This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00224636
92 pages
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10. 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 clegipe." 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] be a defense." 11. Pursuant to Florida Statutes Sections 800.04(5Xa) and 800.04(5)(cX2), 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 ageta 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. 12. Pursuant to Florida Statutes Sections 800.04(6)(a) and 800.04(6Xb), an adult "who [iintentionally touches a person under 16 y rA 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 rr EFTA00224676
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13. Pursuant to Florida Statutes Sections 800.04(7)(a) and 80Q.04(7Xc), 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. 14. 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]." 15. 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 cannolbe raised as a defense in a prosecution under [Section 800.04]." 16. 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." - • 17. Defendant JEFFREY EPSTEIN was the age of 24 and did not have any medical license. 4 EFTA00224677
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18. During the period of her involvement with the Defendants, Jane Doe #4 attended =MINIM and =SEIM= in Palm Beach County... 19. During the period of her involvement with the Defendants, Jane Doe #5 attended in Palm Beach County. 20. During the period of their involvement with the Defendants, Jane Does # 6, 8 and 12 attended in Palm Beach County. 21. During the period of her involvement with the Defendants, Jane Doe #7 attended in Palm Beach County. 22. During the periods of their involvement with the Defendants, Jane Does # 9, 14, 15, 16, 17, 18, and 19 attended in Palm Beach County. 23. During the period of involvement with the Defendants, Jane Doe #10 attended in Palm Beach County. 24. During the period of her involvement with the Defendants, Jane Doe #11 attended the MI a public high school, located in New York, New York. 25. During the period of her involvement with the Defendants, Jane Doe #I3 attended in Palm Beach County. 5 EFTA00224678
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COUNT 1 (Conspiracy: 18 U.S.C. § 371) 26.. Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by reference as though fully set forth herein. 27. 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, 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 cmmit an offense against the United States, that is, to ".; use a facility or means of interstate litiitign 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). Puipose and Object of the Conspiracy 28. It was the purpose and object of thrc;nspiracy 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. 6 EFTA00224679
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Manner and Means 29. The manner and means by which the Defendants and other participants sought to accokkh the purpose and object of the conspiracy included the following: (a) It was part of the conspiracy that Defendants a/k/a " ft 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 DePeridant JEFFREY EPSTEIN to engage in lewd conduct with them. (b) It was further. a part of the conspiracy that Defendants JEFFREY EPSTEIN, and a/k/a " and other participants would make payments to, or cause payments to be made to, minor females in exchangAr 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 that Defendants JEFFREY EPSTEIN, a a a/k/a a" and other participants would make payments to, or cause payments to be made to, the recruiters for 7 EFTA00224680
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bringing additional minor females to 358 El Brillo Way and the New York residence 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. Overt Acts 30. In furtherance of this conspiracy and to effect the objects thereof, there was committed by at leastjent 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 (1) In or around the beginning of 2001, Defendant JEFFREY EPSTEIN engaged in sexual activity wi ane 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 Brill° Way upstairs to Defendant JEFFREY EPSTEIN's bedroom at 358 El Brillo Way. (3) In or around 2001, DefendantieFFREY 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 fourteen years' old, to pinch his nipples while he masturbated. 8 EFTA00224681
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(5) In or around 2001, Defendant JEFFREY EPSTEIN made a payment of $300 to Jane Doe #2. -r (6) In or around 2001, DefendanMIIM 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 unidentiked female in the presence of Jane Doe #2, who was then a fourteen- year-old girl. i • (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 H h 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 wo activities with him. (11) In or around 2003, Defendant be interested in engaging in similar of Jane Doe #2, who was then a sixteen-year-old girl. 9 took nude photographs EFTA00224682
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(12) In or around 2003, Defendant MINIMIEmade a payment of $500 to Jane Doe #2 in exchange for posing for nude photographs. (13) In or around 2003, Defendant allMeold Jane Doe #2 that Defendant JEFFREY EPSTEIN had asked ao take nude photographs of Jane Doe #2. (14) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of JaneDoe #2, who was then a sixteen-year-old girl. • (15) In of 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 IMIIIMIIplaced 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. I (17) On or about April 23, 2004, Defendant I 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 pcie #2. Jane Doe -43 (19) In or around 2003, Defendant JEFFREY EPSTEIN masturbated in the presence of Jane Doe #3, who was then a fifteen-year-old girl. 10 EFTA00224683
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(20) In or around 2003, Defendant JEFFREY EPSTEIN made .a payment of $200 to Jane Doe #3. (21) On or about October 26, 2004, DefendantIMIIIMII placed a telephone call to a telephone used by Jane Doe #3. (22) On or about October 30, 2004, DefendantMIMS placed a telephone call to a telephone used by Jane Doe #3. (23) Ilkor around 2004, Defendant JEFFREY EPSTEIN directed Jane Doe '4, #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-ek 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, DefendanttJEFFREY EPSTEIN placed a massaging device on the vagina of Jane Doe #3, who was then a sixteen- or seventeen-year-old girl. 11 EFTA00224684
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(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." (30) Qn„or about January 14, 2005, Defendant telephone call to if telephone used by Jane Doe #3. placed a (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." p • X 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 df 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #4 about her age, and Jane Doe #4 responded with her true age. 12 EFTA00224685
