The Epstein Index

Keyboard shortcuts

/
Search the files
j k
Move through a list of results
[ ]
Previous or next document
g g · G
Top or bottom of the page
Esc
Leave a search field or close this box
?
Show this box

Go to a page: g then

h
Index
t
Timeline
p
People
r
Redactions
x
Explore
w
News
l
Legislation
a
About

Court filing · April 25, 2008

2008 federal sex trafficking indictment of Jeffrey Epstein and three assistants

Southern District of Florida grand jury indictment charging Jeffrey Epstein, an associate, an associate, and an associate with sex trafficking and related federal offenses, with forfeiture allegations.Machine-written summary

EFTA00192690

1. Defendant JEFFREY EPSTEIN employed defendants SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA to perform, among other things, services as personal assistants.

BACKGROUND

At all times relevant to this Indictment:

The Grand Jury charges that:

INDICTMENT

Defendants.

JEFFREY EPSTEIN,

SARAH KELLEN,

ADRIANA ROSS, a/k/a “Adriana Mucinska,”

and NADIA MARCINKOVA,

VS.

UNITED STATES OF AMERICA

18 U.S.C. § 2423(b)

18 U.S.C. § 2423(d)

18 U.S.C. § 2423(e)

18 U.S.C. § 2422(b)

18 U.S.C. § 1591(a)(2)

18 U.S.C. § 1591(a)(1)

18 U.S.C. § 371

Case No:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

4/25/08

EFTA00192691

2

  1. Defendant JEFFREY EPSTEIN employed L.G. to perform, among other things, services as a personal assistant.

  2. Defendants JEFFREY EPSTEIN and SARAH KELLEN paid T.M., H.R., and A.F. to perform, among other things, recruiting services.

  3. Defendant JEFFREY EPSTEIN owned a property located at 358 El Brillo Way, Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as “358 El Brillo Way”).

  4. Defendant JEFFREY EPSTEIN owned a property located at 9 East 71st Street, New York, New York (hereinafter referred to as “the New York residence”).

  5. Defendant JEFFREY EPSTEIN was the principal owner of JEGE, INC., a Delaware corporation. JEGE, INC.’s sole business activities related to the operation and ownership of a Boeing 727-31 aircraft bearing tail number N908JE.

  6. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of JEGE, INC., and had the power to direct all of its operations.

  7. Defendant JEFFREY EPSTEIN was the principal owner of Hyperion Air, Inc., a Delaware corporation. Hyperion Air, Inc.’s sole business activities related to the operation and ownership of a Gulfstream G-1159B aircraft bearing tail number N909JE.

  8. Defendant JEFFREY EPSTEIN served as president, sole director, and sole shareholder of Hyperion Air, Inc., and had the power to direct all of its operations.

EFTA00192692

  1. Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult “who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious molestation,” which is a felony of the second degree if the victim is 12 years of age or older but less than 16 years of age.

  2. Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult “who [i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or [s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or lascivious conduct,” which is a felony of the second degree.

  3. Pursuant to Florida Statutes Section 794.05, a “person 24 years of age or older who engages in sexual activity with a person 16 or 17 years of age commits a felony of the second degree.” For purposes of “this section, ‘sexual activity’ means oral, anal, or vaginal penetration by, or union with, the sexual organ of another; however, sexual activity does not include an act done for a bona fide medical purpose.” Florida Statutes Section 794.021 states that “ignorance of the age [of the victim] is no defense,” and that neither “misrepresentation of age by [the victim] nor a bona fide belief that such person is over the specified age [shall]

EFTA00192693

medical license.

  1. Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult “who: (1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious manner; or (3) [i]ntentionally commits any other sexual act that does not involve actual physical or sexual contact with the victim, including, but not limited to … the simulation of any act involving sexual activity in the presence of a victim who is less than 16 years of age, commits lewd or lascivious exhibition,” which is a felony of the second degree.

  2. Pursuant to Florida Statutes Section 800.04(2), “[n]either the victim’s lack of chastity nor the victim’s consent is a defense to the crimes proscribed by [Section 800.04].”

  3. Pursuant to Florida Statutes Section 800.04(3), “[t]he perpetrator’s ignorance of the victim’s age, the victim’s misrepresentation of his or her age, or the perpetrator’s bona fide belief of the victim’s age cannot be raised as a defense in a prosecution under [Section 800.04].”

  4. Pursuant to Florida Statutes Section 800.02, a “person who commits any unnatural and lascivious act with another person commits a misdemeanor of the second degree.”

  5. Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any medical license

EFTA00192694

5

  1. During the period of her involvement with the Defendants, Jane Doe #1 attended Wellington High School and Palm Beach Central High School in Palm Beach County.

  2. During the period of her involvement with the Defendants, Jane Doe #5 attended Wellington High School in Palm Beach County.

  3. During the period of their involvement with the Defendants, Jane Does # 6, 8 and 12 attended Palm Beach Central High School in Palm Beach County.

  4. During the period of her involvement with the Defendants, Jane Doe #7 attended William T. Dwyer High School in Palm Beach County.

  5. During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 17, 18, and 19 attended Royal Palm Beach High School in Palm Beach County.

  6. During the period of her involvement with the Defendants, Jane Doe #10 attended Lake Worth High School in Palm Beach County.

  7. During the period of her involvement with the Defendants, Jane Doe #11 attended the Professional Performing Arts School, a public high school, located in New York, New York.

  8. During the period of her involvement with the Defendants, Jane Doe #13 attended John I. Leonard High School in Palm Beach County.

EFTA00192695

9

  1. It was the purpose and object of the conspiracy to procure females under the age of 18 to travel to 358 El Brillo Way and the New York residence so that JEFFREY EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females in order to satisfy JEFFREY EPSTEIN’s prurient interests.

