EFTA00182748

06/0S/2009 09:44 FAX 
ROTHSTEIN ROSENFELT ADLE 
06-01-'09 15:37 FROM-THOMAS & LOCICERO 
8139843070 
Z010/011 
T-989 P006/007 F-845 
of the New York Times Co. v. Holtzendorf 507 So. 2d 667, 668 (Fla. 2d DCA 1987) ("While a 
judge may impose whatever legal sentence he chooses, if such sentence is based on a tangible 
proceeding or document, it is within the public domain unless otherwise privileged."). In this 
case, no interest justifies continued sealing of these "significant" documents that Judge Pucillo 
considered in accepting the plea and sentencing the Defendant. The lack of any such 
compelling interest — as well as the parties' failure to comply with the standards for sealing 
documents initially — provide good cause for unsealing the documents at this time. 
8. 
Finally, continued closure of these documents is pointless, because many portions 
of the sealed documents already have been made public. For example, court papers quoting 
excerpts of the agreement have been made public in related federal proceedings.3 As the Florida 
Supreme Court has noted, "there would be little justification for closing a pretrial hearing in 
order to prevent only the disclosure of details which had already been publicized." Lewis, 426 
So. 2d at 8. Similarly, in this case, to the extent that information already has been made public, 
continued closure is pointless and, therefore, unconstitutional. 
9. 
The Post has no objection to the redaction of victims' names (if any) that appear 
in the sealed documents. In addition, insofar as the Defendant or State Attorney seek continued 
closure, the Post requests that the Court inspect the documents in camera in order to assess 
whether, in fact, continued closure is proper. 
3 See, e.g.,  "Defendants Jeffrey Epstein andig..Motion 
for Stay," =. 
v. 
Epstein, Case No. 08.80811 (S.D. Fla. July 25, 200 
c publicly Jan. 7, 2009). 
4 
EFTA00182888

06/05/2009 09:44 FAX 
ROTHSTEIN ROSENFELT ADLE 
06-01-'09 15:38 FROM-THOMAS & L0CICER0 
8139843070 
e011/011 
T-989 P007/007 F-845 
WHEREFORE, the Post respectfully requests that this Court unseal the non-prosecution 
agreement and addendum and grant the Post such other relief as the Court deems proper. 
Respectfully submitted, 
THOMAS, LOCICERO & BRALOW PL 
(
canna K. Sh 
Florida Bar No.: 
James B. Lake 
Florida Bar No.: 
101 N.E. Third Avenue, Suite 1500 
Fort Lauderdale, FL 33301 
Telephone: 
Facsimile: 
ett,
ri A Fati t
ifi) f   
Attorneys for The Palm Beach Post 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished 
via facsimile and U.S. Mail to: R. Alexander Acosta, United States Attorney's Office - Southern 
District, 500 S. Australian Ave., Ste. 400, West Palm Beach, FL 33401 (fax: 
Michael McAuliffe, Esq., and Judith Stevenson Arco, Esq., State Attorney's Office - West 
Palm Beach, 401 North Dixie Highway, West Palm Beach, FL 33401 (fax: Ell=11; 
Jack 
Man Goldberger, Esq., Atterbury Goldberger, et al., 250 S. Australian Ave., Ste. 1400, West 
Palm Beach, FL 33401 (fax: MIMI; 
and Bradley J. Edwards, Esq. and William J. 
Berger, Esq., Rothstein Rosenfeldt Adler, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, 
FL 33394 (fax: Oa 
on this 1st day of June, 2009. 
5 
EFTA00182889

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
Case No: 
18 U.S.C. § 371 
18 U.S.C. § 1591(a)(1) 
18 U.S.C. § 1591(a)(2) 
18 U.S.C. § 2422(b) 
18 U.S.C. § 2423(e) 
18 U.S.C. § 2423(d) 
18 U.S.C. § 2423(b) 
UNITED STATES OF AMERICA 
vs. 
JEFFREY EPSTEIN, 
" 
and 
Defendants. 
INDICTMENT 
The Grand Jury charges that: 
BACKGROUND 
At all times relevant to this Indictment: 
I. 
Defendant JEFFREY EPSTEIN employed defendants MI
, 
aikia ' 
" and 
to perform, 
among other things, services as personal assistants. 
EFTA00182890

