jury, \nthrough in or around October 2005, in Palm Beach County, in the Southern District of \nFlorida, and elsewhere, the Defendants, \nJEFFREY EPSTEIN, \na/k/a \nand \ndid knowingly and willfully combine, conspire, confederate and agree with each other and \nwith others known and unknown to cmmit an offense against the United States, that is, to \n\".; \nuse a facility or means of interstate litiitign commerce to knowingly persuade, induce, and \nentice individuals who had not attained the age of 18 years to engage in prostitution, in \nviolation of Title 18, United States Code, Section 2422(b). \nPuipose and Object of the Conspiracy \n28. \nIt was the purpose and object of thrc;nspiracy to procure females under the \nage of 18 to travel to 358 El Brillo Way and the New York residence so that JEFFREY \nEPSTEIN could, in exchange for money, engage in lewd conduct with those minor females \nin order to satisfy JEFFREY EPSTEIN's prurient interests. \n6 \nEFTA00224679\n", "char_count": 1210}, {"efta_number": "EFTA00224636", "page_number": 44, "text_content": "Manner and Means \n29. \nThe manner and means by which the Defendants and other participants sought \nto accokkh the purpose and object of the conspiracy included the following: \n(a) \nIt was part of the conspiracy that Defendants \na/k/a \" \nft \nand other \nparticipants would contact minor females via the use of cellular and other telephones to \narrange appointments for minor females to travel to 358 El Brillo Way and the New York \nresidence to allow DePeridant JEFFREY EPSTEIN to engage in lewd conduct with them. \n(b) \nIt was further. a part of the conspiracy that Defendants JEFFREY \nEPSTEIN, \nand \na/k/a \" \nand other participants would make payments to, or cause payments to be \nmade to, minor females in exchangAr engaging in lewd conduct. \nEPSTEIN, \n(c) \nIt was further a part of the conspiracy that Defendants JEFFREY \na/k/a \n\" and other \nparticipants would ask females to recruit other minor females to engage in lewd conduct with \nDefendant JEFFREY EPSTEIN. \n(d) \nIt was further a part of the\n that Defendants JEFFREY \nEPSTEIN, a \na \na/k/a a\" \nand other \nparticipants would make payments to, or cause payments to be made to, the recruiters for \n7 \nEFTA00224680\n", "char_count": 1168}, {"efta_number": "EFTA00224636", "page_number": 45, "text_content": "bringing additional minor females to 358 El Brillo Way and the New York residence to \nengage in lewd conduct with Defendant JEFFREY EPSTEIN. \n(e) \nIt was further a part of the conspiracy that Defendant JEFFREY \nEPSTEIN would pay minor females to engage in lewd conduct with Defendant \nto satisfy Defendant JEFFREY EPSTEIN's prurient interests. \nOvert Acts \n30. \nIn furtherance of this conspiracy and to effect the objects thereof, there was \ncommitted by at leastjent of the co-conspirators herein, at least one of the following overt \nacts, among others, in the Southern District of Florida, and elsewhere: \nJane Does #1 and #2 \n(1) \nIn or around the beginning of 2001, Defendant JEFFREY EPSTEIN \nengaged in sexual activity wi \nane Doe #1, who was then a seventeen-year-old girl, \nin the presence of Jane Doe #2, who was then a fourteen-year-old girl. \n(2) \nIn or around 2001, Defendant \nled Jane Doe #2 from the \nkitchen of 358 El Brill° Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 \nEl Brillo Way. \n(3) \nIn or around 2001, DefendantieFFREY EPSTEIN masturbated in the \npresence of Jane Doe #2, who was then a fourteen-year-old girl. \n(4) \nIn or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, \nwho was then fourteen years' old, to pinch his nipples while he masturbated. \n8 \nEFTA00224681\n", "char_count": 1314}, {"efta_number": "EFTA00224636", "page_number": 46, "text_content": "(5) \nIn or around 2001, Defendant JEFFREY EPSTEIN made a payment of \n$300 to Jane Doe #2. \n-r \n(6) \nIn or around 2001, DefendanMIIM \nplaced a telephone call \nto a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel \nto 358 El Brillo Way. \n(7) \nIn or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse \nwith an unidentiked female in the presence of Jane Doe #2, who was then a fourteen-\nyear-old girl. i\n• \n(8) \nIn or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane \nDoe #2, who was then a fourteen-year-old girl, for allowing an unidentified female \nto perform oral sex on Jane Doe #2 in EPSTEIN's presence. \n(9) \nOn, or about H \nh 11, 2003, an employee of Defendant JEFFREY \nEPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's \nreview regarding a telephone call received from Jane Doe #2. \n(10) \nIn or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 \nif she had any younger. friends who wo \nactivities with him. \n(11) In or around 2003, Defendant \nbe interested in engaging in similar \nof Jane Doe #2, who was then a sixteen-year-old girl. \n9 \ntook nude photographs \nEFTA00224682\n", "char_count": 1159}, {"efta_number": "EFTA00224636", "page_number": 47, "text_content": "(12) \nIn or around 2003, Defendant MINIMIEmade a payment of \n$500 to Jane Doe #2 in exchange for posing for nude photographs. \n(13) In or around 2003, Defendant allMeold \nJane Doe #2 that \nDefendant JEFFREY EPSTEIN had asked ao \ntake nude photographs of Jane \nDoe #2. \n(14) \nIn or around 2003, Defendant JEFFREY EPSTEIN masturbated in the \npresence of JaneDoe #2, who was then a sixteen-year-old girl. \n• \n(15) \nIn of around 2003, Defendant JEFFREY EPSTEIN made a payment of \n$200 to Jane Doe #2, who was then a sixteen-year-old girl. \n(16) \nIn or around 2003, Defendant IMIIIMIIplaced a telephone call \nto a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel \nto 358 El Brillo Way. \nI \n(17) On or about April 23, 2004, Defendant \nI \nplaced a \ntelephone call to a telephone used by Jane Doe #2. \n(18) On or about May 2, 2004, Defendant \nplaced a \ntelephone call to a telephone used by Jane pcie #2. \nJane Doe -43 \n(19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the \npresence of Jane Doe #3, who was then a fifteen-year-old girl. \n10 \nEFTA00224683\n", "char_count": 1093}, {"efta_number": "EFTA00224636", "page_number": 48, "text_content": "(20) \nIn or around 2003, Defendant JEFFREY EPSTEIN made .a payment of \n$200 to Jane Doe #3. \n(21) On or about October 26, 2004, DefendantIMIIIMII placed a \ntelephone call to a telephone used by Jane Doe #3. \n(22) On or about October 30, 2004, DefendantMIMS \nplaced a \ntelephone call to a telephone used by Jane Doe #3. \n(23) \nIlkor around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe \n'4, \n#3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and \nto touch the adult female's breasts. \n(24) \nIn or around 2004, Defendant JEFFREY EPSTEIN placed a massaging \ndevice on the vagina of an adult female in the presence of Jane Doe #3, who was then \na sixteen- or seventeen-year-ek girl. \n(25) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of \n$200 to Jane Doe #3. \n(26) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe \n#3 to rub his nipples. \n(27) \nIn or around 2004, DefendanttJEFFREY EPSTEIN placed a massaging \ndevice on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old \ngirl. \n11 \nEFTA00224684\n", "char_count": 1083}, {"efta_number": "EFTA00224636", "page_number": 49, "text_content": "(28) \nIn or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 \nto recruit additional females to come to 358 El Brillo Way. \n; (29) On or about November 8, 2004, one of Defendant JEFFREY \nEPSTEIN's employees prepared a written telephone message for Defendant \nJEFFREY EPSTEIN's review regarding a telephone call received from Jane Doe #3 \nthat read: \"I have a female for him.