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Government memo

Government memo

GRAND JURY PRESENTATION

OPERATION LEAP YEAR

Corner 4-10,12 7=9

I. INTRODUCTION

14-17, 7, 8

A. New Indictment

  1. Summarize Changes

  2. Summarize Current Charges

  3. Review Law/Instructions

  4. Go through legal allegations in introduction

B. Summarize How the Evidence Will Be Presented

  1. Chart

  2. Break Overt Acts into Two Categories:

a. Meetings/Sexual Activity – Grouped by victim – Testimony re Interviews with the Girls

b. Flights-Manifests

C. Take Questions

II. RETURN DOCUMENTS RECEIVED IN RESPONSE TO SUBPOENAS ISSUED SINCE THE LAST DOCUMENT RETURN.

D. Call Special Agent Kuyrkendall

A. Have additional subpoenas been issued on behalf of this grand jury regarding Operation Leap Year? And have documents been received in response to those subpoenas? What subpoenas were issued and what items were received? Did you bring those records with you today?

III. KUYRKENDALL SUBSTANTIVE TESTIMONY

A. Hand out summary chart

  1. Review renumbering of Jane Does

a. S/A Kuyrkendall: Can you explain to the grand jury how the Jane Does have been renumbered? (They were numbered to try to appear in a more chronological order depending on their

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EFTA00192670

first known contact with Mr. Epstein)

b. S/A Kuyrkendall: Which of these girls has the grand jury already heard testimony about?

  1. Go over how chart is organized

a. S/A Kuyrkendall: What does each column refer to?

  1. Generally review references to transcript pages

a. S/A Kuyrkendall: What does the list of transcript pages refer to? How was that list created?

B. Go through the allegations in the Introductory Section of the Indictment. Summarize evidence that hasn’t already been presented (I think just the high school allegations)

C. Hand out flight chart

  1. What does this chart refer to? What does each column mean?

  2. Flip to a few overt acts and read the text aloud. What is the evidence in support of these allegations? (Flight manifests)

  3. Remind the grand jury how the flight manifests were obtained.

  4. So, for each flight referenced in the overt acts, what evidence was relied upon? And did you bring those flight manifests with you? Let’s mark those manifests as Composite Grand Jury Exhibit Number JE-1.

  5. There are several dozen manifests contained within Exhibit JE-1. Have you marked in any way the manifests related to the flights referenced in the indictment? And in reviewing those manifests, what information will the grand jurors find? [Airplane used. Date. Departure airport. Arrival airport. Arrival time. Passenger names.]

D. Discuss telephone records

  1. Flip to a few overt acts and read the text aloud. What is the evidence in support of these allegations? (Telephone records)

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EFTA00192671

  1. Remind the grand jury how the telephone records were obtained and whose telephone records were obtained. Were there any records that you tried to obtain that you couldn’t?

  2. Have you pulled the telephone records that contain the telephone calls referred to in the indictment? And did you bring them with you? Have you marked in any way the telephone bills that reference the calls listed in the indictment? And in reviewing those billing records, what information will the grand juror’s find? (Telephone number called. Time and date of call. Call length.)

