EFTA00225102

proposed agreements with the State Attorney's Office prior to entering 
into those agreements. 
7. 
The United States shall provide Epstein's attorneys with a list of 
individuals whom it has identified as victims, as defined in 18 U.S.C. 
§ 2255, after Epstein has 
this agreement and been sentenced. 
Upon the execution of this agreement, the United States, in consultation 
with and subject to the good faith approval of Epstein's counsel, shall 
select an attorney representative for these persons, who shall be paid for 
by Epstein. Epstein's counsel may contact the identified individuals 
through that representative. 
8. 
If any of the individuals referred to in paragraph (7), supra, elects to 
file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the 
jurisdiction of the United States District Court for the Southern District 
of Florida over his person and/or the subject matter, and Epstein waives 
his right to contest liability and also waives his right to contest damages 
up to an amount as agreed to between the identified individual and 
Epstein, so long as the identified individual elects to proceed 
exclusively under 18 U.S.C. § 2255, and agrees to waive any other 
claim for damages, whether pursuant to state, federal, or common law. 
Notwithstanding this waiver, as to those individuals whose names 
appear on the list provided by the United States, Epstein's signature on 
this agreement, his waivers and failures to contest liability and such 
damages in any suit arc not to be construed as an admission of any 
criminal or civil liability. 
9. 
Epstein's signature on this agreement also is not to be construed as an 
admission of civil or criminal liability or a waiver of any jurisdictional 
or other defense as to any person whose name does not appear on the 
list provided by the United States. 
10. 
Except as to those individuals who elect to proceed exclusively under 
18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's 
signature on this agreement, nor its terms, nor any resulting waivers or 
settlements by Epstein arc to be construed as admissions or evidence of 
civil or criminal liability or a waiver of any jurisdictional or other 
defense as to any person, whether or not her name appears on the list 
provided by the United States. 
11. 
Epstein shall use his best efforts to enter his guilty plea and be 
Page 4 of 7 
EFTA00225202

sentenced not later than October 26, 2007. The United States has no 
objection to Epstein self reporting to begin serving his sentence not 
later than January 4, 2008. 
12. 
Epstein agrees that he will not be afforded any benefits with respect to 
gain time, other than the rights, opportunities, and benefits as any other 
inmate, including but not limited to, eligibility for gain time credit 
based on standard rules and regulations that apply in the State of 
Florida. At the United States' request, Epstein agrees to provide an 
accounting of the gain time he earned during his period of 
incarceration. 
13. 
The parties anticipate that this agreement will not be made part of any 
public record. If the United States receives a Freedom of Information 
Act request or any compulsory process commanding the disclosure of 
the agreement, it will provide notice to Epstein before making that 
disclosure. 
Epstein understands that the United States Attorney has no authority to require the 
State Attorney's Office to abide by any terms of this agreement. Epstein understands that 
it is his obligation to undertake discussions with the State Attorney's Office and to use his 
best efforts to ensure compliance with these procedures, which compliance will be necessary 
to satisfy the United States' interest. Epstein also understands that it is his obligation to use 
his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding 
recommendation regarding the sentence to be imposed, and understands that the failure to 
do so will be a breach of the agreement. 
In consideration of Epstein's agreement to plead guilty and to provide compensation 
in the manner described above, if Epstein successfully fulfills all of the terms and conditions 
of this agreement, the United States also agrees that it will not institute any criminal charges 
• 
- 
hat 
• 
• 
'rig but not limited to
,
or 
Further, upon execution o this 
agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury 
investigation will be suspended, and all pending federal Grand Jury subpoenas will be held 
in abeyance unless and until the defendant violates any term of this agreement. The 
defendant likewise agrees to withdrew his pending motion to intervene and to quash certain 
grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence 
requested by or directly related to the grand jury subpoenas that have been issued, and 
including certain computer equipment, inviolate until all of the terms of this agreement have 
been satisfied. Upon the successful completion of the terms of this agreement, all 
outstanding grand jury subpoenas shall be deemed withdrawn. 
Page 5 of 7 
EFTA00225203