Purpose and Object of the Conspiracy

violation of Title 18, United States Code, Section 2422(b).

did knowingly and willfully combine, conspire, confederate and agree with each other and with others known and unknown to commit an offense against the United States, that is, to use a facility or means of interstate or foreign commerce to knowingly persuade, induce, and entice individuals who had not attained the age of 18 years to engage in prostitution, in violation of Title 18 United States Code. Section 2422(b).

JEFFREY EPSTEIN,

SARAH KELLEN,

ADRIANA ROSS, a/k/a “Adriana Mucinska,”

and

NADIA MARCINKOVA,

Florida, and elsewhere, the Defendants,

through in or around October 2005, in Palm Beach County, in the Southern District of

  1. From at least as early as 2001, the exact date being unknown to the Grand Jury,

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
COUNT1
(Conspiracy: 18 U.S.C.§371)

EFTA00192696

$$ L $$

to accomplish the purpose and object of the conspiracy included the following:

(a) It was part of the conspiracy that Defendants SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” NADIA MARCINKOVA, and other participants would contact minor females via the use of cellular and other telephones to arrange appointments for minor females to travel to 358 El Brillo Way and the New York residence to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them.

(b) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, SARAH KELLEN, and ADRIANA ROSS, a/k/a “Adriana Mucinska,” NADIA MARCINKOVA, and other participants would make payments to, or cause payments to be made to, minor females in exchange for engaging in lewd conduct.

(c) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and other participants would ask females to recruit other minor females to engage in lewd conduct with Defendant JEFFREY EPSTEIN.

(d) It was further a part of the conspiracy that Defendants JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and other participants would make payments to, or cause payments to be made to, the recruitors for

  1. The manner and means by which the Defendants and other participants sought to accomplish the purpose and object of the conspiracy included the following:

Manner and Means

EFTA00192697

JL 8

(4) In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, who was then fourteen years’ old, to pinch his nipples while he masturbated.

(2) In or around 2001, Defendant SARAH KELLEN led Jane Doe #2 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN’s bedroom at 358

(1) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity with Jane Doe #1, who was then a seventeen-year-old girl, in the presence of Jane Doe #2, who was then a fourteen-year-old girl.

Jane Does #1 and #2

  1. In furtherance of this conspiracy and to effect the objects thereof, there was committed by at least one of the co-conspirators herein, at least one of the following overt acts, among others, in the Southern District of Florida, and elsewhere:

Overt Acts

(e) It was further a part of the conspiracy that Defendant JEFFREY EPSTEIN would pay minor females to engage in lewd conduct with Defendant NADIA MARCINKOVA to satisfy Defendant JEFFREY EPSTEIN’s prurient interests.

bringing additional minor females to 358 El Brillo Way and the New York residence to engage in lewd conduct with Defendant JEFFREY EPSTEIN.

EFTA00192698

(11) In or around 2003, Defendant SARAH KELLEN took nude photographs of Jane Doe #2, who was then a sixteen-year-old girl.

(5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2.

(6) In or around 2001, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way.

(7) In or around 2001, JEFFREY EPSTEIN engaged in sexual intercourse with an unidentified female in the presence of Jane Doe #2, who was then a fourteen-year-old girl.

(8) In or around 2001, Defendant JEFFREY EPSTEIN paid $300 to Jane Doe #2, who was then a fourteen-year-old girl, for allowing an unidentified female to perform oral sex on Jane Doe #2 in EPSTEIN’s presence.

(9) On or about March 11, 2003, an employee of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN’s review regarding a telephone call received from Jane Doe #2.

(10) In or around 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #2 if she had any younger friends who would be interested in engaging in similar activities with him.

EFTA00192699

10

(19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #3, who was then a fifteen-year-old girl.

(17) On or about April 23, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #2.

(18) On or about May 2, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #2.

(14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #2, who was then a sixteen-year-old girl.

(15) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #2, who was then a sixteen-year-old girl.

(16) In or around 2003, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #2 to make an appointment for Jane Doe #2 to travel to 358 El Brillo Way.

(12) In or around 2003, Defendant SARAH KELLEN made a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs.

(13) In or around 2003, Defendant SARAH KELLEN told Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked KELLEN to take nude photographs of Jane

EFTA00192700

(20) In or around 2003, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3.

(21) On or about October 26, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #3.

(22) On or about October 30, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #3.

(23) In or around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe #3, who was then a sixteen- or seventeen-year-old girl, to straddle an adult female and to touch the adult female’s breasts.

(24) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of an adult female in the presence of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl.

(25) In or around 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #3.

(26) In or around 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #3 to rub his nipples.

(27) In or around 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl.

EFTA00192701

12

(32) In or around the first half of 2004, Defendant SARAH KELLEN led Jane Doe #4 and Jane Doe #5 to Defendant JEFFREY EPSTEIN’s bedroom at 358 El Brillo Way.

(33) In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age.

Jane Does #4, #5, and #6

(30) On or about January 14,2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #3.

(31) On or about January 29,2005, one of Defendant JEFFREY EPSTEIN’s employees prepared a written telephone message for Defendant JEFFREY EPSTEIN’s review regarding a telephone call received from Jane Doe #3 that read: “I have a female for him.”

(28) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 to recruit additional females to come to 358 El Brillo Way.

(29) On or about November 8, 2004, one of Defendant JEFFREY EPSTEIN’s employees prepared a written telephone message for Defendant JEFFREY EPSTEIN’s review regarding a telephone call received from Jane Doe #3 that read: “I have a female for him.”

EFTA00192702

13

(34) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #4, who was then a seventeen-year-old girl, and Jane Doe #5, who was then a seventeen-year-old girl.

(35) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to play with his nipples.

(36) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4, who was then a seventeen-year-old girl, to remove her clothing.

(37) In or around the first half of 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #4, who was then a seventeen-year-old girl.

(38) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #4.

(39) In or around the first half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #5.

(40) In or around the first half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #6 what high school she attended.

(41) In or around the first half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #4 to leave so that Jane Doe #6 could massage him alone.