TAKE A BREAK BEGIN TESTIMONY REGARDING THE GIRLS

IV. JANE DOES 1 and 2

A. Who is Jane Doe #1?

  1. Has she been interviewed? In addition to her statements, who else provided information regarding Jane Doe #1?

  2. During what period of time did Jane Doe #1 have contact with JE?

  3. How did she meet JE?

  4. How old was she during that time frame?

  5. And what sexual activity was she involved in with JE?

  6. Did she recruit anyone to go to JE’s home?

B. Who is Jane Doe #2?

  1. Has she been interviewed? In addition to her statements, who else provided information regarding Jane Doe #2?

  2. During what period of time did Jane Doe #2 have contact with JE?

  3. How old was she during that time frame?

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EFTA00192672

  1. How did she meet JE?

  2. And what sexual activity was she involved in with JE?

  3. How much was she paid for performing sexual massages for JE?

  4. Did she recruit any of the other Jane Does to go to JE’s home?

  5. Please take us through the evidence supporting the overt acts related to Jane Doe #2.

  6. What did Jane Doe #2 say about whether JE knew her age?

  7. Who would contact Jane Doe #2 to make appointments? How would she be contacted?

  8. Does your testimony cover the evidence supporting the allegations in overt acts 1 through 18?

  9. Let’s refer to Count 2. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #2 to engage in commercial sex acts knowing that she was under 18?

JANE DOE #3 (W.)

A. Who is Jane Doe #3? Have you testified about her previously?

B. Has she been interviewed?

C. During what period of time did Jane Doe #3 have contact with JE?

D. How old was she during that time frame?

E. How did she meet JE?

F. And what sexual activity was she involved in with JE?

G. How much was she paid?

H. Did she recruit anyone to go to JE’s home? What did she tell you about

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EFTA00192673

JE’s recruiting requests? Were there girls whom Jane Doe #3 brought to Epstein’s home whom he didn’t like? Did he allow them to massage him?

I. Did he ever become frustrated when JD#3 wasn’t able to find a young girl for him?

J. Does your testimony cover the evidence supporting the allegations in overt acts 19 through 31?

K. Let’s refer to Count 12. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #3 to engage in prostitution and in sexual activity for which a person can be charged with a criminal offense? [Florida violations – Jane Doe #3 was under the age of 16 when she was involved with Epstein, so he could be charged with lewd and lascivious molestation, lewd and lascivious conduct, and lewd and lascivious exhibition based upon his touching of Jane Doe #3’s breasts and genitals, his solicitation of Jane Doe #3 to commit a lewd and lascivious act, and his masturbation and exposure of his genitals in her presence.]

VI. JANE DOES #4, 5, and 6 (H., C., and P.)

A. Who are Jane Does #4, 5, and 6? Have you testified about them previously?

B. Have they been interviewed? In addition to their statements, who else provided information regarding Jane Does #4, 5, and 6?

C. During what period of time did Jane Does #4, 5, and 6 have contact with JE?

D. How old were they during that time frame?

E. What sexual activity did Jane Does #4 and #5 engage in with JE?

F. Did either of them take anyone else to JE’s home?

G. What sexual activity was Jane Doe #6 involved in with JE?

H. Did she take anyone else to JE’s home?

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EFTA00192674

I. Does your testimony cover the evidence supporting the allegations in overt acts 32-45?

J. Let’s refer to Count 3. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #4 to engage in commercial sex acts knowing that she was under 18?

K. Let’s refer to Count 13. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #4 to engage in prostitution?

VII. TESTIMONY REGARDING GIRLS ALREADY COVERED IN GRAND JURY – JANE DOES 9, 10, 14, 15, 16 (Alex,

A. JANE DOE #9 (Alex H.)

  1. Who is Jane Doe #9? Have you testified about her previously?

a. Is there anything that you want to clarify or add regarding your earlier testimony?

  1. Please remind the grand jury, during what period of time did Jane Doe #9 have contact with JE?

  2. How old was she during that time frame?

  3. And please summarize the sexual activity that Jane Doe #9 was involved in with JE?

a. Was she involved in sexual activity with any of the other defendants?

  1. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 66-73, 75-77, 80-83, and 90?

  2. Let’s refer to Count 4. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #9 to engage in

Page 6 of 11

EFTA00192675

commercial sex acts knowing that she was under 18?

  1. Let’s refer to Count 15. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #9 to engage in prostitution and in sexual activity for which a person can be charged with an offense? How many telephone calls have you been able to document between Jane Doe #9 and Kellen?

