EFTA00174587

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
x 
UNITED STATES OF AMERICA 
JEFFREY EPSTEIN, 
Defendant. 
x 
SEALED 
INDICTMENT 
19 Cr. 
19 CRIM 490 
COUNT ONE 
(Sex Trafficking Conspiracy) 
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 
defendant, 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 Residence") 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 
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this way, EPSTEIN created a vast network of underage victims for 
him to sexually exploit in locations including New York and 
Palm Beach. 
3. 
The victims described herein were as young as 14 
years old at the time they were abused by JEFFREY EPSTEIN, the 
defendant, and were, for various reasons, often particularly 
vulnerable to exploitation. EPSTEIN intentionally sought out 
minors and knew that many of his victims were in fact under the 
age of 18, including because, in some instances, minor victims 
expressly told him their age. 
4. 
In creating and maintaining this network of minor 
victims in multiple states to sexually abuse and exploit, 
JEFFREY EPSTEIN, the defendant, worked and conspired with 
others, including employees and associates who facilitated his 
conduct by, among other things, contacting victims and 
scheduling their sexual encounters with EPSTEIN at the New York 
Residence and at the Palm Beach Residence. 
FACTUAL BACKGROUND 
5. 
During all time periods charged in this 
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with 
multiple residences in the continental United States, including 
the New York Residence and the Palm Beach Residence. 
6. 
Beginning in at least 2002, JEFFREY EPSTEIN, the 
defendant, enticed and recruited, and caused to be enticed and 
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recruited, dozens of minor girls to engage in sex acts with him, 
after which EPSTEIN paid the victims hundreds 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 
doing, 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, EPSTEIN abused numerous minor victims at 
the New York Residence by causing these victims to be recruited 
to engage in paid sex acts with him. 
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9. 
When a victim arrived at the New York Residence, 
she typically would be escorted to a room with a massage table, 
where she would perform a massage on JEFFREY EPSTEIN, the 
defendant. The victims, who were as young as 14 years of age, 
were told by EPSTEIN or other individuals to partially or fully 
undress before beginning the "massage." During the encounter, 
EPSTEIN would escalate the nature and scope of physical contact 
with his victim to include, among other things, sex acts such as 
groping and direct and indirect contact with the victim's 
genitals. EPSTEIN typically would also masturbate during these 
sexualized encounters, ask victims to touch him while he 
masturbated, and touch victims' genitals with his hands or with 
sex toys. 
10. In connection with each sexual encounter, JEFFREY 
EPSTEIN, the defendant, or one of his employees or associates, 
paid the victim in cash. Victims typically were paid hundreds 
of dollars in cash for each encounter. 
11. JEFFREY EPSTEIN, the defendant, knew that many of 
his New York victims were underage, including because certain 
victims told him their age. Further, once these minor victims 
were recruited, many were abused by EPSTEIN on multiple 
subsequent occasions at the New York Residence. EPSTEIN 
sometimes personally contacted victims to schedule appointments 
at the New York Residence. In other instances, EPSTEIN directed 
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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 victim-
recruiters, 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 additional 
girls by offering to pay these victim-recruiters for every 
additional girl they brought to EPSTEIN. When a victim-
recruiter 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 
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encounters through Employee-1, who sometimes asked the 
recruiters to bring a specific minor girl for EPSTEIN. 
The Palm Beach Residence 
14. In addition to recruiting and abusing minor girls 
in New York, JEFFREY EPSTEIN, the defendant, created a similar 
network of minor girls to victimize in Palm Beach, Florida, 
where EPSTEIN owned, possessed and controlled another large 
residence, i.e., the Palm Beach Residence. EPSTEIN frequently 
traveled from New York to Palm Beach by private jet, before 
which an employee or associate would ensure that minor victims 
were available for encounters upon his arrival in Florida. 
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the 
defendant, engaged in a similar course of abusive conduct. 
When a victim initially arrived at the Palm Beach Residence, she 
would be escorted to a room, sometimes by an employee of 
EPSTEIN's, including, at times, two assistants ("Employee-2" and' 
"Employee-3") who, as described herein, were also responsible 
for scheduling sexual encounters with minor victims. Once 
inside, the victim would provide a nude or semi-nude massage for 
EPSTEIN, who would himself typically be naked. During these 
encounters, EPSTEIN would escalate the nature and scope of the 
physical contact to include sex acts such as groping and direct 
and indirect contact with the victim's genitals. EPSTEIN would 
also typically masturbate during these encounters, ask victims 
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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 typically were paid hundreds 
of dollars for each encounter. 