EFTA00192703

14

telephone call to a telephone used by T.M.

(46) In or around July 2004, Defendant JEFFREY EPSTEIN led T.M., who was then a fifteen-year-old girl, and Jane Doe #7, who was then a sixteen-year-old girl, from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN’s bedroom at 358 El Brillo Way.

(47) On or about July 4, 2004, Defendant SARAH KELLEN made one or more telephone calls to a telephone used by Jane Doe #7.

(48) On or about July 5, 2004, Defendant SARAH KELLEN placed a call to a telephone used by T.M.

Jane Does #7 and #8

caused a payment of $200 to be paid to Jane Doe #6.

(45) In or around the first half of 2004, Defendant JEFFREY EPSTEIN

sixteen-year-old girl.

(44) In or around the first half of 2004, Defendant JEFFREY EPSTEIN placed a large vibrating massager on the vagina of Jane Doe #6, who was then a

(42) In or around the first half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #6, who was then a sixteen-year-old girl.

(43) In or around the first half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #6, who was then a sixteen-year-old girl.

EFTA00192704

15

(49) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #8, who was then a seventeen-year-old girl.

(50) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #8, who was then a seventeen-year-old girl.

(51) In or around July 2004, Defendant JEFFREY EPSTEIN paid approximately $200 to Jane Doe #8.

(52) In or around July 2004, Defendant JEFFREY EPSTEIN paid $200 to T.M. for recruiting Jane Doe #8 to travel to 358 El Brillo Way.

(53) In or around July 2004, Defendant SARAH KELLEN told Jane Doe #8 that Defendant JEFFREY EPSTEIN would pay Jane Doe #8 if she returned with a friend.

(54) On or about July 15, 2004, Defendant SARAH KELLEN placed one or more telephone calls to a telephone used by Jane Doe #7.

(55) On or about July 15, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #8.

(56) On or about July 15, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by T.M.

(57) On or about July 16, 2004, Defendant SARAH KELLEN placed one or more telephone calls to a telephone used by Jane Doe #7.

EFTA00192705

16

(58) On or about July 16, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by T.M.

(59) On or about July 17, 2004, one of Defendant JEFFREY EPSTEIN’s employees prepared a written telephone message for Defendant JEFFREY EPSTEIN’s review regarding a telephone call received from T.M. that read: “Me & [Jane Doe #7] can come tomorrow any time or [T.M.] alone”.

(60) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #7, who was then a sixteen-year-old girl.

(61) In or around July 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #7, who was then a sixteen-year-old girl, to rub his nipples.

(62) In or around July 2004, Defendant JEFFREY EPSTEIN stroked the vagina of Jane Doe #7, who was then a sixteen-year-old girl.

(63) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #7.

(64) In or around July 2004, Defendant JEFFREY EPSTEIN told Jane Doe #7 that if she reported to anyone what had occurred at Defendant JEFFREY EPSTEIN’s home, bad things could happen to her.

(65) On or about July 24, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #8.

EFTA00192706

17

telephone call to a telephone used by Jane Doe #10.

(74) On or about July 22, 2004, Defendant SARAH KELLEN placed a

(66) On or about July 15, 2004, Defendant SARAH KELLEN placed one or more telephone calls to a telephone used by Jane Doe #9.

(67) On or about July 16, 2004, Defendant SARAH KELLEN caused Jane Doe #9 to make one or more telephone calls to a telephone used by Jane Doe #10.

(68) On or about July 17, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #9.

(69) On or about July 18, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #9.

(70) On or about July 22, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #9.

(71) In or around July 2004, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #9, who was then a seventeen-year-old girl.

(72) In or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #9, who was then a seventeen-year-old girl.

(73) In or around July 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #9.

Jane Does #9 and #10

EFTA00192707

18

(75) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and NADIA MARCINKOVA engaged in oral sex and sexual intercourse in the presence of Jane Doe #9, who was then a seventeen-year-old girl.

(76) In or around the last half of 2004, Defendant JEFFREY EPSTEIN forcibly inserted his penis into the vagina of Jane Doe #9, who was then a seventeen-year-old girl.

(77) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #9.

(78) In or around the last half of 2004, Defendant JEFFREY EPSTEIN rubbed the vagina of Jane Doe #10, who was then a seventeen-year-old girl.

(79) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #10.

(80) On or about November 28, 2004, Defendant JEFFREY EPSTEIN arranged for one of his employees to provide an envelope filled with cash to Jane Doe #9.

(81) On or about December 4, 2004, Defendant SARAH KELLEN provided a written message to Defendant JEFFREY EPSTEIN regarding Jane Does #9 and 10, stating: “[Jane Doe #10] would like to work @ 4:00 pm if possible. [[Jane Doe #9]] is scheduled for 5:00 today.] the movie is @ 7:30”.

(82) On or about December 29, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #9.

EFTA00192708

19

(83) On or about December 30, 2004, Defendants JEFFREY EPSTEIN and SARAH KELLEN caused the purchase of Broadway tickets as an eighteenth birthday gift for Jane Doe #9.

(84) In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #10, who was then a seventeen-year-old girl.

(85) In or around the last half of 2004 or January 2005, Defendant JEFFREY EPSTEIN fondled the breasts of Jane Doe #10, who was then a seventeen-year-old girl.

(86) On or about January 14, 2005, Defendant SARAH KELLEN placed one or more telephone calls to a telephone used by Jane Doe #10.

(87) On or about January 27, 2005, Defendant ADRIANA ROSS, a/k/a “Adriana Mucinska,” placed one or more telephone calls to a telephone used by Jane Doe #10.

(88) On or about January 28, 2005, Defendant SARAH KELLEN placed one or more telephone calls to a telephone used by Jane Doe #10.

(89) On or about February 1, 2005, Defendant NADIA MARCINKOVA placed one or more telephone calls to a telephone used by Jane Doe #10.