2. 
Defendants JEFFREY EPSTEIN and 
paid.., 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 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. 
5. 
Defendant JEFFREY EPSTEIN served as president, sole director, and sole 
shareholder of JEGE, INC., and had the power to direct all of its operations. 
6. 
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. 
7. 
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. 
8. 
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 
2 
EFTA00182891

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] 
be a defense." 
9. 
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. 
10. 
Pursuant to Florida Statutes Sections 800.04(6Xa) 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. 
11. 
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 
3 
EFTA00182892

16 years of age, commits lewd or lascivious exhibition," which is a felony of the second 
degree. 
12. 
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]." 
13. 
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]." 
14. 
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." 
15. 
Defendant JEFFREY EPSTEIN was over the age of 24 and did not have any 
medical license. 
16. 
During the period of her involvement with the Defendants, Jane Doe #4 
attended Wellington High School and 
County. 
17. 
in Palm Beach 
During the period of her involvement with the Defendants, Jane Doe #5 
attended Wellington High School in Palm Beach County. 
4 
EFTA00182893

18. 
During the period of their involvement with the Defendants, Jane Does # 6, 8, 
and 12 attended 
in Palm Beach County. 
19. 
During the period of her involvement with the Defendants, Jane Doe #7 
attended 
in Palm Beach County. 
20. 
During the periods of their involvement with the Defendants, Jane Does # 9, 
14, 15, 16, 17, 18, and 19 attended 
21. 
attended 
in Palm Beach County. 
During the period of her involvement with the Defendants, Jane Doe #10 
in Palm Beach County. 
22. 
During the period of her involvement with the Defendants, Jane Doe #11 
attended 
in Palm Beach County. 
23. 
During the period of her involvement with the Defendants, Jane Doe #13 
attended 
in Palm Beach County. 
COUNT 1 
(Conspiracy: 18 U.S.C. § 371) 
24. 
Paragraphs 1 through 23 of this Indictment are re-alleged and incorporated by 
reference as though fully set forth herein. 
25. 
From at least as early as 2001, the exact date being unknown to the Grand Jury, 
through in or around October 2005, in Palm Beach County, in the Southern District of 
Florida, and elsewhere, the Defendants, 
5 
EFTA00182894

JEFFREY EPSTEIN, 
a/k/a ' 
" 
and 
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). 
Purpose and Object of the Conspiracy 
26. 
It was the purpose and object of the conspiracy to procure females under the 
age of 18 to travel to 358 El Brillo Way 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. 
Manner and Means 
27. 
The manner and means by which the Defendants and other participants sought 
to accomplish the purpose and object of the conspiracy included the following: 
(a) 
It was part of the conspiracy that Defendants 
, a/k/a ' 
,, 
and other 
participants would contact minor females via the use of cellular and other telephones to 
6 
EFTA00182895

arrange appointments for minor females to travel to 358 El Brillo Way 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, 
, a/k/a 
1.1 
and other participants would make payments to, or cause payments to be 
made to, minor females in exchange for engaging in lewd conduct. 
EPSTEIN, 
(c) 
It was further a part of the conspiracy that Defendants JEFFREY 
a/k/a 
," 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, 
a/k/a 
" and other 
participants would make payments to, or cause payments to be made to, the recruiters for 
bringing additional minor females to 358 El Brillo Way to engage in lewd conduct with 
Defendant JEFFREY EPSTEIN. 
(e) 
It was further a part of the conspiracy that Defendant JEFFREY 
EPSTEIN would pay minor females to engage in lewd conduct with Defendant 
to satisfy Defendant JEFFREY EPSTEIN's prurient interests. 
7 
EFTA00182896

Overt Acts 
28. 
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: 
Jane Does #1 and #2 
(I) 
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. 
(2) 
In or around 2001, Defendant 
led Jane Doe #2 from the 
kitchen of 358 El Brillo Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 
El Brillo Way. 
(3) 
In or around 2001, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #2, who was then a fourteen-year-old girl. 
(4) 
In or around 2001, Defendant JEFFREY EPSTEIN asked Jane Doe #2, 
who was then a fourteen-years-old girl, to pinch his nipples while he masturbated. 
(5) 
In or around 2001, Defendant JEFFREY EPSTEIN made a payment of 
$300 to Jane Doe #2. 
(6) 
In or around 2001, Defendant 
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. 
8 
EFTA00182897

