What the documents describe as the approachPayment offered for giving a massage at one of Epstein’s residences, alleged in civil pleadings and stated as an opinion in an expert report served in civil litigation12
What they describe as the means of expansionPayment to people already involved for bringing others, alleged in a class-action pleading and reported by an expert as mentioned by numerous complainants and in the Palm Beach investigation34
Figure attached to the approach in a pleading”generally $200 to $300 per ‘massage’ session”, as the amended complaint alleged and the court recited it on a motion to dismiss1
Figure attached to bringing others”$200”, reported by an expert as a potential recruitment fee she could not determine the frequency of and therefore excluded from her own estimates4
Other inducement recordedPromises of modelling work, in an expert’s list of pretexts and in an FBI note reporting one victim account56
Status of every item aboveAllegation, opinion or assessment. None of it is a finding by any court127

This page reports what the released documents state about the method by which girls and young women were brought to Epstein, and about what kind of document states it. It carries no account of what happened to any individual, identifies no complainant, and reproduces no example from any source that gives one.

The subject is dangerous in a specific way. Almost every document that describes the method does so through the account of a particular person, and the passages that make the method concrete are the passages that identify her. Where the documents cited here give examples, this page reports that they do and stops.

The proceedings are covered elsewhere: the Palm Beach Police Department investigation sets out what that department found in 2005 and 2006 and how, and is the fuller account of the same conduct; Victims in the Epstein record covers the pseudonyms, designations and counting; Jean-Luc Brunel and Elite Model Management cover the modelling agencies and what is and is not documented about them.

The pretext, as the documents state it

An expert report served in the Virgin Islands’ civil action against JPMorgan Chase gives the fullest general statement. Bridgette Carr, retained by the Virgin Islands, wrote on June 16, 2023 that on her review of the victim statements she had been given, “it appears that Epstein or others acting under his direction recruited economically vulnerable girls and young women for commercial sex under the false pretense of receiving payment for providing a massage.”2 She added: “Many of the statements I reviewed were strikingly similar in their pattern of recruitment and exploitation, reinforcing their credibility.”2 That is an expert’s opinion prepared for a party in civil litigation, not a finding, and every page cited here carries a header marking the report confidential and subject to a protective order.

Two pages further on she set out what she said the fraud consisted of: that “young girls and women were fraudulently recruited to perform paid ‘massages,’ ‘modeling,’ or other forms of work; however, in most instances, Epstein required sexual acts as part of the work”, that this “was perpetuated by the language used to recruit young girls and women to his home and even in the physical set-up he created in his home”, and that at the residence they “were taken to an interior, private space with a massage table.”5 The word “perpetuated” is the report’s own.

Under each of those two passages the report sets out lettered examples drawn from individual accounts. Those accounts are not reproduced or summarised here.25

The same approach appears in the pleadings. Ruling on a motion to dismiss in Jane Doe No. 5 v. Jeffrey Epstein on February 12, 2009, the United States District Court for the Southern District of Florida introduced its account with the words “The facts, as alleged in the Amended Complaint, are as follows”, tagged each sentence of it to a paragraph of that pleading, and decided nothing about whether any of it was true. The recitation states: “Defendant’s scheme involved the use of young girls to recruit underage girls.” It continues that under the plan “underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion.”1

Who the pleadings say was sought, and on what terms

The same recitation gives the alleged terms and the alleged selection. It states that the girls approached were “economically disadvantaged underage girls from western Palm Beach County who would be enticed by the money being offered”, the money being “generally $200 to $300 per ‘massage’ session”, and that they were “perceived as less likely to complain to authorities or have credibility if allegations of improper conduct were made.”1 The name of the person the pleading alleges did the seeking is blacked out on that page, and nothing here supplies it. Epstein was the moving party: he was contesting that pleading. Ruling on that motion, the court denied dismissal of Count I, granted in part his motion for a more definite statement on Count III while denying dismissal of it, and struck his citation to 28 U.S.C. § 2255 from the complaint.8 He died in August 2019; what became of the case after that is not established on this page.

Carr reached the economic point separately, as an opinion on the material she reviewed rather than as a count, and her statement of why she could not put a number on it is reported at Victims in the Epstein record.2

Payment for bringing others

Both the expert report and the pleadings describe payment to people already involved for bringing others, and they describe it as the mechanism by which the number grew.