(90) In or around February 2005, Defendant JEFFREY EPSTEIN caused a payment of $200 to be made to Jane Doe #9 for recruiting Jane Doe #16 to travel to 358 El Brillo Way.

EFTA00192709

20

(96) On or about August 2, 2004, an employee of Defendant JEFFREY EPSTEIN prepared a written telephone message for Defendant JEFFREY EPSTEIN’s review regarding a telephone call received from T.M. and Jane Doe #12 that stated: “They are available all weekend and maybe [Jane Doe #13] too”.

telephone call to a telephone used by Jane Doe #11.

Jane Does #12 and #13

(95) On or about June 22, 2005, Defendant SARAH KELLEN placed a

when she would be getting more girls.

(94) On or about April 5, 2005, one of Defendant JEFFREY EPSTEIN’s employees prepared a written message for Defendant JEFFREY EPSTEIN’s review regarding a telephone call received from Jane Doe #11 that read: “Re does she have any new friends you can meet – I was away over the weekend so I have not spoken to anyone new. But, [unidentified Jane Doe] will be around later today and I know she really wants to work. The others should be back around Thursday. Let me know about [unidentified Jane Doe].”

(93) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #11

(91) In or around 2004, Defendant JEFFREY EPSTEIN told Jane Doe #11 that he would pay her to find and bring him more girls.

(92) In or around 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #11 for recruiting a minor female to travel to his New York home.

(93) In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #11

Jane Doe #11

EFTA00192710

21

(105) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #13, who was then a seventeen-year-old girl.

(104) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and SARAH KELLEN caused Jane Doe #12 to recruit Jane Doe #13 to travel to 358 El

(103) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #12 that he would take her to Los Angeles when she turned eighteen.

(102) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #12, who was then a seventeen-year-old girl, about her age.

a payment of $200 to Jane Doe #12.

(101) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made

a seventeen-year-old girl.

(100) In or around the last half of 2004, Defendant JEFFREY EPSTEIN attempted to place a massaging device on the vagina of Jane Doe #12, who was then

(97) On or about August 21, 2004, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #13.

(98) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #12, who was then a seventeen-year-old girl.

(99) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #12, who was then a seventeen-year-old girl.

EFTA00192711

Jane Doe #14

(112) In or around the last half of 2004, Defendant SARAH KELLEN led Jane Doe #14 from the kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN’s bedroom at 358 El Brillo Way.

(113) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #14 to provide her telephone number.

(111) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13 to bring her friends to his home, especially “girls who looked like [Jane Doe #13].”

(110) In or around the last half of 2004, Defendant JEFFREY EPSTEIN told Jane Doe #13 that he wanted to take her to Paris but he could not because Jane Doe #13 was not yet eighteen years old.

(109) In or around the last half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13, who was then a seventeen-year-old girl, about her age.

(108) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #13, who was then a seventeen-year-old girl.

a payment of $200 to Jane Doe #13.

(107) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made

old girl.

(106) In or around the end of 2004, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #13, who was then a seventeen-year-

EFTA00192712

23

(121) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doe #14, who was then a seventeen-year-old

(120) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #14, who was then a seventeen-year-old girl.

(119) On or about December 23, 2004, Defendant JEFFREY EPSTEIN caused a Western Union wire transfer order to be sent to Jane Doe #14.

not yet turned eighteen.

(118) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #14, who was then a seventeen-year-old girl, whether she had any plans for her eighteenth birthday and acknowledged that she had

year-old girl.

(117) In or around the end of 2004 and the beginning of 2005, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #14, who was then a seventeen-

a payment of $300 to Jane Doe #14.

(114) In or around the last half of 2004, Defendant JEFFREY EPSTEIN instructed Jane Doe #14, who was then a seventeen-year-old girl, to pinch his nipples.

(115) In or around the last half of 2004, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #14, who was then a seventeen-year old girl.

(116) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made

EFTA00192713

24

(122) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN performed oral sex on Jane Doe #14, who was then a seventeen-year-old girl.

(123) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $600 to Jane Doe #14.

(124) On or about January 8, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #14.

(125) On or about January 9, 2005, Defendant ADRIANA ROSS, a/k/a “Adriana Mucinska,” placed a telephone call to a telephone used by Jane Doe #14.

(126) On or about January 26, 2005, one of Defendant JEFFREY EPSTEIN’s employees prepared a written telephone message for Defendant ADRIANA ROSS’s review regarding a call received from Jane Doe #14 that read: “She is confirming for 5:30”.

(127) On or about January 26, 2005, Defendant ADRIANA ROSS, a/k/a “Adriana Mucinska,” placed a telephone call to a telephone used by Jane Doe #14.

(128) On or about February 1, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #14.

(129) On or about March 1, 2005, Defendant ADRIANA ROSS, a/k/a “Adriana Mucinska,” placed a telephone call to a telephone used by Jane Doe #14.

(130) On or about March 21, 2005, Defendant ADRIANA ROSS, a/k/a “Adriana Mucinska,” placed a telephone calls to a telephone used by Jane Doe #14.

EFTA00192714

25

(138) On or about January 7, 2005, Defendant ADRIANA ROSS, a/k/a “ADRIANA MUCINSKA,” placed a telephone call to a telephone used by Jane Doe

fondled the breasts of Jane Doe #15.

(137) In or around the first half of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #15.

(135) In or around the first half of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #15, who was then a seventeen-year-old girl, to pinch his nipples

Jane Doe #15

(131) On or about March 29, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #14.

EFTA00192715

26

(139) On or about February 4, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #15.

(140) On or about February 10, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #15.

(141) On or about February 21, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #15.

(142) On or about February 24, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #15.

(143) On or about March 17, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #15.

(144) On or about March 30, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #15.

(145) On or about March 31, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #15.

(146) On or about March 31, 2005, Defendant ADRIANA ROSS, a/k/a “Adriana Mucinska,” placed a telephone call to a telephone used by Jane Doe #15.