(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, Defendant JEFFREY EPSTEIN reviewed 
a written telephone message prepared by one of his employees 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 sexual 
activities with him. 
(11) 
In or around 2003, Defendant-
of Jane Doe #2, who was then a sixteen-year-old girl.
(12) 
In or around 2003, Defendant 
took nude photographs 
made a payment of 
$500 to Jane Doe #2 in exchange for posing for nude photographs. 
(13) In or around 2003, Defendant 
told Jane Doe #2 that 
Defendant JEFFREY EPSTEIN had asked 
to take nude photographs of Jane 
Doe #2. 
9 
EFTA00182898

(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 
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. 
(17) 
On or about April 23, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #2. 
(18) 
On or about May 2, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #2. 
Jane Doe #3 
(19) 
In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the 
presence of Jane Doe #3, who was then a fifteen-year-old girl. 
(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 
placed a 
telephone call to a telephone used by Jane Doe #3. 
10 
EFTA00182899

(22) 
On or about October 30, 2004, Defendant 
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. 
(28) 
In or around 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #3 
to recruit additional females to come to 358 El Brillo Way. 
11 
EFTA00182900

(29) 
On or about November 8, 2004, Defendant JEFFREY EPSTEIN 
reviewed a written telephone message prepared by one of his employees regarding a 
telephone call received from Jane Doe #3 that read: "I have a female for him." 
(30) On or about January 14, 2005, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #3. 
(31) On or about January 29, 2005, Defendant JEFFREY EPSTEIN reviewed 
a written telephone message prepared by one of his employees regarding a telephone 
call received from Jane Doe #3 that read: "I have a female for him." 
Jane Does #4. #5, and #6 
(32) 
In or around the first half of 2004, Defendant 
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 
learned that Jane Doe #4 was seventeen years old when he asked Jane Doe #4 about 
her age, and Jane Doe #4 responded with her true age. 
(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. 
12 
EFTA00182901

(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. 
(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. 
13 
EFTA00182902

(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. 
(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 
sixteen-year-old girl. 
(45) 
In or around the first half of 2004, Defendant JEFFREY EPSTEIN 
caused a payment of $200 to be made to Jane Doe #6. 
Jane Does #7 and #8 
(46) 
In or around July 2004, Defendant JEFFREY EPSTEIN led.., 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. 
(47) 
On or about July 4, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #7. 
(48) 
On or about July 5, 2004, Defendant 
placed a 
telephone call to a telephone used by M. 
(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. 
14 
EFTA00182903

(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 
M. for recruiting Jane Doe #8 to travel to 358 El Brillo Way. 
(53) 
In or around July 2004, Defendant 
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 
telephone call to a telephone used by Jane Doe #7. 
(55) On or about July 15, 2004, Defendant 
telephone call to a telephone used by Jane Doe #8. 
(56) On or about July 15, 2004, Defendant 
telephone call to a telephone used by 
(57) On or about July 16, 2004, Defendant 
more telephone calls to a telephone used by Jane Doe #7. 
(58) On or about July 16, 2004, Defendant 
telephone call to a telephone used by.. 
15 
placed a 
placed a 
placed a 
placed one or 
placed a 
EFTA00182904

(59) 
On or about July 17, 2004, Defendant JEFFREY EPSTEIN reviewed 
a written telephone message prepared by one of his employees regarding a telephone 
call received from.. that read: "Me & [Jane Doe #7] can come tomorrow any time 
or [M.1 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 
placed a 
telephone call to a telephone used by Jane Doe #8. 
Jane Does #9 and #10 
(66) On or about July 15, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #9. 
16 
EFTA00182905

(67) 
On or about July 16, 2004, Defendant 
caused Jane 
Doe #9 to make a telephone call to a telephone used by Jane Doe #10. 
(68) On or about July 17, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #9. 
(69) On or about July 18, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #9. 
(70) 
On or about July 22, 2004, Defendant 
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. 
(74) On or about July 22, 2004, Defendant 
placed a 
telephone call to a telephone used by Jane Doe #10. 
(75) 
In or around the last half of 2004, Defendants JEFFREY EPSTEIN and 
engaged in oral sex and sexual intercourse in the presence 
of Jane Doe #9, who was then a seventeen-year-old girl. 
17 
EFTA00182906

(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 
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 
placed 
a telephone call to a telephone used by Jane Doe #9. 
(83) On or about December 30, 2004, Defendants JEFFREY EPSTEIN and 
caused the purchase of Broadway tickets as an eighteenth birthday 
gift for Jane Doe #9. 
18 
EFTA00182907