Carr wrote that “several of the victims mention being offered cash to recruit young girls for Epstein.”4 She put a figure on it and immediately qualified it: “potential recruitment fees of $200 which were mentioned by numerous victims and in the Palm Beach police investigation”, which she excluded from her own payment estimates because she “was unable to determine how often recruitment fees were paid.”4 The qualification is hers and belongs with the figure.

The first amended class-action complaint filed against JPMorgan Chase Bank in the Southern District of New York on January 13, 2023 alleges the same thing and dates it: that “By 1998, each victim was being directed to recruit other vulnerable victims and being paid handsomely, typically in cash, for each recruitment, creating a pyramid scheme of abuse.”3 It also alleges what the arrangement did beyond adding numbers: “This scheme of paying victims to recruit other victims worked effectively for Epstein. It not only allowed expansion through the recruitment of other victims in a pyramid scheme or spiderweb fashion, but it also gave each victim hope that she could avoid future sexual abuse—she could bring someone else who would get abused in her place.”7 Those are allegations in a private plaintiff’s pleading, brought against a bank rather than against Epstein, and Epstein had been dead more than three years when it was filed. No response from him to any of it exists and none could. Both the Virgin Islands’ action, in which Carr’s report was filed, and this class action ended in settlement rather than in a verdict or judgment: the class action’s court-approved settlement notice states in capitals that “THE COURT HAS NOT RULED AS TO WHETHER DEFENDANT IS LIABLE TO THE CLASS REPRESENTATIVE OR TO THE CLASS,” and the Virgin Islands’ action was dismissed with prejudice by stipulation and closed on October 18, 2023, without any adjudication of the claims.910 Further detail on both settlements is at JPMorgan Chase Bank.

What happened to a woman who took the payment described above, once she had recruited someone else, is answered directly in the Department of Justice’s own review of the 2007 non-prosecution agreement. Andrew Lourie, the supervisor who reviewed the agreement’s clause promising not to prosecute “potential co-conspirators,” told the Department’s Office of Professional Responsibility that “victims who recruited other underage girls to provide massages for Epstein ‘theoretically’ could have been charged as co-conspirators,” and that when he saw the provision, he “may have understood the reference to unnamed ‘co-conspirators’ as ‘a message to any victims that had recruited other victims that there was no intent to charge them.’”11 The same review recorded that “the USAO had not indicated interest in prosecuting anyone other than the four named female assistants, and OPR found no record indicating that Epstein had expressed concern about the prosecutive fate of anyone other than the four assistants and unnamed employees of a specific Epstein company.”11 A Department trial attorney who separately reviewed the case for trial told OPR that one of the difficulties in prosecuting Epstein was that “some had recruited other victims to provide Epstein massages, and thus could have been charged as accomplices”, one item on a list of reasons the case was thought difficult, not a charging decision that was made.12 The review’s own conclusion is that no woman in that position was charged: prosecutors had indicated interest in prosecuting only the four named assistants, and nothing cited here or elsewhere on this wiki records a different outcome.11

The Palm Beach Police Department recorded the same practice independently, from the complainants and household staff it interviewed in 2005 and 2006, including that Epstein “encouraged the girls who performed these massages to find other girls interested in performing massages for him, and promised that if a girl brought a friend along to perform a massage, each girl would receive $200. Several of the victims acknowledged to the PBPD that they had recruited other girls on Epstein’s behalf.”13 Its account is the contemporaneous one and it is the fuller one, and it carries the evidence about what Epstein knew of the girls’ ages, which ran both ways, and his attorney’s response. It is at the Palm Beach Police Department investigation and is not restated here.

An undated outline of questions for Ghislaine Maxwell

A six-page document in the released files is headed “GHISLAINE MAXWELL - DEPOSITION OUTLINE”; its first five pages consist entirely of numbered questions grouped under headings, the first of which is “Recruitment”, and its sixth page is blank.14 It carries no date, no case caption, no letterhead and no author on any of its six pages, and it contains no answers. It is evidence of what someone intended to ask and of nothing else, and this page does not treat it as evidence that anything asked about happened.