(147) On or about April 1, 2005, one of Defendant JEFFREY EPSTEIN’s employees prepared a note for Defendant JEFFREY EPSTEIN’s review that read: “10:30 [Jane Doe #15]/[Jane Doe #10] on Fri around 2’Oclock”.

(148) In or around June 2005, Defendant JEFFREY EPSTEIN provided Jane Doe #15 with a gift of Secret lingerie for her eighteenth birthday.

EFTA00192716

27

(155) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #17, who was then a sixteen-year-old girl.

(154) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #17, who was then a sixteen-year-old girl.

year-old girl.

clothing.

(152) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #17, who was then a sixteen-year-old girl.

(153) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN instructed Jane Doe #17, who was then a sixteen-year-old girl, to remove all of her

to 358 El Brillo Way.

(151) In or around the first quarter of 2005, Defendant JEFFREY EPSTEIN caused a payment to be made to Jane Doe #16 for recruiting Jane Doe #17 to travel

to ask her to travel to 358 El Brillo Way.

(149) In or around February 2005, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #16, who was then a seventeen-year-old girl.

(150) In or around the first quarter of 2005, Defendants JEFFREY EPSTEIN and SARAH KELLEN caused Jane Doe #16 to place a telephone call to Jane Doe #17

Jane Does #16 & #17

EFTA00192717

28

(163) On or about May 19, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #16.

tomorrow at 4pm.”

telephone call to a telephone used by Jane Doe #16.

(162) On or about April 11, 2005, Defendant SARAH KELLEN left a message for Defendant JEFFREY EPSTEIN stating: “[Jane Doe #16] can work

(159) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, to touch the

(158) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN engaged-in sexual activity with Defendant NADIA MARCINKOVA in the presence of Jane Doe #16, who was then a seventeen-year-old girl.

(157) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN asked Jane Doe #16, who was then a seventeen-year-old girl, how old she was, and she responded that she was seventeen years old.

a seventeen-year-old girl.

(156) In or around the first nine months of 2005, Defendant JEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #16, who was then

EFTA00192718

29

(164) On or about June 30, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #16.

(165) On or about July 2, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #16.

(166) On or about July 22, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #16.

(167) On or about August 18, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #16.

(168) On or about August 19, 2005, Defendant ADRIANA ROSS, a/k/a “Adriana Mucinska,” placed a telephone call to a telephone used by Jane Doe #16.

(169) On or about August 21, 2005, Defendant NADIA MARCINKOVA placed a telephone call to a telephone used by Jane Doe #16.

(170) On or about September 3, 2005, Defendant ADRIANA ROSS, a/k/a “Adriana Mucinska,” placed a telephone call to a telephone used by Jane Doe #16.

(171) On or about September 18, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #16.

(172) On or about September 19, 2005, Defendant SARAH KELLEN sent a text message to a telephone used by Jane Doe #16.

(173) On or about September 29, 2005, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #16.

EFTA00192719

30

(181) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN provided a gift of Secret lingerie to Jane Doe #16 for her

year-old girl.

(180) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN made a payment of $350.00 to Jane Doe #16, who was then a seventeen-

(179) In or around the first week of October, 2005, Defendant JEFFREY EPSTEIN engaged in sexual intercourse with Jane Doe #16, who was then a seventeen-year-old girl.

(178) On or about October 3, 2005, Defendant SARAH KELLEN left a telephone message for Defendant JEFFREY EPSTEIN stating: “[Jane Doe #16] will

telephone call to a telephone used by Jane Doe #16.

(177) On or about October 3, 2005, Defendant SARAH KELLEN placed a

telephone call to a telephone used by Jane Doe #16.

(176) On or about October 2, 2005, Defendant SARAH KELLEN placed a

confirmed at 11 AM and [Jane Doe #16] - 4PM”.

telephone message for Defendant JEFFREY EPSTEIN stating: “[Jane Doe #15]

(175) On or about October 1,2005, Defendant SARAH KELLEN left a

“Adriana Mucinska,” placed a telephone call to a telephone used by Jane Doe #16.

(174) On or about September 30, 2005, Defendant ADRIANA ROSS, a/k/a

EFTA00192720

31

remove her shirt.

(182) In or around the last half of 2003, Jane Doe #18 was approached by A.F. and was asked whether she would be willing to provide a massage to Defendant JEFFREY EPSTEIN in exchange for $200.

(183) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to provide her telephone number.

(184) On or around August 27, 2003, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #18.

(185) In or around the last half of 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #18, who was then a seventeen-year-old girl.

(186) On or around November 16, 2003, Defendant SARAH KELLEN placed a telephone call to a telephone used by Jane Doe #18.

(187) In or around the last half of 2003, Defendant JEFFREY EPSTEIN digitally penetrated Jane Doe #18, who was then a seventeen-year-old girl.

(188) In or around the last half of 2003, Defendant JEFFREY EPSTEIN asked Jane Doe #18 to recruit other females to travel to 358 El Brillo Way.

(189) On or about March 5, 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #19, who was then a seventeen-year-old girl, to leave when she refused to remove her shirt

Jane Does #18 and #19

EFTA00192721

32

(194) On or about June 11, 2004, Defendants JEFFREY EPSTEIN and SARAH KELLEN traveled from Chicago, Illinois to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(195) On or about June 20, 2004, Defendants JEFFREY EPSTEIN and NADIA MARCINKOVA traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(193) On or about May 14, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from Canada to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(192) On or about May 1, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(191) On or about March 11, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from Teterboro, New Jersey, to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air,

The Defendants’ Travel

was not willing to undress for him.