\" \n(30) \nQn„or about January 14, 2005, Defendant \ntelephone call to if telephone used by Jane Doe #3. \nplaced a \n(31) \nOn or about January 29, 2005, one of Defendant JEFFREY EPSTEIN's \nemployees prepared a written telephone message for Defendant JEFFREY \nEPSTEIN's review regarding a telephone call received from Jane Doe #3 that read: \n\"I have a female for him.\" p \n• \nX \nJane Does #4, #5, and #6 \n(32) \nIn or around the first half of 2004, Defendant \nled \nJane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN's bedroom at 358 El \nBrillo Way. \n(33) \nIn or around the first half df 2004, Defendant JEFFREY EPSTEIN \nasked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. \n12 \nEFTA00224685\n", "char_count": 1096}, {"efta_number": "EFTA00224636", "page_number": 50, "text_content": "(34) \nIn or around the first half of 2004, Defendant JEFFREY EPSTEIN \nmasturbated in the presence of Jane Doe #4, who was then a seventeen-year-old-girl, \nd Jane Doe #5, who was then a seventeen-year-old girl. \n(35) \nIn or around the first half of 2004, Defendant JEFFREY EPSTEIN \ninstructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his \nnipples. \n(36) \nIn,or around the first half of 2004, Defendant JEFFREY EPSTEIN \ninstructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her \nclothing. \n(37) \nIn or around the first half of 2004, Defendant JEFFREY EPSTEIN \nstroked the vagina of Jane Doe #4, who was then a seventeen-year-old girl. \n(38) \nIn or around the4st half of 2004, Defendant JEFFREY EPSTEIN paid \n$200 to Jane Doe #4. \n(39) \nIn or around the first hal f of 2004, Defendant JEFFREY EPSTEIN paid \n$200 to Jane Doe #5. \n(40) \nIn or around the fust half oppoit, Defendant JEFFREY EPSTEIN \nasked Jane Doe #6 what high school she attended. \n(41) \nIn or around the first half of 2004, Defendant JEFFREY EPSTEIN \ninstructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone. \n13 \nEFTA00224686\n", "char_count": 1154}, {"efta_number": "EFTA00224636", "page_number": 51, "text_content": "(42) \nIn or around the first half of 2004, Defendant JEFFREY EPSTEIN \nmasturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl. \nfi (43) \nIn or around the first half of 2004, Defendant JEFFREY EPSTEIN \ndigitally penetrated Jane Doe #6, who was then a sixteen-year-old girl. \n(44) \nIn or around the first half of 2004, Defendant JEFFREY EPSTEIN \nplaced a large vibrating massager on the vagina of Jane Doe #6, who was then a \nsixteen-year-old. irl. \n(45) \nII \nr around the first half of 2004, Defendant JEFFREY EPSTEIN \ncaused a payment of $200 to be paid to Jane Doe #6. \nJane Does #7 and #8 \n(46) \nIn or around July 2004, Defendant JEFFREY EPSTEIN ledM., who \nwas then a fifteen-year-old gjk.and Jane Doe #7, who was then a sixteen-years-old \ngirl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY \nEPSTEIN's bedroom at 358 El Brillo Way. \n(47) On or about July 4, 2004, Defendant \nmade one pr \nmore telephone calls to a telephone used by Jane Doe #7. \n(48) \nOn or about July 5, 2004, Defendant \nplaced a \ntelephone call to a telephone used by NI. \n4-\n14 \nEFTA00224687\n", "char_count": 1113}, {"efta_number": "EFTA00224636", "page_number": 52, "text_content": "(49) \nIn or around July 2004, Defendant JEFFREY EPSTEIN masturbated in \nthe presence of Jane Doe #8, who was then a seventeen-year-old girl. \n(50) \nIn or around July 2004, Defendant JEFFREY EPSTEIN stroked the \nvagina of Jane Doe #8, who was then a seventeen-year-old girl. \n(51) \nIn or around July 2004, Defendant JEFFREY EPSTEIN paid \napproximately $200 to Jane Doe #8. \n(52) 1p-9r around July 2004, Defendant JEFFREY EPSTEIN paid $200 to \nfor recruiting Jane Doe #8 to travel to 358 El Brillo Way. \n(53) \nIn or around July 2004, Defendant \ntold Jane Doe #8 \nthat Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a \nfriend. \n(54) \nOn or about Jul IS, 2004, Defendant-\nmore telephone calls to a telephone used by Jane Doe #7. \n(55) On or about July 15, 2004, Defendant \ntelephone call to a telephone used by Jane Doe #8. \n(56) \nOn or about July 15, 2004,-pefendant \ntelephone call to a telephone used by mmt\n(57) \nOn or about July 16, 2004, Defendant \nmore telephone calls to a telephone used by Jane Doe #7. \n15 \nplaced one or \n■ \nplaced a \n■ \nplaced a \nplaced one or \nEFTA00224688\n", "char_count": 1104}, {"efta_number": "EFTA00224636", "page_number": 53, "text_content": "(58) On or about July 16, 2004, Defendant \nMB \nplaced a \ntelephone call to a telephone used bye. \n(59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN's \nemployees prepared a written telephone message for Defendant JEFFREY \nEPSTEIN's review regarding a telephone call received fromin. that read: \"Me & \n[Jane Doe #7] can come tomorrow any time or a.] \nalone\". \n(60) Ip or around July 2004, Defendant JEFFREY EPSTEIN masturbated in \nthe presence ()bane Doe #7, who was then a sixteen-year-old girl. \n(61) \nIn or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane \nDoe #7, who was then a sixteen-year-old girl, to rub his nipples. \n(62) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the \nvagina of Jane Doe #7, who v‘iis then a sixteen-year-old girl. \n(63) \nIn or around July 2004, Defendant JEFFREY EPSTEIN made a \npayment of $200 to Jane Doe #7. \n(64) \nIn or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe \n#7 that if she reported to anyone what•Mad occurred at Defendant JEFFREY \nEPSTEIN's home, bad things could happeti to her. \n(65) On or about July 24, 2004, Defendant \nplaced a \ntelephone call to a telephone used by Jane Doe #8. \n16 \nEFTA00224689\n", "char_count": 1197}, {"efta_number": "EFTA00224636", "page_number": 54, "text_content": "Jane Does #9 and #10 \n(66) On or about July 15, 2004, DefendantIMEMS placed one or \nniorii telephone calls to a telephone used by Jane Doe #9. \n(67) On or about July 16, 2004, Defendan \ncaused Jane \nDoe #9 to make one or more telephone calls to a telephone used by Jane Doe #10. \n(68) On or about July 17, 2004, Defendant \ntelephone call to.a telephone used by Jane Doe #9. \n(69) On or about July 18, 2004, Defendant \ntelephone call to a telephone used by Jane Doe #9. \n(70) On or about July 22, 2004, Defendant \ntelephone call to a telephone used by Jane Doe #9. \n(71) In or around J \n2004, Defendant JEFFREY EPSTEIN fondled the \nbreasts of Jane Doe #9, who was then a seventeen-year-old girl. \n(72) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in \nthe presence of Jane Doe #9, who was then a seventeen-year-old girl. \nME \nplaced a \nMI \nplaced a \nplaced a \n(73) In or around July 2004, D?fendant JEFFREY EPSTEIN made a \npayment of $200 to Jane Doe #9. \n(74) On or about July 22, 2004, Defendant \nplaced a \ntelephone call to a telephone used by Jane Doe #10. \nr\n17 \nEFTA00224690\n", "char_count": 1096}, {"efta_number": "EFTA00224636", "page_number": 55, "text_content": "(75) \nIn or around the last half of 2004, Defendants JEFFREY EPSTEIN and \nengaged in oral sex and sexual intercourse in the presence \nJime Doe #9, who was then a seventeen-year-old girl. \n(76) \nIn or around the last half of 2004, Defendant JEFFREY EPSTEIN \nforcibly inserted his penis into the vagina of Jane Doe #9, who was then a seventeen-\nyear-old girl. \n(77) \nIpvy around the last hal f of 2004, Defendant JEFFREY EPSTErN made \n16\na payment of S300-to Jane Doe #9. \n(78) \nIn or around the last half of 2004, Defendant JEFFREY EPSTEIN \nrubbed the vagina of Jane Doe #10, who was then