Most of its recruitment questions name a person whose name is blacked out. Five do not, and they set out plainly what was to be put to her: whether she did “recruit young, including underage, females for Jeffrey Epstein”; whether he told her to; whether she did “oversee and train other recruiters on how best to recruit females for sex for Jeffrey Epstein”; and whether she ever promised, or heard him promise, “young women money, shelter, transportation, gifts, employment, admission into educational institutions, education tuition, protection or other things in exchange for sex or sexual activities.”14 That list of inducements is the most detailed enumeration of them in the documents cited on this page.

No response by Maxwell to this specific outline is recorded among the documents cited on this page or on her own; the questions it lists were never put to her in these terms in the criminal case that was actually brought. An FBI investigative-status summary of that case records that Maxwell was indicted on June 29, 2020, that her trial began on November 28, 2021, that she was convicted on December 29, 2021 on five of six counts, that she was sentenced on June 28, 2022 to twenty years, and that in November 2024 an appeals court rejected her request for en banc review.15 Her plea, the trial evidence, her subsequent appeals and her collateral challenge are set out in full, with their own sources, at Ghislaine Maxwell.

The FBI’s 2022 assessment

The FBI New York Field Office issued an intelligence note on April 6, 2022 headed “Wealthy, Influential Individuals Involved in Sex Trafficking Likely Rely Primarily on Referrals and Career Enhancement Promises to Entice Victims, Representing an Expansion of Traditional Sex Trafficking Techniques.”16 It is an assessment of a class of people and is not confined to Epstein: it names several other men and one woman, and does not connect any of them to him, and it states that the assessment is made “with medium confidence”.16

Epstein appears on one page of it, in two bullets of illustrative accounts and in a list of high-profile cases. The first of those bullets records that as of November 2020, according to a victim with direct access, he “lured young females with the promise of modeling careers stating he had connections with Victoria’s Secret.”6 The rest of that bullet, and the bullet after it, are accounts of what was done to two individuals, and neither is reproduced here.

The note’s outlook is a forecast rather than a record of anything Epstein did, and is quoted because it is the reason the assessment was written: “FBI New York assesses wealthy influential traffickers will likely resume their predatory behavior in the next two to three years, as these high profile investigations cease and media coverage lessens.”17

The note describes itself as expanding on an earlier FBI New York note of 22 January 2021 about the use of social media to recruit victims.18 That earlier note is a separate document; it is referred to by title and date on this page’s cited pages and is not itself among the documents cited here.

The modelling agencies, and where that material is

The expert report lists “modeling” among the pretexts, and the FBI note records one account of it, and both are above. The agencies themselves are not covered here. A search of the released files under the variants “MC2”, “MC2 Model Management”, “Karin Models”, “Elite”, “Brunel” and “modeling agency” returns the material those pages are built from, and it is set out there with the qualifications its own sources gave it and with the responses of the people concerned: see Jean-Luc Brunel and Elite Model Management. Some of the documents those searches surface are newspaper articles held in the release rather than records made by anyone who investigated anything, which is a reason to read them on the pages that treat them as journalism.

Footnotes

  1. Jane Doe No. 5 v. Jeffrey Epstein, No. 08-80381-CIV-MARRA (S.D. Fla.), Opinion and Order on Motion to Dismiss and Motion for More Definite Statement, entered February 12, 2009, EFTA02741750, pp. 1-2. The words introducing the account stand at the foot of p. 1 and the recited allegations run over on to p. 2, which is why both pages are pinned. The passages quoted are the court’s recitation of the amended complaint’s allegations, each tagged in the original to a paragraph of that pleading. Nothing else on those pages is cited here. 2 3 4 5

  2. Expert report of Bridgette Carr, June 16, 2023, filed as Exhibit 9 to Document 237-9 in Government of the United States Virgin Islands v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10904-JSR (S.D.N.Y.), EFTA02810334, p. 21 (report folio 18), paragraphs 56 and 57. The lettered examples under paragraph 57 are covered on that page. 2 3 4 5 6

  3. Jane Doe 1, individually and on behalf of all others similarly situated v. JP Morgan Chase Bank, N.A., No. 22-cv-10019-JSR (S.D.N.Y.), First Amended Individual and Class Action Complaint, Document 36, filed January 13, 2023, EFTA00162121, p. 11, paragraph 36. 2