(190) On or about March 5, 2004, Defendant JEFFREY EPSTEIN verbally reprimanded Jane Doe #18 for bringing Jane Doe #19 to 358 El Brillo Way when she

EFTA00192722

33

(201) On or about October 2, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(200) On or about August 25, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from Ecuador to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(198) On or about July 22, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(199) On or about August 19, 2004, Defendants JEFFREY EPSTEIN and NADIA MARCINKOVA traveled from Van Nuys, California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(196) On or about July 4, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from Aspen, Colorado to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(197) On or about July 16, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air,

EFTA00192723

34

(207) On or about December 17, 2004, Defendants JEFFREY EPSTEIN and NADIA MARCINKOVA traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(206) On or about December 13, 2004, Defendant JEFFREY EPSTEIN traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(205) On or about December 3, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and ADRIANA ROSS, a/k/a “Adriana Mucinska,” traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(204) On or about November 18, 2004, Defendants JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(203) On or about November 10, 2004, Defendants JEFFREY EPSTEIN and SARAH KELLEN traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(202) On or about October 29, 2004, Defendants JEFFREY EPSTEIN and NADIA MARCINKOVA traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

EFTA00192724

35

On or about February 3, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from Columbus, Ohio, to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC.

(213) On or about February 10, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA

(211) On or about January 19, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(209) On or about January 6, 2005, Defendant JEFFREY EPSTEIN traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(210) On or about January 14, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC.

(208) On or about January 1, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from Anguilla, British West Indies to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

| EFTA00192725 | | :--- | :--- |

This is a simple Markdown document with no headings or paragraphs. It contains just one line of text.

36

(218) On or about March 31, 2005, Defendant JEFFREY EPSTEIN traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC.

(217) On or about March 18, 2005, Defendant JEFFREY EPSTEIN traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

Hyperion Air, Inc.

(216) On or about March 4, 2005, Defendants JEFFREY EPSTEIN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIAMARCINKOVA traveled from New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by JEGE, INC.

(215) On or about February 24, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft owned by

MARCINKOVA traveled from New York, New York to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by JEGE, INC.

(214) On or about February 21, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and NADIA MARCINKOVA traveled from the U.S. Virgin Islands to Palm Beach County, Florida, aboard the Boeing 727 aircraft owned by

EFTA00192726

37

(224) On or about September 18, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and ADRIANA ROSS, a/k/a “Adriana Mucinska,” traveled from

(223) On or about September 3, 2005, Defendants JEFFREY EPSTEIN and ADRIANA ROSS, a/k/a “Adriana Mucinska,” traveled from the U.S. Virgin Islands to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(222) On or about August 18, 2005, Defendants JEFFREY EPSTEIN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(221) On or about July 22, 2005, Defendants JEFFREY EPSTEIN and SARAH KELLEN traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(220) On or about June 30, 2005, Defendants JEFFREY EPSTEIN and SARAH KELLEN traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

owned by Hyperion Air, Inc.

(219) On or about May 19, 2005, Defendants JEFFREY EPSTEIN, SARAH KELLEN, and ADRIANA ROSS, a/k/a “Adriana Mucinska,” traveled from Teterboro, New Jersey to Palm Beach County, Florida, aboard the Gulfstream aircraft

EFTA00192727

38

CountDate(s)Minor InvolvedDefendant(s)
22001-2004Jane Doe #2JEFFREY EPSTEIN SARAH KELLEN

1591(c)(1):

reference as though fully set forth herein.

  1. On or about the dates enumerated as to each count listed below, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendants listed below did knowingly, in and affecting interstate and foreign commerce, recruit, entice, provide, and obtain by any means a person, that is, the person in each count listed below, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. §

  2. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

COUNTS 2 THROUGH 10
(Sex Trafficking:18 U.S.C.§1591(a)(1))

Westchester County, New York to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

(225) On or about September 29, 2005, Defendants JEFFREY EPSTEIN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft owned by Hyperion Air, Inc.

All in violation of Title 18, United States Code, Section 371.

EFTA00192728

39

All in violation of Title 18, United States Code, Sections 1591(a)(1) and 2.

CountDate(s)Minor InvolvedDefendant(s)
3January 2004 through July 2004Jane Doe #4JEFFREY EPSTEIN SARAH KELLEN
4July 2004 through December 29, 2004Jane Doe #9JEFFREY EPSTEIN SARAH KELLEN
5July 2004 through January 31, 2005Jane Doe #10JEFFREY EPSTEIN SARAH KELLEN
6Mid-2004 through April 22, 2005Jane Doe #12JEFFREY EPSTEIN SARAH KELLEN
7August 2004 through May 27, 2005Jane Doe #13JEFFREY EPSTEIN SARAH KELLEN
8November 2004 through March 2005Jane Doe #14JEFFREY EPSTEIN SARAH KELLEN ADRIANA ROSS, a/k/a “Adriana Mucinska”
9December 2004 through June 5, 2005Jane Doe #15JEFFREY EPSTEIN SARAH KELLEN ADRIANA ROSS, a/k/a “Adriana Mucinska”
10February 2005 through first week of October 2005Jane Doe #16JEFFREY EPSTEIN SARAH KELLEN ADRIANA ROSS, a/k/a “Adriana Mucinska” NADIA MARCINKOVA

EFTA00192729

40

reference as though fully set forth herein.

35. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

Sections 1591(a)(2), 1591(b)(2), and 2.

COUNT 12

(Enticement of a Minor: 18 U.S.C. § 2422(b))

did knowingly benefit, financially or by receiving anything of value, from participation in a venture, as defined in 18 U.S.C. § 1591(c)(3), which had engaged in an act described in violation of 18 U.S.C. § 1591(a)(1), that is, the recruiting, enticing, providing, and obtaining by any means a person, in or affecting interstate commerce, knowing that the person or persons had not attained the age of 18 years and would be caused to engage in a commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title 18, United States Code,

SARAH KELLEN,

ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA,

District of Florida, and elsewhere, the defendants,

the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern

  1. From at least as early as in or about 2001 through in or about October 2005,

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

COUNT 11

(Sex Trafficking: 18 U.S.C. § 1591(a)(2))

EFTA00192730

41

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #7, who was a person who had not attained the age of

JEFFREY EPSTEIN

and SARAH KELLEN,

  1. In or around July 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants,

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

| COUNT 13 |

| :---: |

(Enticement of a Minor: 18 U.S.C. § 2422(b))

and 2.