  2. What was the activity for which a person could be charged with an offense [Vaginal intercourse between an adult over 24 and a 16 or 17 year old minor – violates Fl. Stat. 794.05]

B. JANE DOE #10 ( B.)

  1. Who is Jane Doe #10? Have you testified about her previously?

a. Is there anything that you want to clarify or add regarding your earlier testimony?

  1. Please remind the grand jury, during what period of time did Jane Doe #10 have contact with JE?

  2. How old was she during that time frame?

  3. Please summarize the sexual activity that Jane Doe #10 was involved in with JE?

  4. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 67, 74, 78-79, 81, 84-89, 147?

  5. Let’s refer to Count 5. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #10 to engage in commercial sex acts knowing that she was under 18?

  6. Let’s refer to Count 16. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #10 to engage in prostitution? How many telephone calls have you been able to

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EFTA00192676

document between Jane Doe #10 and Kellen?

VIII. OTHER BACKGROUND INFO

A. Background re defendants and intro section – February 6, 2007 NK Transcript and May 8, 2007 NK Transcript pp. 17-end.

B. ASK ABOUT ITEMS TO BE BROUGHT FOR FINAL PRESENTATION – MASSAGE BEDS!!!

C. JANE DOE #14 E.)

  1. Who is Jane Doe #14? Have you testified about her previously?

a. Is there anything that you want to clarify or add regarding your earlier testimony?

  1. Please remind the grand jury, during what period of time did Jane Doe #14 have contact with JE?

  2. How old was she during that time frame?

  3. Please summarize the sexual activity that Jane Doe #14 was involved in with JE?

  4. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 112-131?

  5. Let’s refer to Count 8. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #14 to engage in commercial sex acts knowing that she was under 18?

  6. Let’s refer to Count 19. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce, and entice Jane Doe #14 to engage in prostitution and in sexual activity for which a person can be charged with an offense? How many telephone calls have you been able to document between Jane Doe #9 and Kellen?

Page 8 of 11

EFTA00192677

a. How old was Jane Doe #14 during this period? And what is the sexual activity that she and JE engaged in that also violated Fl. Stat. 794.05? [Sexual intercourse btw adult over 24 and a minor.]

D. JANE DOE #15 (Z.)

  1. Who is Jane Doe #15? Have you testified about her previously?

a. Is there anything that you want to clarify or add regarding your earlier testimony?

  1. Please remind the grand jury, during what period of time did Jane Doe #15 have contact with JE?

  2. How old was she during that time frame?

  3. Please summarize the sexual activity that she was involved in with JE?

  4. Does your prior testimony and testimony here today cover the evidence supporting the allegations in overt acts 132-148, 175?

  5. Let’s refer to Count 9. Is the evidence you just summarized the basis for the allegation that JE, SK, and Adriana Ross procured Jane Doe #15 to engage in commercial sex acts knowing that she was under 18?

  6. Let’s refer to Count 20. Is the evidence you just summarized the basis for the allegation that JE, SK, and Adriana Ross used a facility of interstate commerce to persuade, induce, and entice Jane Doe #15 to engage in prostitution? How many telephone calls have you been able to document between Jane Doe #15 and Kellen? And how many telephone calls between Jane Doe #15 and Ross?

E. JANE DOE #16 ( D.)

  1. Who is Jane Doe #16? Have you testified about her previously?

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EFTA00192678

a. Is there anything that you want to clarify or add regarding your earlier testimony?

  1. Please remind the grand jury, during what period of time did Jane Doe #16 have contact with JE?

  2. How old was she during that time frame?

  3. Please summarize the sexual activity that Jane Doe #16 was involved in with JE?

  4. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 90,149-151,and 156-181?

  5. Let’s refer to Count 10. Is the evidence you just summarized the basis for the allegation that JE, SK, Adriana Ross, and Nadia Marcinkova procured Jane Doe #16 to engage in commercial sex acts knowing that she was under 18?