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(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, d 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 the4st half of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #4. (39) In or around the first hal f of 2004, Defendant JEFFREY EPSTEIN paid $200 to Jane Doe #5. (40) In or around the fust half oppoit, 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. 13 EFTA00224686
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(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. fi (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. irl. (45) II r around the first half of 2004, Defendant JEFFREY EPSTEIN caused a payment of $200 to be paid to Jane Doe #6. Jane Does #7 and #8 (46) In or around July 2004, Defendant JEFFREY EPSTEIN ledM., who was then a fifteen-year-old gjk.and Jane Doe #7, who was then a sixteen-years-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 made one pr more telephone calls 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 NI. 4- 14 EFTA00224687
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(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) 1p-9r around July 2004, Defendant JEFFREY EPSTEIN paid $200 to 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 Jul IS, 2004, Defendant- more telephone calls 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,-pefendant telephone call to a telephone used by mmt (57) On or about July 16, 2004, Defendant more telephone calls to a telephone used by Jane Doe #7. 15 placed one or ■ placed a ■ placed a placed one or EFTA00224688
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(58) On or about July 16, 2004, Defendant MB placed a telephone call to a telephone used bye. (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 fromin. that read: "Me & [Jane Doe #7] can come tomorrow any time or a.] alone". (60) Ip or around July 2004, Defendant JEFFREY EPSTEIN masturbated in the presence ()bane 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 v‘iis 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•Mad occurred at Defendant JEFFREY EPSTEIN's home, bad things could happeti to her. (65) On or about July 24, 2004, Defendant placed a telephone call to a telephone used by Jane Doe #8. 16 EFTA00224689
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Jane Does #9 and #10 (66) On or about July 15, 2004, DefendantIMEMS placed one or niorii telephone calls to a telephone used by Jane Doe #9. (67) On or about July 16, 2004, Defendan 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 telephone call to.a telephone used by Jane Doe #9. (69) On or about July 18, 2004, Defendant telephone call to a telephone used by Jane Doe #9. (70) On or about July 22, 2004, Defendant telephone call to a telephone used by Jane Doe #9. (71) In or around J 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. ME placed a MI placed a placed a (73) In or around July 2004, D?fendant 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. r 17 EFTA00224690
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(75) In or around the last half of 2004, Defendants JEFFREY EPSTEIN and engaged in oral sex and sexual intercourse in the presence Jime 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) Ipvy around the last hal f of 2004, Defendant JEFFREY EPSTErN made 16 a payment of S300-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 DJvo. (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, 20 Pefendan provided et —4 a written message to Defendant JEFFREY PSTEIN 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. 18 EFTA00224691
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Doe #10. (83) On or about December 30, 2004, Defendants JEFFREY EPSTEIN and caused the purchase of Broadway tickets as an eighteenth birthday Oft 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) btqr around the last half of 2004 or January 2005, Defendant JEFFREY r < EPSTEIN fondled' the breasts of Jane Doe #10, who was then a seventeen-year-old girl. (86) On or about January 14, 2005, Defendant placed one or more telephone calls to a telephone used by Jane Doe #10. (87) On or about Ji ary 27, 2005, Defendant , a/k/a placed one or more telephone calls to a telephone used by Jane (88) On or about January 28, 2005, Defendant placed one or more telephone calls to a telephone us by Jane Doe #10. a - (89) On or about February 1, 2005, Defendant 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 #I6 to travel to 358 El Brillo way. 19 EFTA00224692
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Jane Doe #11, (91) In or around 2004, Defendant JEFFREY EPSTEIN told Jane Doe #11 girt be 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 when she wou getting more girls. (94) n 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, [unide ed 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]." (95) On or about June 22, 2005, Defendant placed a telephone call to a telephone used by Jane pcie #11. Jane Does #12 and #13 (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 II. and Jane Doe #12 that stated: "They are available all weekend and maybe [Jane Doe #1 ] too". 20 EFTA00224693
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(97) On or about August 21, 2004, Defendant I....placed a telephone call to a telephone used by Jane Doe #13. a a) (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. (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 a seventeen-year-old girl. (101) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #12. (102) In or around th0i§t half of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #12, who was then a seventeen-year-old girl, about her age. (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. 23 (104) In or around the last half of . 4, Defendants JEFFREY EPSTEIN and 4 , caused Jane Doe #12 o recruit Jane Doe #13 to travel to 358 El Brillo Way. (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. fi 2! EFTA00224694
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(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- old (107) In or around the last half of 2004, Defendant JEFFREY EPSTEIN made a payment of $200 to Jane Doe #13. (108) In or around the last half of 2004, Defendant JEFFREY EPSTEIN digitally penetrttd Jane Doe #13, who was then a seventeen-year-old girl. (109) 14around the last hal f of 2004, Defendant JEFFREY EPSTEIN asked Jane Doe #13, who was then a seventeen-year-old girl, about her age. (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 yearsnold. (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]." Jane Doe #44 (112) In or around the last half of 2004, Defendant 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 #I4 to provide her telephone number. 22 EFTA00224695