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. 
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19. Moreover, as in New York, to ensure a steady 
stream of minor victims, JEFFREY EPSTEIN, the defendant, asked 
and enticed certain victims in Florida to recruit other girls to 
engage in sex acts. EPSTEIN paid hundreds of dollars to victim-
recruiters for each additional girl they brought to the Palm 
Beach Residence. 
STATUTORY ALLEGATIONS 
20. From at least in or about 2002, up to and 
including in or about 2005, in the Southern District of New York 
and elsewhere, JEFFREY EPSTEIN, the defendant, and others known 
and unknown, willfully and knowingly did combine, conspire, 
confederate, and agree together and with each other to commit an 
offense against the United States, to wit, sex trafficking of 
minors, in violation of Title 18, United States Code, Section.
1591(a) and (b). 
21. It was a part and object of the conspiracy that 
JEFFREY EPSTEIN, the defendant, and others known and unknown, 
would and did, in and affecting interstate and foreign commerce, 
recruit, entice, harbor, transport, provide, and obtain, by any 
means a person, and to benefit, financially and by receiving 
anything of value, from participation in a venture which has 
engaged in any such act, knowing that the person had not 
attained the age of 18 years and would be caused to engage in a 
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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 
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a telephone call to Minor Victim-1 in order to schedule an 
appointment for Minor Victim-1 to engage in paid sex acts with 
EPSTEIN. 
d. 
In or about 2004, Minor Victim-2 was 
recruited to engage in sex acts with EPSTEIN and was repeatedly 
sexually abused by EPSTEIN at the Palm Beach Residence over a 
period of years and was paid hundreds of dollars after each 
encounter. EPSTEIN also encouraged and enticed Minor Victim-2 
to recruit other girls to engage in paid sex acts, which she 
did. 
e. 
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-2 in order to schedule an 
appointment for Minor Victim-2 to engage in paid sex acts with 
EPSTEIN. 
f. 
In or about 2005, Minor Victim-3 was 
recruited to engage in sex acts with EPSTEIN and was repeatedly 
sexually abused by EPSTEIN at the Palm Beach Residence over a 
period of years and was paid hundreds of dollars for each 
encounter. EPSTEIN also encouraged and enticed Minor Victim-3 
to recruit other girls to engage in paid sex acts, which she 
did. EPSTEIN asked Minor Victim-3 how old she was, and Minor 
Victim-3 answered truthfully. 
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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 
acts 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 1 
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 
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individuals-who were less than 18 years old, including but not 
limited to Minor Victim-1, as described above, and who were then 
caused to engage in at least one commercial sex act in 
Manhattan, New York. 
(Title 18, United States Code, Sections 1591(a), 
(b)(2), and 2.) 
FORFEITURE ALLEGATIONS 
25. As a result of committing the offense alleged in 
Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, 
shall forfeit to the United States, pursuant to Title 18, United 
States Code, Section 1594(c) (1), any property, real and 
personal, that was used or intended to be used to commit or to 
facilitate the commission of the offense alleged in Count Two, 
and any property, real or personal, constituting or derived from 
any proceeds obtained, directly or indirectly, as a result of 
the offense alleged in Count Two, or any property traceable to 
such property, and the following specific property: 
a. 
The lot or parcel of land, together with its 
buildings, appurtenances, improvements, fixtures, attachments 
and easements, located at 9 East 71st Street, New York, New 
York, with block number 1386 and lot number 10, owned by 
Maple, Inc. 
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Substitute Asset Provision 
26. If any of the above-described forfeitable 
property, as a result of any act or omission of the defendant: 
(a) cannot be located upon the exercise of due diligence; 
(b) has been transferred or sold to, or deposited with, a 
third person; 
(c) has been placed beyond the jurisdiction of the Court; 
(d). has been substantially diminished in value; or 
(e) has been commingled with other property which cannot 
be subdivided without difficulty; 
it is 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 property 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 853(p); and 
Title 28, United States Code, Section 2461.) 
EPERSON 
GEOFFREY . BERMAN 
United States Attorney 
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Form No. USA-33s-274 (Ed. 9-25-58) 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
JEFFREY EPSTEIN, 
Defendant. 
INDICTMENT
(18 U.S.C. §S 371, 1591(a), (b) (2), 
and 2) 
GEOFFREY S. BERMAN 
United States Attorney 
Z
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Foret:Yon 
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