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #3, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is violations of Florida Statutes Sections 800.04(5)(a), 800.04(6)(a), and 800.04(7)(a); in violation of Title 18, United States Code, Sections 2422(b)

JEFFREY EPSTEIN

and SARAH KELLEN,

of Florida, and elsewhere, the defendants,

  1. From in or around the spring of 2003 through on or about October 2, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District

EFTA00192731

42

of Florida, and elsewhere, the defendants,

exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District

  1. From in or around July 2004 through on or around December 29, 2004, the

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

| COUNT 15 |

| :---: | | (Enticement of a Minor: 18 U.S.C. § 2422(b)) |

2422(b) and 2.

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #8, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections

JEFFREY EPSTEIN

and

SARAH KELLEN,

  1. From in or around July 2004 through in or around October 2004, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants,

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

| COUNT 14 |

| :---: |

| (Enticement of a Minor: 18 U.S.C. § 2422(b)) |

2422(b) and 2.

18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections

EFTA00192732

43

2422(b) and 2.

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #10, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections

JEFFREY EPSTEIN

and SARAH KELLEN,

Florida, and elsewhere, the defendants,

  1. From in or around July 2004 through on or about January 31, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

COUNT 16

(Enticement of a Minor: 18 U.S.C. § 2422(b))

Title 18, United States Code, Sections 2422(b) and 2.

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #9, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of

JEFFREY EPSTEIN

and

SARAH KELLEN,

EFTA00192733

44

JEFFREY EPSTEIN

and SARAH KELLEN,

Florida, and elsewhere, the defendants,

reference as though fully set forth herein.

  1. From in or around August 2004 through on or about May 27, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida. and elsewhere, the defendants.

  2. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

| COUNT 18 |

| :---: |

| (Enticement of a Minor: 18 U.S.C. § 2422(b)) |

2422(b) and 2.

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #12, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.

JEFFREY EPSTEIN

and

SARAH KELLEN,

of Florida, and elsewhere, the defendants,

  1. From in or around the middle of 2004 through on or about April 22, 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

| COUNT 17 |

| :---: |

(Enticement of a Minor: 18 U.S.C. § 2422(b))

EFTA00192734

45

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #14, who was a person who had not attained the age of 18 years, to engage in prostitution and in a sexual activity for which a person can be charged with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of Title 18, United States Code, Sections 2422(b) and 2.

JEFFREY EPSTEIN,

SARAH KELLEN,

and ADRIANA ROSS, a/k/a “Adriana Mucinska,”

Florida, and elsewhere, the defendants,

dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of

  1. From in or around November 2004 through in or around March 2005, the exact

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

COUNT 19

(Enticement of a Minor: 18 U.S.C. § 2422(b))

2422(b) and 2.

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #13, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections

EFTA00192735

46

reference as though fully set forth herein.

  1. From in or around February 2005 through in or around the first week of October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the defendants,

  2. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

| COUNT 21 |

| :---: |

| (Enticement of a Minor: 18 U.S.C. § 2422(b)) |

2422(b) and 2.

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #15, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections

JEFFREY EPSTEIN,

SARAH KELLEN, and

ADRIANA ROSS, a/k/a “Adriana Mucinska,”

Florida, and elsewhere, the defendants,

dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of

  1. From in or around December 2004 through on or about June 5, 2005,the exact

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

| COUNT 20 |

| :---: |

| (Enticement of a Minor: 18 U.S.C. § 2422(b)) |

EFTA00192736

47

2422(b) and 2.

JEFFREY EPSTEIN,

SARAH KELLEN, and ADRIANA ROSS, a/k/a “Adriana Mucinska,”

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #17, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections

Florida, and elsewhere, the defendants,

dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of

  1. From in or around February 2005 through in or around April 2005, the exact

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by
(Enticement of a Minor: 18 U.S.C.§2422(b))

Title 18, United States Code, Sections 2422(b) and 2.

with a criminal offense, that is a violation of Florida Statutes Section 794.05; in violation of

18 years, to engage in prostitution and in a sexual activity for which a person can be charged

persuade, induce or entice Jane Doe #16, who was a person who had not attained the age of

did use a facility or means of interstate commerce, that is, the telephone, to knowingly

JEFFREY EPSTEIN,

SARAH KELLEN,

ADRIANA ROSS, a/k/a “Adriana Mucinska,”

and NADIA MARCINKOVA,

EFTA00192737

48

JEFFREY EPSTEIN,

SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA,

dates being unknown to the Grand Jury, the Defendants,

reference as fully set for the herein.

  1. From at least as early as 2001 through in or around October 2005, the exact

  2. Paragraphs 1 through 25 of this indictment are re-alleged and incorporated by

COUNT 24 (Conspiracy to Travel: 18 U.S.C. § 2423(e))

2422(b) and 2.

did use a facility or means of interstate commerce, that is, the telephone, to knowingly persuade, induce and entice Jane Doe #18, who was a person who had not attained the age of 18 years, to engage in prostitution; in violation of Title 18, United States Code, Sections 2422(b) and 2.

JEFFREY EPSTEIN,

and

SARAH KELLEN,

Florida, and elsewhere, the defendants,

dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of

  1. From in or around August 2003 through in or around February 2004, the exact

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

| COUNT 23 |

| :---: |

| (Enticement of a Minor: 18 U.S.C. § 2422(b)) |

EFTA00192738

49

  1. On or about the dates enumerated as to each count listed below, from a place outside the Southern District of Florida to a place inside the Southern District of Florida, the

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

COUNTS 26 THROUGH 29
(Travel to Engage in Illicit Sexual Conduct: 18 U.S.C.§2423(b))

did, for the purpose of commercial advantage or private financial gain, arrange and facilitate the travel of a person, that is Defendant Jeffrey Epstein, knowing that such person was traveling in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. §2423(f); in violation of Title 18, United States Code, Section 2423(d).