a seventeen-year-old girl. \n(79) \nIn or around the last half of 2004, Defendant JEFFREY EPSTEIN made \na payment of $200 to Jane DJvo. \n(80) On or about November 28, 2004, Defendant JEFFREY EPSTEIN \narranged for one of his employees to provide an envelope filled with cash to Jane Doe \n#9. \n(81) On or about December 4, 20 \nPefendan \nprovided \net\n—4 \na written message to Defendant JEFFREY PSTEIN regarding Jane Does # 9 and 10, \nstating: \"[Jane Doe #10] would like to work @ 4:00 pm if possible. [[Jane Doe #9] \nis scheduled for 5:00 today.] the movie is @ 7:30\". \n(82) On or about December 29, 2004, Defendant \nplaced \na telephone call to a telephone used by Jane Doe #9. \n18 \nEFTA00224691\n", "char_count": 1279}, {"efta_number": "EFTA00224636", "page_number": 56, "text_content": "Doe #10. \n(83) \nOn or about December 30, 2004, Defendants JEFFREY EPSTEIN and \ncaused the purchase of Broadway tickets as an eighteenth birthday \nOft for Jane Doe #9. \n(84) \nIn or around the last half of 2004 or January 2005, Defendant JEFFREY \nEPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen-\nyear-old girl. \n(85) btqr around the last half of 2004 or January 2005, Defendant JEFFREY \nr < \nEPSTEIN fondled' the breasts of Jane Doe #10, who was then a seventeen-year-old \ngirl. \n(86) On or about January 14, 2005, Defendant \nplaced one \nor more telephone calls to a telephone used by Jane Doe #10. \n(87) On or about Ji ary 27, 2005, Defendant \n, a/k/a \nplaced one or more telephone calls to a telephone used by Jane \n(88) On or about January 28, 2005, Defendant \nplaced one \nor more telephone calls to a telephone us \nby Jane Doe #10. \na - \n(89) On or about February 1, 2005, Defendant \nplaced one or more telephone calls to a telephone used by Jane Doe #10. \n(90) In or around February 2005, Defendant JEFFREY EPSTEIN caused a \npayment of $200 to be made to Jane Doe #9 for recruiting Jane Doe #I6 to travel to \n358 El Brillo way. \n19 \nEFTA00224692\n", "char_count": 1179}, {"efta_number": "EFTA00224636", "page_number": 57, "text_content": "Jane Doe #11, \n(91) \nIn or around 2004, Defendant JEFFREY EPSTEIN told Jane Doe #11 \ngirt be would pay her to find and bring him more girls. \n(92) \nIn or around 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane \nDoe #11 for recruiting a minor female to travel to his New York home. \n(93) \nIn or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe # 11 \nwhen she wou \ngetting more girls. \n(94)\nn or about April 5, 2005, one of Defendant JEFFREY EPSTEIN's \nemployees prepared a written message for Defendant JEFFREY EPSTEIN's review \nregarding a telephone call received from Jane Doe #11 that read: \"Re does she have \nany new friends you can meet — I was away over the weekend so I have not spoken \nto anyone new. But, [unide \ned Jane Doe] will be around later today and I know \nshe really wants to work. The others should be back around Thursday. Let me know \nabout [unidentified Jane Doe].\" \n(95) On or about June 22, 2005, Defendant \nplaced a \ntelephone call to a telephone used by Jane pcie #11. \nJane Does #12 and #13 \n(96) On or about August 2, 2004, an employee of Defendant JEFFREY \nEPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN's \nreview regarding a telephone call received from II. and Jane Doe #12 that stated: \n\"They are available all weekend and maybe [Jane Doe #1  ] too\". \n20 \nEFTA00224693\n", "char_count": 1334}, {"efta_number": "EFTA00224636", "page_number": 58, "text_content": "(97) On or about August 21, 2004, Defendant I....placed \na \ntelephone call to a telephone used by Jane Doe #13. \na \na) (98) \nIn or around the last half of 2004, Defendant JEFFREY EPSTEIN \nmasturbated in the presence of Jane Doe #12, who was then a seventeen-year-old girl. \n(99) \nIn or around the last half of 2004, Defendant JEFFREY EPSTEIN \ndigitally penetrated Jane Doe #12, who was then a seventeen-year-old girl. \n(100) In-or around the last half of 2004, Defendant JEFFREY EPSTEIN \nattempted to place a massaging device on the vagina of Jane Doe #12, who was then \na seventeen-year-old girl. \n(101) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made \na payment of $200 to Jane Doe #12. \n(102) In or around th0i§t half of 2004, Defendant JEFFREY EPSTEIN asked \nJane Doe #12, who was then a seventeen-year-old girl, about her age. \n(103) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told \nJane Doe #12 that he would take her to Los Angeles when she turned eighteen. \n23\n(104) In or around the last half of . 4, Defendants JEFFREY EPSTEIN and \n4 \n,\ncaused Jane Doe #12 o recruit Jane Doe #13 to travel to 358 El \nBrillo Way. \n(105) In or around the last half of 2004, Defendant JEFFREY EPSTEIN \nmasturbated in the presence of Jane Doe #13, who was then a seventeen-year-old girl. \nfi\n2! \nEFTA00224694\n", "char_count": 1337}, {"efta_number": "EFTA00224636", "page_number": 59, "text_content": "(106) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed \na massaging device on the vagina of Jane Doe #13, who was then a seventeen-year-\nold \n(107) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made \na payment of $200 to Jane Doe #13. \n(108) In or around the last half of 2004, Defendant JEFFREY EPSTEIN \ndigitally penetrttd Jane Doe #13, who was then a seventeen-year-old girl. \n(109) 14around the last hal f of 2004, Defendant JEFFREY EPSTEIN asked \nJane Doe #13, who was then a seventeen-year-old girl, about her age. \n(110) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told \nJane Doe #13 that he wanted to take her to Paris but he could not because Jane Doe \n#13 was not yet eighteen yearsnold. \n(111) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked \nJane Doe #13 to bring her friends to his home, especially \"girls who looked like [Jane \nDoe #13].\" \nJane Doe #44 \n(112) In or around the last half of 2004, Defendant \nled \nJane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY \nEPSTEIN's bedroom at 358 El Brillo Way. \n(113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked \nJane Doe #I4 to provide her telephone number. \n22 \nEFTA00224695\n", "char_count": 1256}, {"efta_number": "EFTA00224636", "page_number": 60, "text_content": "(114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN \ninstructed Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples. \n4* (115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN \nmasturbated in the presence of Jane Doe #14, who was then a seventeen-year old girl. \n(116) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made \na payment of $300 to Jane Doe #14. \n(117) bkpr around the end of 2004 and the beginning of 2005, Defendant \nca \nJEFFREY EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeen-\nyear-old girl. \n(118) In or around the end of 2004 and the beginning of 2005, Defendant \nJEFFREY EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl, \nwhether she had any plans foriAr eighteenth birthday and acknowledged that she had \nnot yet turned eighteen. \n(119) On or about December 23, 2004, Defendant JEFFREY EPSTEIN \ncaused a Western Union wire transfer order to be sent to Jane Doe #14. \n(120) In or around the first quarter of-2005, Defendant JEFFREY EPSTEIN \nplaced a massaging device on the vagina of Jane Doe #14, who was then a seventeen-\nyear-old girl. \n(121) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN \nengaged in sexual intercourse with Jane Doe #14, who was then a seventeen-year-old \ngirl. \n23 \nEFTA00224696\n", "char_count": 1343}, {"efta_number": "EFTA00224636", "page_number": 61, "text_content": "(122) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN \nperformed oral sex on Jane Doe #14, who was then a seventeen-year-old girl. \n(123) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN \nmade a payment of $600 to Jane Doe #14. \n(124) On or about January 8, 2005, Defendant \ntelephone call to a telephone used by Jane Doe #14. \nplaced a \n(125) On or about January 9, 2005, Defendant \na/k/a \n\"Adrian Mucthska,\" placed a telephone call to a telephone used by Jane Doe #14. \n(126) On or about January 26, 2005, one ofDefendant JEFFREY EPSTEIN' s \nemployees prepared a written telephone message for Defendant \nreview regarding a call received from Jane Doe #14 that read: \"She is confirming for \n5:30\". \n.2.