  6. Let’s refer to Count 21. Is the evidence you just summarized the basis for the allegation that JE, SK, Adriana Ross, and Nadia Marcinkova used a facility of interstate commerce to persuade, induce, and entice Jane Doe #16 to engage in prostitution and in sexual activity for which a person can be charged with an offense?

a. How many telephone calls have you been able to document between Jane Doe #16 and Kellen? Between Jane Doe #16 and Ross? And between Jane Doe #16 and Marcinkova?

  1. What was the sexual activity that Jane Doe #16 and JE engaged in that also violated Fl. Stat. 794.05? [Sexual intercourse between an adult over 24 and a minor]

IX. PRIOR DRUG USE/MENTAL HEALTH ISSUES

A. Today we have discussed 11 victims-Jane Does 1 through 6,9,10,and 14 through 16.Are you aware of whether any of them have used illicit drugs or have had mental health issues? Please summarize.

Page 10 of 11

EFTA00192679

B. Now, with respect to each of those girls, can you summarize for the grand jury your efforts to independently corroborate their statements? What physical evidence corroborates their statements to law enforcement?

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EFTA00192680

E. JANE DOE # 16

D.) and JANE DOE # 17

  1. Who is Jane Doe # 16? Have you testified about her previously?

a. Is there anything that you want to clarify or add regarding your earlier testimony?

  1. Please remind the grand jury, during what period of time did Jane Doe #16 have contact with JE?

  2. How old was she during that time frame?

  3. Please summarize the sexual activity that Jane Doe #16 was involved in with JE?

  4. Did Jane Doe #16 recruit anyone to go to JE’s home?

JANE DOE # 17

  1. Who is Jane Doe # 17? Have you testified about her previously?

  2. Has she been interviewed?

  3. During what period of time did Jane Doe #17 have contact with JE?

  4. How old was she during that time frame?

  5. How did she meet JE?

  6. And what sexual activity was she involved in with JE?

  7. How much was she paid?

  8. Did she recruit anyone to go to JE’s home?

JANE DOE # 16

D.) and JANE DOE # 17

  1. Does your prior testimony and your testimony today cover the evidence supporting the allegations and overt acts 90, 149-151 and 156-181?

  2. Let’s refer to Count 10. Is the evidence you just summarized the basis for the allegation that JE, SK, AR and NM procured Jane Doe # 16 to engage in commercial sex acts knowing that she was under 18?

  3. Let’s refer to Count 21. Is the evidence you just summarized the basis for the allegation that JE, SK, AR and NM used a facility of interstate commerce to

EFTA00192681

persuade, induce and entice Jane Doe # 16 to engage in prostitution and in sexual activity for which a person can be charged with an offense?

a. How many telephone calls have you been able to document between Jane Doe #16 and Kellen? Between Jane Doe #16 and Ross? And between Jane Doe #16 and Marcinkova?

  1. What was the sexual activity that Jane Doe # 16 and JE engaged in that also violated Fl. Stat. 794.05? (Sexual intercourse between an adult over 24 and a minor)

  2. Does your prior testimony and your testimony today cover the evidence supporting the allegations and overt acts 150-155?

  3. Let’s refer to Count 22. Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe #17 to engage in prostitution and in sexual activity for which a person can be charged with an offense?

EFTA00192682

F. JANE DOE # 7 (L.)

  1. Who is Jane Doe # 7? Have you testified about her previously?

  2. Has she been interviewed?

  3. During what period of time did Jane Doe # 7 have contact with JE?

  4. How old was she during that time frame?

  5. How did she meet JE?

  6. And what sexual activity was she involved in with JE?

  7. How much was she paid?

  8. Did she recruit anyone to go to JE’s home?

  9. Does your testimony cover the evidence supporting the allegations in overt acts 46,47,54,57,59-64?

  10. Let’s refer to Count 14 Is the evidence you just summarized the basis for the allegation that JE and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe #7 to engage in prostitution and in sexual activity for which a person can be charged with an offense? How many telephone calls have you been able to document between Jane Doe #7 and Kellen?