District of Florida, and elsewhere, the Defendant,

  1. From at least as early as in or about 2001 through in or around October 2005, the exact dates being unknown to the Grand Jury, in Palm Beach County, in the Southern District of Florida, and elsewhere, the Defendant,

reference as though fully set forth herein.

  1. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by

COUNT 25

(Facilitation of Unlawful Travel of Another: 18 U.S.C. § 2423(d))

did knowingly and willfully conspire with each other and with others known and unknown to travel in interstate commerce for the purpose of engaging in illicit sexual conduct, as defined in 18 U.S.C. § 2423(f), with another person, in violation of Title 18, United States Code, Section 2423(b); all in violation of Title 18, United States Code, Section 2423(e).

EFTA00192739

50

FORFEITURE 1

Upon conviction of the violation alleged in Count 1 of this indictment, the defendants, JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA, shall forfeit to the United States any property, real or personal, which constitutes or is derived from proceeds traceable to the violation.

All in violation of Title 18, United States Code, Sections 2423(b) and 2.

CountDate(s)Minor(s) InvolvedDefendant(s)
267/16/2004Jane Doe #7 Jane Doe #8 Jane Doe #9 Jane Doe #10JEFFREY EPSTEIN SARAH KELLEN NADIA MARCINKOVA
273/31/2005Jane Doe #14 Jane Doe #15 Jane Doe #16JEFFREY EPSTEIN SARAH KELLEN ADRIANA ROSS, a/k/a “Adriana Mucinska”
289/18/2005Jane Doe #16JEFFREY EPSTEIN SARAH KELLEN ADRIANA ROSS, a/k/a “Adriana Mucinska”
299/29/05Jane Doe #16JEFFREY EPSTEIN SARAH KELLEN ADRIANA ROSS, a/k/a “Adriana Mucinska” NADIA MARCINKOVA

that is, the person(s) listed in each count below:

Defendant(s) listed below traveled in interstate commerce for the purpose of engaging in illicit sexual conduct as defined in 18 U.S.C. §2423(f), with a person under 18 years of age,

EFTA00192740

51

Upon conviction of any of the violations alleged in Counts 12-29 of this indictment, the defendants, JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA, shall forfeit to the United States any property, real or personal, constituting or traceable to gross profits or other proceeds obtained from such

FORFEITURE 2

All pursuant to Title 28 United States Code, Section 2461; Title 18, United States Code, Section 981(a)(1)(C); and Title 21 United States Code, Section 853.

forfeitable property.

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of the defendants up to the value of the above

difficulty;

(5) has been commingled with other property which cannot be subdivided without

(4) has been substantially diminished in value; or

(3) has been placed beyond the jurisdiction of the Court;

(2) has been transferred or sold to, or deposited with a third person;

(1) cannot be located upon the exercise of due diligence;

a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA,

omission of the defendants, JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS,

If the property described above as being subject to forfeiture, as a result of any act or

Section 981(a)(1)(C); and Title 21, United States Code, Section 853.

Pursuant to Title 28, United States Code, Section 2461; Title 18, United States Code,

EFTA00192741

52

(d) has been substantially diminished in value; or

(c) has been placed beyond the jurisdiction of the Court;

(b) has been transferred or sold to, or deposited with, a third person;

(a) cannot be located upon the exercise of due diligence;

ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA,

as a result of any act or omission of the defendants JEFFREY EPSTEIN, SARAH KELLEN,

If any of the forfeitable property described in the forfeiture section of this indictment,

Pursuant to Title 18, United States Code, Section 2253.

BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or

Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida

therein or thereon, and more particularly described as:

a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found

offense; and any property, real or personal, used or intended to be used to commit or to promote the commission of such offense, including but not limited to the following:

EFTA00192742

53

BEING that portion lying West of Lot 40, El Bravo Park, in Section 27, Township 43 South, Range 43 East, as recorded in Plat Book 9, Page 9, Public Records of Palm Beach County, Florida, being bounded on the West by the

Being all of Lot 40 and the West 24.3 feet of Lot 39, El Bravo Park, as recorded in Plat Book 9, Page 9, in the records of Palm Beach County, Florida

a. A parcel of land located at 358 El Brillo Way, Palm Beach, Florida 33480, including all buildings, improvements, fixtures, attachments, and easements found therein or thereon, and more particularly described as:

including but not limited to the following:

Upon conviction of any of the violations alleged in Counts 2-11 of this indictment, the defendants, JEFFREY EPSTEIN, SARAH KELLEN, ADRIANA ROSS, a/k/a “Adriana Mucinska,” and NADIA MARCINKOVA, shall forfeit to the United States any property, real or personal, that was used or intended to be used to commit or to facilitate the commission of such violation; and any property, real or personal, constituting or derived from any proceeds that such person obtained, directly or indirectly, as a result of such violation.

FORFEITURE 3

Pursuant to Title 18, United States Code, Section 2253.

forfeitable property.

it is the intent of the United States, pursuant to Title 18, United States Code, Section 2253(o), to seek forfeiture of any other property of said defendant up to the value of the above

difficulty;

(e) has been commingled with other property which cannot be divided without

EFTA00192743

West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less.

Pursuant to Title 18, United States Code, Section 1594(b).

A TRUE BILL.

FOREPERSON

R. ALEXANDER ACOSTA

UNITED STATES ATTORNEY

A. MARIE VILLAFAÑA

ASSISTANT UNITED STATES ATTORNEY

54

Other documents from the same file

These documents were released together, in one file.

Discuss on Bluesky

Retrieved from https://epstein-index.org/documents/ds9-efta00192690/.