- 1 \n(127) On or about January 26, 2005, Defendant \nMI \na/k/a \n\" placed a telephone call to a telephone used by Jane Doe #14. \n(128) On or about February 1, 2005, Defendant \ntelephone call to a telephone used by Jane Doe #14. \n(129) On or about March 1, 2005, Defendant \nplaced a \na/k/a \n\"IIMMIM\" \nplaced a telephone call to a telephone used by Jane Doe #14. \n(130) On or about March 21, 2005, Defendant \na/k/a \n`IIMIIMS\" \nplaced a telephone calls to a telephone used by Jane Doe #14. \nAl \n24 \nEFTA00224697\n", "char_count": 1245}, {"efta_number": "EFTA00224636", "page_number": 62, "text_content": "(131) On or about March 29, 2005, Defendant MINIMIlplaced a \ntelephone call to a telephone used by Jane Doe #I4. \nt \nJane Doe #15 \n4' \n(132) On or about December 6, 2004, Defendant \nplaced \na telephone call to a telephone used by Jane Doe #I5. \n(133) On or about December 14, 2004, Defendant \nplaced \na telephone call to a telephone used by Jane Doe #15. \n(134) In or around the first half of 2005, Defendant \nled \nJane Doe #15 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY \nEPSTEIN's bedroom at 358 El Brillo Way. \n(135) In or around the first half of 2005, Defendant JEFFREY EPSTEIN \ninstructed Jane Doe #15, who was then a seventeen-year-old girl, to pinch his nipples \nwhile he masturbated. \n(136) In or around the first half of 2005, Defendant JEFFREY EPSTEIN \nfondled the breasts of Jane Doe #15. \n(137) In or around the first half of 2005, Defendant JEFFREY EPSTEIN \nmade a payment of $200 to Jane Doe #15.-1\n(138) On or about January 7, 2005, Defendant \nMI \na/k/a \n#15. \nplaced a telephone call to a telephone used by Jane Doe \n25 \nEFTA00224698\n", "char_count": 1075}, {"efta_number": "EFTA00224636", "page_number": 63, "text_content": "(139) On or about February 4, 2005, Defendan \nplaced a \ntelephone call to a telephone used by Jane Doe #15. \n(140) On or about February 10, 2005, Defendan \nplaced \na telephone call to a telephone used by Jane Doe #15. \n(141) On or about February 21, 2005, Defendant \nplaced \na telephone call to a telephone used by Jane Doe #15. \n(142) On or about February 24, 2005, Defendant \nplaced \na telephone calitemi telephone used by Jane Doe #15. \n(143) On or about March 17, 2005, Defendant \nplaced a \ntelephone call to a telephone used by Jane Doe #I5. \n(144) On or about March 30, 2005, Defendant \nplaced a \ntelephone call to a telephone lied by Jane Doe #15. \n(145) On or about March 31, 2005, Defendant \nplaced a \ntelephone call to a telephone used by Jane Doe #15. \n(146) On or about March 31, 2005, Defendant \n, a/k/a \n,\" placed a telephone call to a telephone used by Jane Doe #I5. \n(147) On or about April 1, 2005, °tie of Defendant JEFFREY EPSTEIN's \nemployees prepared a note for Defendant JEFFREY EPSTEIN's review that read: \n\"10:30 [Jane Doe #15]/[Jane Doe #10] on Fri around 2'Oclock\". \n(148) In or around lime 2005, Defendant JEFFREY EPSTEIN provided Jane \nDoe #15 with a gift of \nSecret lingerie for her eighteenth birthday. \n26 \nEFTA00224699\n", "char_count": 1251}, {"efta_number": "EFTA00224636", "page_number": 64, "text_content": "Jane Does #16 & #17 \n(149) In or around February 2005, Defendant JEFFREY EPSTEIN \niiigisturbated in the presence of Jane Doe #16, who was then a seventeen-year-old girl. \n(150) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN \nand \ncaused Jane Doe #16 to place a telephone call to Jane Doe #17 \nto ask her to travel to 358 El Brillo Way. \n(151) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN \ncaused a paymine.to be made to Jane Doe #16 for recruiting Jane Doe #I7 to travel \nto 358 El Brillo Way. \n(152) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN \nmasturbated in the presence of Jane Doe #17, who was then a sixteen-year-old girl. \n(153) In or around the' rst quarter of 2005, Defendant JEFFREY EPSTEIN \ninstructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her \nclothing. \n(154) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN \nplaced a massaging device on the vagina of Jane Doe #17, who was then a sixteen-\nyear-old girl. \n(155) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN \nmade a payment of $200 to Jane Doe 1117, who was then a sixteen-year-old girl. \n27 \nEFTA00224700\n", "char_count": 1201}, {"efta_number": "EFTA00224636", "page_number": 65, "text_content": "(156) In or around the first nine months of 2005, Defendant JEFFREY \nEPSTEIN placed a massaging device on the vagina of Jane Doe #16, who was then \na/seventeen-year-old girl. \n(157) In or around the first nine months of 2005, Defendant JEFFREY \nEPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, how old she \nwas, and she responded that she was seventeen years old. \n(158) In or around the first nine months of 2005, Defendant JEFFREY \nEPSTEIN engetged in sexual activity with Defendant...NM= \nin the \npresence of Jane Doe #16, who was then a seventeen-year-old girl. \n(159) In or around the first nine months of 2005, Defendant JEFFREY \nEPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, to touch the \nbreast of Defendant \n(160) On or about April 11, 2005, Defendant \nME, ailda \n\" placed a telephone call to a telephone used by Jane Doe #I6. \n(161) On or about April 11, 2005, Defendant \ntelephone call to a telephone used by Janep2e #I6. \nEMI \nplaced a \n(162) On or about April 11, 200t, Defendant \nleft a \nmessage for Defendant JEFFREY EPSTEIN stating: \"[Jane Doe #16] can work • \ntomorrow at 4pm.\" \n(163) On or about May 19, 2005, Defendant \nplaced a \nr \n• \ntelephone call to a telephone used by Jane Doe #16. \n28 \nEFTA00224701\n", "char_count": 1266}, {"efta_number": "EFTA00224636", "page_number": 66, "text_content": "Jane Does #18 and #19 \n(182) In or around the last half of 2003, Jane Doe #18 was approached by.. \naturwas asked whether she would be willing to provide a massage to Defendant \nJEFFREY EPSTEIN in exchange for $200. \n(183) In or around the last half of 2003, Defendant JEFFREY EPST)EIN asked \nJane Doe #18 to provide her telephone number. \n(184) On or around August 27, 2003, Defendant \na telephone can tin telephone used by Jane Doe #I8. \nplaced \n(185) In or around the last half of 2003, Defendant JEFFREY EPSTEIN \nmasturbated in the presence of Jane Doe #18, who was then a seventeen-year-old-girl. \n(186) On or around November 16, 2003, Defendant \nplaced \na telephone call to a telephond sed by Jane Doe #18. \n(187) In or around the last half of 2003, Defendant JEFFREY EPSTEIN \ndigitally penetrated Jane Doe #18, who was then a seventeen-year-old-girl. \n(188) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked \nJane Doe #18 to recruit other females to travel to 358 El Brillo Way. \n(189) On or about March 5, 2004, defendant JEFFREY EPSTEIN asked Jane \nDoe #19, who was then a seventeen-year-old girl, to leave