  11. Did Tatum Miller recruit anyone else

EFTA00192683

G. JANE DOE # 8 E.)

  1. Who is Jane Doe # 8? Have you testified about her previously?

  2. Has she been interviewed?

  3. During what period of time did Jane Doe # 8 have contact with JE?

  4. How old was she during that time frame?

  5. How did she meet JE?

  6. And what sexual activity was she involved in with JE?

  7. How much was she paid?

  8. Did she recruit anyone to go to JE’s home?

  9. Does your testimony cover the evidence supporting the allegations in overt acts 49-53, 55, 65?

Ct 14

9 calls btwn SK

EFTA00192684

H. JANE DOE # 12

  1. Who is Jane Doe # 12? Have you testified about her previously?

  2. Has she been interviewed?

  3. During what period of time did Jane Doe #12 have contact with JE?

  4. How old was she during that time frame?

  5. How did she meet JE?

  6. And what sexual activity was she involved in with JE?

  7. How much was she paid?

  8. Did she recruit anyone to go to JE’s home?

  9. Does your testimony cover the evidence supporting the allegations in overt acts 96, 98-104?

  10. Let’s refer to Count 06. Is the evidence you just summarized the basis for the allegation that JE, and SK procured Jane Doe # 12 to engage in commercial sex acts knowing that she was under 18?

  11. Let’s refer to Count 17. Is the evidence you just summarized the basis for the allegation that JE, and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe # 12 to engage in prostitution and in sexual activity for which a person can be charged with an offense?

a. How many telephone calls have you been able to document between Jane Doe #12 and Kellen?

EFTA00192685

I. JANE DOE # 13 (N.)

  1. Who is Jane Doe # 13? Have you testified about her previously?

  2. Has she been interviewed?

  3. During what period of time did Jane Doe #13 have contact with JE?

  4. How old was she during that time frame?

  5. How did she meet JE?

  6. And what sexual activity was she involved in with JE?

  7. How much was she paid?

  8. Did she recruit anyone to go to JE’s home?

  9. Does your testimony cover the evidence supporting the allegations in overt acts 96, 97, 104-111?

  10. Let’s refer to Count 07. Is the evidence you just summarized the basis for the allegation that JE, and SK procured Jane Doe # 13 to engage in commercial sex acts knowing that she was under 18?

  11. Let’s refer to Count 18. Is the evidence you just summarized the basis for the allegation that JE, and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe # 13 to engage in prostitution and in sexual activity for which a person can be charged with an offense?

a. How many telephone calls have you been able to document between Jane Doe #13 and Kellen?

EFTA00192686

J. JANE DOE # 18

  1. Who is Jane Doe # 18? Have you testified about her previously?

  2. Has she been interviewed?

  3. During what period of time did Jane Doe #18 have contact with JE?

  4. How old was she during that time frame?

  5. How did she meet JE?

  6. And what sexual activity was she involved in with JE?

  7. How much was she paid?

  8. Did she recruit anyone to go to JE’s home?

  9. Does your testimony cover the evidence supporting the allegations in overt acts 182-188, 190?

  10. Let’s refer to Count 23. Is the evidence you just summarized the basis for the allegation that JE, and SK used a facility of interstate commerce to persuade, induce and entice Jane Doe #18 to engage in prostitution and in sexual activity for which a person can be charged with an offense?

a. How many telephone calls have you been able to document between Jane Doe #18 and Kellen?

EFTA00192687

K. JANE DOE # 19

  1. Who is Jane Doe # 19? Have you testified about her previously?

  2. Has she been interviewed?

  3. During what period of time did Jane Doe #19 have contact with JE?

  4. How old was she during that time frame?

  5. How did she meet JE?

  6. And what sexual activity was she involved in with JE?

  7. How much was she paid?

  8. Did she recruit anyone to go to JE’s home?

  9. Does your testimony cover the evidence supporting the allegations in overt acts 189-190?

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