  4. Same report, EFTA02810334, p. 56 (report folio 53), paragraphs 164 and 167. The daily payment estimates on the same page concern payments for sexual acts rather than recruitment and are not cited here. 2 3 4

  5. Same report, EFTA02810334, p. 23 (report folio 20), paragraph 59. The lettered examples following that paragraph are not reproduced here. 2 3

  6. Same note, EFTA00172536, p. 3. The remainder of that bullet and the bullet following it are individual accounts and are not cited for anything. 2

  7. Same complaint, EFTA00162121, p. 13, paragraph 47. 2

  8. Jane Doe No. 5 v. Jeffrey Epstein, No. 08-80381-CIV-MARRA (S.D. Fla.), Opinion and Order on Motion to Dismiss and Motion for More Definite Statement, entered February 12, 2009, EFTA02741750, pp. 11-12 (“Defendant’s motion to dismiss or for a more definite statement as to Count I is DENIED”; “Defendant’s motion to dismiss or for a more definite statement as to Count III is GRANTED IN PART AND DENIED IN PART. Defendant’s motion to dismiss is denied; however, Plaintiff must file another complaint, which includes a more definite statement as to Count III…”; “Defendant’s motion to strike the citation to 28 U.S.C. § 2255 in the Amended Complaint is GRANTED and that citation is hereby STRICKEN.”).

  9. Notice of Proposed Settlement of Class Action, Jane Doe 1 v. JPMorgan Chase Bank, N.A., No. 1:22-cv-10019-JSR (S.D.N.Y.), EFTA00146745, p. 5 (“THE COURT HAS NOT RULED AS TO WHETHER DEFENDANT IS LIABLE TO THE CLASS REPRESENTATIVE OR TO THE CLASS.”), p. 4 (allegations and general denial).

  10. Government of the United States Virgin Islands’ Stipulation of Dismissal, USVI v. JPMorgan Chase Bank, N.A., No. 22-cv-10904-JSR (S.D.N.Y.), Document 343, filed September 29, 2023, EFTA02818725, p. 1 (“Plaintiff the Government of the United States Virgin Islands submits this stipulation of dismissal of its claims against Defendant JPMorgan Chase Bank, N.A. The dismissal shall be with prejudice.”); Memorandum Order, same case, Document 366, June 28, 2024, EFTA02819006, p. 1 (recording the settlement for $75 million and the case closed October 18, 2023).

  11. U.S. Department of Justice, Office of Professional Responsibility, Report of Investigation, filed as Government Exhibit 3, Document 204-3 in United States v. Maxwell, No. 1:20-cr-00330-PAE (S.D.N.Y.), April 16, 2021, EFTA02830776, p. 194 (narrative p. 168), section IV.G. 2 3

  12. Same report, EFTA02830776, p. 128 (narrative p. 102).

  13. Same report, EFTA02830776, p. 39 (narrative p. 13).

  14. “GHISLAINE MAXWELL - DEPOSITION OUTLINE”, undated and unattributed, EFTA00794269, pp. 1-6; the questions quoted are numbers 5, 6, 7, 8 and 9 on p. 1. All six pages were read; the document carries no date, no author, no caption and no answers. 2

  15. FBI investigative-status summary, case 50D-NY-3027571, EFTA01684602, p. 2 (“Maxwell was indicted on 06/29/2020 and arrested on 07/02/2020. The Maxwell trial began on 11/28/2021. Maxwell was convicted on 12/29/2021 on 5 out of 6 counts. Maxwell was sentenced on 06/28/2022 to 20 years. In November 2024, the U.S. appeals court rejected Maxwell’s request for en banc review. Maxwell requested an appeals extension to 04/10/2025.”).

  16. FBI New York Field Office intelligence note, “Wealthy, Influential Individuals Involved in Sex Trafficking Likely Rely Primarily on Referrals and Career Enhancement Promises to Entice Victims, Representing an Expansion of Traditional Sex Trafficking Techniques”, 06 April 2022, EFTA00172536, p. 1. 2

  17. Same note, EFTA00172536, p. 5.

  18. Same note, EFTA00172536, p. 4, which names the earlier note by title and date.