when she refused to \nremove her shirt. \n31 \nEFTA00224702\n", "char_count": 1190}, {"efta_number": "EFTA00224636", "page_number": 67, "text_content": "(164) On or about June 30, 2005, Defendant \nMil \nplaced a \ntelephone call to a telephone used by Jane Doe #16. \n(165) On or about July 2, 2005, Defendant_ \nplaced \nplaced a \ntelephone call to a telephone used by Jane Doe #16. \n(166) Oh or about July 22, 2005, Defendant \nplaced a \ntelephone call to a telephone used by Jane Doe #16. \n(167) On or about August 18, 2005, Defendant \nplaced a \ntelephone call to's telephone used by Jane Doe #16. \n(168) On or about August 19, 2005, Defendant \naRcla \n,\" placed a telephone call to a telephone used by Jane Doe #16. \n(169) On or about August 21, 2005, Defendant \nplaced a telephone call to a telephone used by Jane Doe #16. \n(170) On or about September 3, 2005, Defendant \n, a/k/a \n,\" placed a telephone call to a telephone used by Jane Doe #16. \n(171) On or about September 18, 2005, Defendant \nplaced \na telephone call to a telephone used by Jane Doe #16. \n141\n(172) On or about September 19, 2005, Defendant \nsent a \ntext message to a telephone used by Jane Doe #16. \n(173) On or about September 29, 2005, Defendant \na telephone call to a telephone used by Jane Doe #16. \n29 \nplaced \nEFTA00224703\n", "char_count": 1144}, {"efta_number": "EFTA00224636", "page_number": 68, "text_content": "(174) On or about September 30, 2005, Defendant \na/k/a \nplaced a telephone call to a telephone used by Jane Doe #16. \n(175) On or about October 1, 2005, Defendant \nleft a \ntelephone message for Defendant JEFFREY EPSTEIN stating: \"[Jane Doe #15] \nconfirmed at 11 AM and [Jane Doe #16] — 4PM\". \n(176) On or about October 2, 2005, Defendant \nplaced a \ntelephone call t9 a telephone used by Jane Doe #16. \n(177) Ori.or about October 3, 2005, Defendant \nplaced a \ntelephone call to a telephone used by Jane Doe #16. \n(178) On or about October 3, 2005, Defendant \nleft a \ntelephone message for Defendant JEFFREY EPSTEIN stating: \"[Jane Doe #I6] will \nbe''/: hour late\".\n(179) In or around the first week of October, 2005, Defendaqt JEFFREY \nEPSTEIN engaged in sexual intercourse with Jane Doe #16, who was then a \nseventeen-year-old girl. \n(180) In or around the first week of October, 2005, Defendant JEFFREY \n4 \nEPSTEIN made a payment of $350.00 to ne Doe #16, who was then a seventeen-\nyear-old girl. \n(181) In or around the first week of October, 2005, Defendant JEFFREY \nEPSTEIN provided a gill of \nSecret lingerie to Jane Doe #16 for her \neighteenth birthday. \nt 4 \nI \n30 \nEFTA00224704\n", "char_count": 1186}, {"efta_number": "EFTA00224636", "page_number": 69, "text_content": "(190) On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally \nreprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she \nviasVot willing to undress for him. \nThe Defendants' Travel \n(191) On or about March 11, 2004, Defendants JEFFREY EPSTEIN \n, and \ntraveled from Teterboro, New Jersey, to \nPalm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, \nInc. \nN\n4\ni4;\n(192) On or about May 1, 2004, Defendants JEFFREY EPSTEIN, \nand \ntraveled from New York, New York to Palm \nBeach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. \n(193) On or about MA4, 2004, Defendants JEFFREY EPSTEIN, \nand \ntraveled from Canada to Palm Beach \nCounty, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. \n(194) On or about June 11, 2004, Defendants JEFFREY EPSTEIN and \ntraveled from Chicago, Illinois to Palm Beach County, Florida \naboard the Gulfstream aircraft owned by Fyperion Air, Inc. \n(195) On or about June 20, 2004, Defendants JEFFREY EPSTEIN and \ntraveled from the U.S. Virgin Islands to Palm Beach \nCounty, Florida aboard the Boeing 727 aircraft owned by JEGE, MC. \nIn \n• \n32 \nEFTA00224705\n", "char_count": 1163}, {"efta_number": "EFTA00224636", "page_number": 70, "text_content": "(196) On or about July 4, 2004, Defendants JEFFREY EPSTEIN, ME \nand =N\n-traveled \nfrom Aspen, Colorado to Palm \ngaol), County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. \n(197) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, \n11.. \nand \ntraveled from Teterboro, New Jersey to \nPalm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, \nInc. \n(198) NI. about July 22, 2004, Defendants JEFFREY EPSTEIN,' \nEIM \nand \ntraveled from the U.S. Virgin Islands to \nPalm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. \n(199) On or about August 19, 2004, Defendants JEFFREY EPSTEIN and \ned from Van Nuys, California to Palm Beach County, \nFlorida aboard the Boeing 727 aircraft owned by JEGE, INC. \n(200) On or about August 25, 2004, Defendants JEFFREY EPSTEIN, \nand \ntraveled from Ecuador to Palm \nBeach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. \n(201) On or about October 2, 2004, efendants JEFFREY EPSTEIN, \na \nand \ntraveled from the U.S. Virgin Islands to \nPalm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC. \n33. \nEFTA00224706\n", "char_count": 1151}, {"efta_number": "EFTA00224636", "page_number": 71, "text_content": "(202) On or about October 29, 2004, Defendants JEFFREY EPSTEIN and \ntraveled from Teterboro, New Jersey to Palm Beach \neibilisy, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. \n• \n(203) On or about November 10, 2004, Defendants JEFFREY EPSTEIN and \nMB \ntraveled from Teterboro, New Jersey to Palm Beach County, \nFlorida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. \n(204) On or about November 18, 2004, Defendants JEFFREY EPSTEIN, \nSARAH ICEL4N, \nMI \na/k/a ME \nElln,\" \nand= \ntraveled from Teterboro, New Jersey to Palm Beach County, Florida \naboard the Gulfstream aircraft owned by Hyperion Air, Inc. \n(205) On or about December 3, 2004, Defendants JEFFREY EPSTEIN, \nand \n,a/k/a` \n,\"traveled from \nNew York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft \nowned by JEGE, INC. \n(206) On or about December 13, 2004, Defendant JEFFREY EPSTEIN \ntraveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the \nGulfstream aircraft owned by Hyperion Ail, Inc. \n(207) On or about December 17, 2004, Defendants JEFFREY EPSTEIN and \ntraveled from Teterboro, New Jersey to Palm Beach \nCounty, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. \n34 \nEFTA00224707\n", "char_count": 1241}, {"efta_number": "EFTA00224636", "page_number": 72, "text_content": "(208) On or about January 1, 2005, Defendants JEFFREY EPSTEIN, \n,and \ntraveled from Anguilla, British West Indies \ntl Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion \nAir, Inc. \n(209) On or about January 6, 2005, Defendant JEFFREY EPSTEIN traveled \nfrom Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream \naircraft owned by Hyperion Air, Inc. \n(210) f7' or about January 14, 2005, Defendants JEFFREY EPSTEIN, \n, a/k/a \nEMB\" \nand \ntraveled from the U.S. Virgin Islands to Palm Beach County, \nFlorida, aboard the Boeing 727 aircraft owned by JEGE, INC. \n(211) On or about J.ifixuary 19, 2005, Defetidants JEFFREY EPSTEIN, \na/k/a \nand \ntraveled from New York, New York to Palm Beach County, Florida \naboard the Boeing 727 aircraft owned by JEGE, INC. \n(S ) On or about February 3, 2005, Defendants JEFFREY EPSTEIN, \nr-41\nand \ntraveled from Columbus, Ohio, to \nPalm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC. \n(213) On or about February 10, 2005, Defendants JEFFREY EPSTEIN, \na/k/a \nand \nEFTA00224708\n", "char_count": 1080}, {"efta_number": "EFTA00224636", "page_number": 73, "text_content": "traveled from New York, New York to Palm Beach County, Florida, \naboard