EFTA00028489 UNITED STATES DISTRICT COURT .SOUTHERN DISTRICT OF NEW YORK. UNITED. STATES OF AMERICA SEALED INDICTMENT CRIM 19 Cr. JEFFREY EPSTEIN, Defendant. # COUNT ONE (Sex Trafficking Conspiracy) x The Grand Jury charges: #### OVERVIEW 1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and abused dozens of minor girls at his homes in Manhattan, New York, and Palm Beach, Florida, among other locations. 2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defehdant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residonce") to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. Moreover, and in order to maintain and increase his supply of victims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In recruited, dozens of minor girls to engage in sex acts with him, after which EPSTEIN paid the victims hund*Oda of dollars in cash, at the, New York Residence and the Palm Beach Residence. 7: In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to EPSTEIN, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts. EPSTEIN paid his victims hundreds of dollars in cash for each encounter. Moreover, EPSTEIN actively encouraged certain of his victims' to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN. In so doihg, EPSTEIN maintained a steady supply of new victims to exploit. #### The New York Residence 8. At all times relevant to this Indictment, JEFFREY EPSTEIN, the defendant, possessed and controlled a multi-story private residence on the Upper East Side of Manhattan, New York, i.e., the New York Residence. Between at least in or about 2002 and in or about 2005, ONTEIN abused numerous minor victims at . . the New York Residence by causing these victims to be recruited to engage in paid sex acts with him. 3 employees and associates, including a New York-based employee ("Employee-1"), to communicate with victims via phone to arrange for these victims to return to the New York Residence for additional sexual encounters with EPSTEIN. 12. Additionally, and to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain of his victims to recruit additional girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another girl for EPSTEIN, he paid both the victim-recruiter and the new victim hundreds of dollars in cash. Through these victimrecttiters, EPSTEIN gained access to and was able to abuse dozens of additional minor girls. 13. In particular, certain recruiters brought dozens of additional minor girls to the New York Residence to give massages to and engage in sex acts with JEFFREY EPSTEIN, the defendant. EPSTEIN encouraged victims to recruit additiona'l girls by offering to pay these victim-recruiters for every additional girl they brought to EPSTEIN. When a victimrecruiter accompanied a new minor victim to the New York Residence, both the victim-recruiter and the new minor victim were paid hundreds of dollars by EPSTEIN for each encounter. In addition, certain victim-recruiters routinely scheduled these 5 to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. 16. In connection with each sexual encounter) JEFFREY EPSTEIN, the defendant or one of his employees or associates, paid the victim in cash. Victims of dollars for each encounter. typically were paid hundreds 17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based::.. victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions. 18. JEFFREY EPSTEIN, the defendant, who during the releVant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived: In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At-' the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters. commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2). #### Overt Acts 22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter. b. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully. c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed g. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to. Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage'in paid sex eats with EPSTEIN. h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with' EPSTEIN. (Title 18, United States Code, Section 371.) #### COUNT TWO (Sex Trafficking) The Grand Jury further charges: 23. The allegations contained in paragraphs'l through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within. 24. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the'defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous 11 # Substitute Asset Provision 26. If any of the abovea-described forfeitable property, as a result of any act or omission of the defendant: - (a) cannot be located upon the ekerciee of due diligence; - (b) hat been transferred or sold to, or deposited with; a third person; - (c) has been placed beyond the jurisdictional the. Court; - (d),bas been Substantially diminished in value; or - .(e) has been commingled with other propetty which cannot .be subdivided without difficulty; it as the intent of the United States, pursuant to 21 U.S.C. \$ 853(p) and 28 U.S.C.' \$ 2461(c), to seek forfeiture of any other propetty of the defendant up to the value of the above forfeitable property.. (Title 18, United States Code, Section 1594; Title 21, United States Code, Section 85S(p); and, Title 28, United States Code, Section 2461.) 13 A lt GEOPER Y . BERMAN United States Attorney # EXHIBIT B #### ATTACHMENT A # I. Premises to be Searched—Subject Premises 1. The premises to be searched (the "Subject Premises") are described as a multi-story single-family residence located at New York, New York, and include all locked and closed containers found therein. A photograph of the front entrance to the Subject Premises is included below: # II. Items to Be Seized ## A. Evidence, Fruits, and Instrumentalities of the Subject Offenses This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: - i. Any and all taxidermied dogs. - ii. Any and all massage tables and massage paraphernalia. - iii. Any and all busts or three-dimensional representations of female human torsos. - iv. Any and all photos or representations depicting nude or partially nude women located in the Massage Room, as defined herein. - v. Any and all sex toys and sex paraphernalia located in the Massage Room, as defined herein. 2017.08.02