the Boeing 727 aircraft owned by JEGE, INC. \n(214) On or about February 21, 2005, Defendants JEFFREY EPSTEIN, \n, and \ntraveled from the U.S. Virgin \nIslands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by \nJEGE, INC. \n(215) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, \nSARAH KEL  \nand \ntraveled from Teterboro, New \nJersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by \nHyperion Air, Inc. \n(216) On or about March 4, 2005, Defendants JEFFREY EPSTEIN, \n, a/k/a \"Adriana Mucinska,\" and_- \ntraveled \nfrom New York, New York to Palm Beach County, Florida aboard the Boeing 727 \naircraft owned by JEGE, INC. \n(217) On or about March 18, 2005, Defendant JEFFREY EPSTEIN traveled \nfrom New York, New York to Palm Beach County, Florida aboard the Boeing 727 \naircraft owned by JEGE, INC. \n(218) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled \nfrom New York, New York to Palm Beach County, Florida, aboard the Boeing 727 \naircraft owned by JEGE, INC. \n36 \nEFTA00224709\n", "char_count": 1111}, {"efta_number": "EFTA00224636", "page_number": 74, "text_content": "(219) On or about May 19, 2005, Defendants JEFFREY EPSTEIN, \nMIL and \na/k/a \n\" traveled from \n'fete born, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft \n• \nowned by Hyperion Air, Inc. \n(220) On or about June 30, 2005, Defendants JEFFREY EPSTEIN and \ntraveled from Teterboro, New Jersey to Palm Beach County, \nFlorida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. \n(221) Orr-or about July 22, 2005, Defendants JEFFREY EPSTEIN and \ntraveled from Teterboro, New Jersey to Palm Beach County, \nFlorida aboard the Gulfstream aircraft owned by Hyperion Air, Inc. \n(222) On or about August 18, 2005, Defendants JEFFREY EPSTEIN, \na/k/a \"Adriiina Mucinska,\" and \ntraveled \nJ. \nA \nfrom Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream \naircraft owned by Hyperion Air, Inc. \n(223) On or about September 3, 2005, Defendants JEFFREY EPSTEIN and \na/k/a \n\" traveled from the U.S. Virgin Islands \nto Palm Beach County, Florida aboard th Gulfstream aircraft owned by Hyperion \nAir, Inc. \n(224) On or about September 18, 2005, Defendants JEFFREY EPSTEIN, \nand \n37 \na/k/a \n\" traveled from \nEFTA00224710\n", "char_count": 1148}, {"efta_number": "EFTA00224636", "page_number": 75, "text_content": "Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream \naircraft owned by Hyperion Air, Inc. \nrf, (225) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, \nafida \ntraveled \nfrom Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream \naircraft owned by Hyperion Air, Inc. \nAll in violation of Title 18, United States Code, Section 371. \nCOUNTS 2 THROUGH 10 \n(Sex Trafficking: 18 U.S.C. § 1591(a)(1)) \n31. \nParagraphs I through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n32. \nOn or about the dates enumerated as to each count listed below, the exact dates \nA \nbeing unknown to the Grand Jury,\n Beach County, in the Southern District of Florida, \nand elsewhere, the Defendants listed below did knowingly, in and affecting interstate and \nforeign commerce, recruit, entice, provide, and obtain by any means a person, that is, the \nperson in each count listed below, knowing that the person had not attained the age of 18 \nyears and would be caused to engage in a comn\\Wial sex act as defined in 18 U.S.C. § \nV. \n1591(cX1): \nCount \nDate(s) \nMinor Involved \nDefendant(s) \n2 \n2001 - 2004 \nJane Doe #2 \nJEFFREY EP \nFIN \n38 \nEFTA00224711\n", "char_count": 1243}, {"efta_number": "EFTA00224636", "page_number": 76, "text_content": "Count \nDate(s) \nMinor Involved \nDefondantis) \n3 \nJanuary 2004 \nthrough \nJuly 2004 \nJane Doe #4 \nJEFFREY EPSTEIN \n4 \nJuly 2004 \nthrough \nDecember 29, \n2004 \nJane Doe #9 \nJEFFREY EPSTEIN \n5 \nJuly \nthrough \nJanuary, \n2004 \n1, 2005 \nJane Doe #10 \nJEFFREY EPSTEIN \n6 \nMid \nthrough \nApril 22, \n(104 \n2005 \nJane Doe #12 \nJEFFREY EPSTEIN \n7 \nAugust 2004 \nthrough \nMay 27, 2005 \nJane Doe #13 \nJEFFREY EPSTEIN \n8 \nNovember 2004 \nthrough \nMarch 2005 \nJane Doe #14 \ns r. \n/- ' \nJEFFREY EPSTEIN \na/k/ ' \n, \n9 \nDecember 2004 \nthrough \nJune 5, 2005 \nJane Doe #15 \nJEFFREY EPSTEIN \na/k/ \n10 \nFebruary 2005 \nthrough\nfirst week of \nOctober 2005 \nJane Doe #16 \nJEFFREY EPSTEIN \nand ' \nAll in violation of Title 18, United States Code, Sections 1591(a)(I) and 2. \n39 \nEFTA00224712\n", "char_count": 761}, {"efta_number": "EFTA00224636", "page_number": 77, "text_content": "COUNT 11 \n(Sex Trafficking: 18 U.S.C. § 1591(a)(2)) \n33. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreferendeaS though fully set forth herein. \n34. \nFrom at least as early as in or about 2001 through in or about October 2005, \nthe exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern \nDistrict of Florida, and elsewhere, the defendants, \na/l\naa \nand \n11 \ndid knowingly benefit, financially or by receiving anything of value, from participation in a \nventure, as defined in 18 U.S.C. § 1591(cX3), which had engaged in an act described in \nviolation of 18 U.S.C. § 1591(aX1), thht is, the recruiting, enticing, providing, and obtaining \nby any means a person, in or affecting interstate commerce, knowing that the person or \npersons had not attained the age of 18 years and would be caused to engage in a commercial \nsex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code, \nSections 1591(aX2), 1591(b)(2), and 2. \nCOUNT 112 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n35. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n40 \nEFTA00224713\n", "char_count": 1218}, {"efta_number": "EFTA00224636", "page_number": 78, "text_content": "36. \nFrom in or around the spring of 2003 through on or about October 2, 2005, the \nexact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District \nof Floral, Ind elsewhere, the defendants, \nJEFFREY EPSTEIN \nand \ndid use a facility or means of interstate commerce, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #3, who was a person who had not attained the age of \n18 years, to engage in intOstitution and in a sexual activity for which a person can be charged \nwith a criminal offense, that is violations of Florida Statutes Sections 800.04(5)(a), \n800.04(6)(a), and 800.04(7Xa); in violation of Title 18, United States Code, Sections 2422(b) \nand 2. \n\".4COUNT 13 \n(Enticement ofi a:Minor: 18 U.S.C. § 2422(b)) \n37. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n38. \nIn or around July 2004, the exact dates being unknown to the Grand Jury, in \nPalm Beach County, in the Southern District of F(oda, and elsewhere, the defendants, \nJEFFREY EPSTEIN \nand \ndid use a facility or means of interstate commerce, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #7, who was a person who had not attained the age of . \nrr \n41 \nEFTA00224714\n", "char_count": 1294}, {"efta_number": "EFTA00224636", "page_number": 79, "text_content": "18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections \n2422(b) and 2. \nCOUNT 14 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n39. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n40. \nFrom in or around July 2004 through in or around October 2004, the exact \ndates being unknown lathe Grand Jury, in Palm Beach County, in the Southern District of \nFlorida, and elsewhere, the defendants, \nJEFFREY EPSTEIN \nand \ndid use a facility or means of interstate commerce, that is, the telephone, to knowingly \ncs \npersuade, induce and entice Jane Dere #8, who was a person who had not attained the age of \n18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections \n2422(b) and 2. \nCOUNT 15 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \nT.:. \n41. \nParagraphs 1 through 25 of this Indiament are re-alleged and incorporated by \nreference as though fully set forth herein. \n42. \nFrom in or around July 2004 through on or around December 29, 2004, the \nexact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District \nof Florida, and elsewhere, the defendants, \n42 \nEFTA00224715\n", "char_count": 1242}, {"efta_number": "EFTA00224636", "page_number": 80, "text_content": "JEFFREY EPSTEIN \nand \ndid use ja facility or means of interstate commerce, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #9, who was a person who had not attained the age of \n18 years, to engage in prostitution and in a sexual activity for which a person can be charged \nwith a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of \nTitle 18, United States Code, Sections 2422(b) and 2. \nc \nCOUNT 16 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n43. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n44. \nFrom in or around July 2004 through on or about January 31, 2005, the exact \ndates being unknown to the Grand Jury; in Palm Beach County, in the Southern District of \nFlorida, and elsewhere, the defendants, \nJEFFREY EPSTEIN \nand. \ndid use a facility or means of interstate commef\n, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #10, who was a person who had not attained the age \nof 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections \n2422(b) and 2. \n43 \nEFTA00224716\n", "char_count": 1184}, {"efta_number": "EFTA00224636", "page_number": 81, "text_content": "COUNT 17 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n45. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nto. \nreference-a1 though fully set forth herein. \n46. \nFrom in or around the middle of 2004 through on or about April 22, 2005, the \nexact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District \nof Florida, and elsewhere, the defendants, \nJEFFREY EPSTEIN \n,t \nand \ndid use a facility or means of interstate commerce, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #12, who was a person who had not attained the age \nof 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections \n2422(b) and 2. \nCOUNT 18 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n47. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n48. \nFrom in or around August 2004 thrLgh on or about May 27, 2005, the exact \ndates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of \nFlorida, and elsewhere, the defendants, \nJEFFREY EPSTEIN \nand \n44 \nEFTA00224717\n", "char_count": 1161}, {"efta_number": "EFTA00224636", "page_number": 82, "text_content": "did use a facility or mans of interstate commerce, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #13, who was a person who had not attained the age \nir • \nof 18 yelirsidto engage in prostitution; in violation of Title 18, United States Code, Sections \n2422(b) and 2. \nCOUNT 19 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n49. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though flilk set forth herein. \n50. \nFrom in or around November 2004 through in or around March 2005, the exact \ndates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of \nFlorida, and elsewhere, the defendants, \nJEFFREY EPS \nIN, \nie\nmn\nH \nand \n, a/k/a \ndid use a facility or means of interstate commerce, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #14, who was a person who had not attained the age \nof 18 years, to engage in prostitution and in a sexual activity for which a person can be \ncharged with a criminal offense, that is a violatifilof Florida Statutes Section 794.05; in \nviolation of Title 18, United States Code, Sections 2422(b) and 2. \n45 \nEFTA00224718\n", "char_count": 1183}, {"efta_number": "EFTA00224636", "page_number": 83, "text_content": "COUNT 20 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n51. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nX \n4 \nrefereneeeitg though fully set forth herein. \n52. \nFrom in or around December 2004 through on or about June 5, 2005, the exact \ndates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of \nFlorida, and elsewhere, the defendants, \n% \nJEFFREY EPSTEIN, \nand \na/k/a \n tf\ndid use a facility or means of interstate commerce, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #15, who was a person who had not attained the age \nof 18 years, to engage in prostitution \nviolation of Title 18, United States Code, Sections \nr \n2422(b) and 2. \nCOUNT 21 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n53. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n.1 \n54. \nFrom in or around February 2005 through in or around the first week of \nOctober 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in \nthe Southern District of Florida, and elsewhere, the defendants, \n46 \nEFTA00224719\n", "char_count": 1171}, {"efta_number": "EFTA00224636", "page_number": 84, "text_content": "JEFFREY EPSTEIN, \nand \ndid useLfilcility or means of interstate commerce, that is, the telephone, to knowingly \npersuade, induce or entice Jane Doe #16, who was a person who had not attained the age of \n18 years, to engage in prostitution and in a sexual activity for which a person can be charged \nwith a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of \nTitle 18, United Staticode, Sections 2422(b) and 2. \nCOUNT 22 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n55. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n56. \nFrom in or around Fennry 2005 through in or around April 2005, the exact \ndates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of \nFlorida, and elsewhere, the defendants, \nJEFFREY EPSTEIN, \nand \na/k/a \n1 • \ndid use a facility or means of interstate commerce, that is, the telephone, to knowingly \nI> \npersuade, induce and entice Jane Doe #17, who was a person who had not attained the age \nof 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections \n2422(b) and 2. \n47 \nEFTA00224720\n", "char_count": 1192}, {"efta_number": "EFTA00224636", "page_number": 85, "text_content": "2422(b) and 2. \nCOUNT 23 \n(Enticement of a Minor: 18 U.S.C. § 2422(b)) \n57. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference .$ though fully set forth herein. \n58. \nFrom in or around August 2003 through in or around February 2004, the exact \ndates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of \nFlorida, and elsewhere, the defendants, \nJEFFREY EPSTEIN, \nand \ndid use a facility or means of interstate commerce, that is, the telephone, to knowingly \npersuade, induce and entice Jane Doe #18, who was a person who had not attained the age \nof 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections \nIAP \nCOUNT 24 \n(Conspiracy to Travel: 18 U.S.C. § 2423(e)) \n59. \nParagraphs 1 through 25 of this indictment are re-alleged and incorporated by \nreference as fully set for the herein. \n60. \nFrom at least as early as 2001 through in or around October 2005, the exact \ndates being unknown to the Grand Jury, the Defendants, \nJEFFREY EPSTEIN, \nand \n48 \nEFTA00224721\n", "char_count": 1074}, {"efta_number": "EFTA00224636", "page_number": 86, "text_content": "did knowingly and willfully conspire with each other and with others known and unknown \nto travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined 'n 1,8 U.S.C. § 2423(0, with another person, in violation of Title 18, United States \nCode, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e). \nCOUNT 25 \n(Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d)) \n61. \nParagraphs I through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n62. \nFrom at least as early as in or about 2001 through in or around October 2005, \nthe exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern \nDistrict of Florida, and elsewhere, the Defendant, \ndid, for the purpose of commercial ailattage or private financial gain, arrange and facilitate \nthe travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was \ntraveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as \ndefined in 18 U.S.C. § 2423(f); in violation of Title 18, United States Code, Section 2423(d). \nCOUNTS 26 THTT,JGH 29 \n(Travel to Engage in Illicit Sexual C nduct: 18 U.S.C. § 2423(b)) \n63. \nParagraphs 1 through 25 of this Indictment are re-alleged and incorporated by \nreference as though fully set forth herein. \n64. \nOn or about the dates enumerated as to each count listed below, from a place \noutside the Southern District of Florida to a place inside the Southern District of Florida, the \n49 \nEFTA00224722\n", "char_count": 1585}, {"efta_number": "EFTA00224636", "page_number": 87, "text_content": "Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in \nillicit sexual conduct as defined in 18 U.S.C. § 2423(t), with a person under 18 years of age, \nthat is, ilie-person(s) listed in each count below: \nCount \nDate(s) \nMinor(s) Involved \nDefendant(s) \n26 \n7/16/2004 \nJane Doe #7 \nJane Doe #8 \nJane Doe #9 \nJane Doe #16 \nJ \nREY EP \n27 \n3/31/29OJ5 \n!! • \nJane Doe #14 \nJane Doe #15 \nJane Doe #16 \nJ \na/k/1 111111\na\" \nE\n' \n28 \n9/18/2005 \nJane Doe #16 \nJEFFREY EPSTEIN \na/k/a \" \n29 \n9/29/05 \nJane Doe #16 \n.1 .-\nJEFFREY E. ,\" ‘E N \n, \n' \nAll in violation of Title 18, United States Code, Sections 2423(b) and 2. \nFORFEITURE I. \nUpon conviction ofthe violation alleged inlount 1 of this indictment, the defendants, \nJEFFREY EPSTEIN, Mall, \nIMIMMI, \na/k/a `MM.\" \nand \nEMIIIMIMI, \nshall forfeit to the United States any property, real or personal, \nwhich constitutes or is derived from proceeds traceable to the violation. \n50 \nEFTA00224723\n", "char_count": 970}, {"efta_number": "EFTA00224636", "page_number": 88, "text_content": "Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code, \nSection 981(aX1)(C); and Title 21, United States Code, Section 853. \nIf the property described above as being subject to forfeiture, as a result of any act or \nomission of the defendants, JEFFREY EPSTEIN, \na/k/a \n\" and \n(1) \ncannot be located upon the exercise of due diligence; \n(2) \nhas been transferred or sold to, or deposited with a third person; \n) \n(3) \nhas been placed beyond the jurisdiction of the Court; \n(4) \nhas been substantially diminished in value; or \n(5) \nhas been commingled with other property which cannot be subdivided without \ndifficulty; \nit is the intent of the United States, pylkuant to Title 21, United States Code, Section 853(p), \nat \nto seek \nseek forfeiture of any other property of the defendants up to the value of the above \nforfeitable property. \nAll pursuant to Title 28 United States Code, Section 2461; Title 18, United States \nCode, Section 981(aX1)(C); and Title 21 United States Code, Section 853. \n4 .\nFORFEITURE 2 \nUpon conviction of any of the violations alleged in Counts 12-29 of this indictment, \nthe defendants, JEFFREY EPSTEIN, \nn\nand \n, a/k/a `M \nshall forfeit to the United States any property, real \nor personal, constituting or traceable to gross profits or other proceeds obtained from such \n51 \nEFTA00224724\n", "char_count": 1351}, {"efta_number": "EFTA00224636", "page_number": 89, "text_content": "offense; and any property, real or personal, used or intended to be used to commit or to \npromote the commission of such offense, including but not limited to the following: \na.\n33480, including all buildings, improvements, fixtures, attachments, and easements found \nA parcel of land located at 358 El Brillo Way, Palm Beach, Florida \ntherein or thereon, and more particularly described as: \nBeing all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as \nrecorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida \nand \nBEING that pi:Vtion lying West of Lot 40, El Bravo Park, in Section 27, \nTownship 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public \nRecords of Palm Beach County, Florida, being bounded on the West by the \nWest side of an existing concrete seawall and the northerly extension thereof \nas shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, \nand bounded on the East by the shoreline as shown on the plat of El Bravo \nPark, and bounded on the North and South by the Westerly extensions of the \nNorth and South lines respectively of Lot 40, containing 0.07 acres, more or \nless. \nPursuant to Title 18, United States Code, Section 2253. \nIf any of the forfeitable property described in the forfeiture section of this indictment, \nas a result of any act or omission of the defendants JEFFREY EPSTEIN, \n, a/k/a \n\" and \n(a) \ncannot be located upon the exercisAf due diligence; \n(b) \nhas been transferred or sold to, or deposited with, a third person; \n(c) \nhas been placed beyond the jurisdiction of the Court; \n(d) \nhas been substantially diminished in value; or \n52 \nEFTA00224725\n", "char_count": 1664}, {"efta_number": "EFTA00224636", "page_number": 90, "text_content": "(e) \nhas been commingled with other property which cannot be divided without \ndifficulty; \nit is the ijte t of the United States, pursuant to Title 18, United States Code, Section 2253(o), \nA...,? \nto seek forfeiture of any other property of said defendant up to the value of the above \nforfeitable property. \nPursuant to Title 18, United States Code, Section 2253. \nFORFEITURE 3 \nt FY\nUpon convictien%f any of the violations alleged in Counts 2-11 of this indictment, \nthe defendants, JEFFREY EPSTEIN, \na/k/a'\nn \nand \nshall forfeit to the United States any property, real \nor personal, that was used or intended to be used to commit or to facilitate the commission \nof such violation; and any properyc,real or personal, constituting or derived from any \nproceeds that such person obtained, directly or indirectly, as a result of such violation, \nincluding but not limited to the following: \na. \nA parcel of land located at 358 El Brillo Way, Palm Beach, Florida \n33480, including all buildings, improvements, fixtures, attachments, and easements found \ntherein or thereon, and more particularly described as: \nBeing all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as \nrecorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida \nand \nBEING that portion lying West of Lot 40, El Bravo Park, in Section 27, \nTownship 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public \nRecords of Palm Beach County, Florida, being boundetIF the West by the \n53 \nEFTA00224726\n", "char_count": 1507}, {"efta_number": "EFTA00224636", "page_number": 91, "text_content": "West side of an existing concrete seawall and the northerly extension thereof \nas shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, \nand bounded on the East by the shoreline as shown on the plat of El Bravo \nPark, and bounded on the North and South by the Westerly extensions of the \nItfoith and South lines respectively of Lot 40, containing 0.07 acres, more or \nless. \nPursuant to Title 18, United States Code, Section 1594(b). \nA TRUE BILL. \nFOREPERSON \nIt ALEXANDER ACOSTA \nUNITED STATES ATTORNEY \nASSISTANT UNITED STATES ATTORNEY \nre; \n1 \n54 \nEFTA00224727\n", "char_count": 584}]}