By signing this agreement, Epstein asserts and certifies that each of these terms is 
material to this agreement and is supported by independent consideration and that a breach 
of any one of these conditions allows the United States to elect to terminate the agreement 
and to investigate and prosecute Epstein and any other individual or entity for any and all 
federal offenses. 
By signing this agreement, Epstein asserts and certifies that he is aware of the fact that 
the Sixth Amendment to the Constitution of the United States provides that in all criminal 
prosecutions the accused shall enjoy the right to a speedy and public trial. Epstein further 
is aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Court 
may dismiss an indictment, information, or complaint for unnecessary delay in presenting 
a charge to the Grand Jury, tiling an information, or in bringing a defendant to trial. Epstein 
hereby requests that the United States Attorney for the Southern District of Florida defer such 
prosecution. Epstein agrees and consents that any delay from the date of this Agreement to 
the datc of initiation of prosecution, as provided for in the terms expressed herein, shall be 
deemed to be a necessary delay at his own request, and he hereby waives any defense to such 
prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of 
the Federal Rules ofCriminal Procedure and the Sixth Amendment to the Constitution of the 
United States to a speedy trial or to bar the prosecution by reason of the running of the statute 
of limitations for a period of months equal to the period between the signing of this 
agreement and the breach of this agreement as to those offenses that were the subject of the 
grand jury's investigation. Epstein further asserts and certifies that he understands that the 
Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all 
felonies must be charged in an indictment presented to a grand jury. Epstein hereby agrees 
and consents that, if a prosecution against hint is instituted for any offense that was the 
subject of the grand jury's investigation, it may be by way of an Information signed and filed 
by the United States Attorney, and hereby waives his right to be indicted by a grand jury as 
to any such offense. 
III 
/1/ 
111 
Page 6 of 7 
EFTA00225204

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
IL ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated: 
Dated: 
A. MARIE VILLAPARA 
ASSISTANT U.S. ATTORNEY 
°BRAID LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Pogo 7 of 7 
!A' 
EFTA00225205

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non. 
Prosecution Agreement and agrees to comply with them. 
IL ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated: 
 
By: 
A. MARIE VILLAPARA 
ASSISTANT U.S. ATTORNEY 
Dated: 
Dated:  ? 12-9107 
Dated: 
JEFFREY EPSTEIN 
RA 
C°Q6t
4ta91-
OUNSEL TO JEFF 
Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page 7 of 7 
EFTA00225206

By signing this agreement, Epstein asserts and certifies that the above has been read 
and explained to him. Epstein hereby states that he understands the conditions of this Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNTTED STATES ATTORNEY 
Dated: 
 
By: 
Dated: 
Dated: 
Datiedg—Aid—o 
A. MARIE VILLAPARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
GERALD LEPCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
Page 7 of 7 
EFTA00225207

IN RE: 
INVESTIGATION OF 
JEFFREY EPSTEIN 
ADDENDUM TO THE NON-PROSECUTION AGREEMENT 
IT APPEARING that the parties seek to clarify certain provisions of page 4, paragraph 7 
of the Non-Prosecution Agreement (hereinafter "paragraph 7"), that agreement is modified as 
follows: 
7A. 
The United States has the right to assign to an independent third-party the responsibility 
for consulting with and, subject to the good faith approval of Epstein's counsel, selecting 
the attorney representative for the individuals identified under the Agreement. If the 
United States elects to assign this responsibility to an independent third-party, both the 
United States and Epstein retain the right to make good faith objections to the attorney 
representative suggested by the independent third-party prior to the final designation of 
the attorney representative. 
The parties will jointly prepare a short written submission to the independent third-party 
regarding the role of the attorney representative and regarding Epstein's Agreement to 
pay such attorney representative his or her regular customary hourly rate for representing 
such victims subject to the provisions of paragraph C, infra. 
7C. 
Pursuant to additional paragraph 7A, Epstein has agreed to pay the fees of the attorney 
representative selected by the independent third party. This provision, however, shall not 
obligate Epstein to pay the fees and costs of contested litigation filed against him. Thus, 
if after consideration of potential settlements, an attorney representative elects to file a 
contested lawsuit pursuant to IS U.S.C. s 2255 or elects to pursue any other contested 
remedy, the paragraph 7 obligation of the Agreement to pay the costs of the attorney 
representative, as opposed to any statutory or other obligations to pay reasonable 
attorneys fees and costs such as those contained in 3 2255 to bear the costs of the attorney 
representative, shall cease. 
EFTA00225208

By signing this Addendum, Epstein asserts and certifies that the abovo has been read and 
explained to him. Epstein hereby. states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated:  (0/3 b /07 
Dated:  I7 i' 'II-
Dated: 
Dated: 
By: 
41-LISHa4A-- MI41/3-
7€ A. MARIE VILLAPANA 
ASSISTANT U.S. ATTORNEY 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00225209

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
Dated:  ID h 1947
Dated: 
Dated: 
By: 
vit._
 tin
t( 
s'A 
pi A. MARIE V LAFARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY EPSTEIN 
ERALD LEFCO RT ESQ. 
COUNSEL TO JEFFR Y EPSTEIN 
LILLY ANN SANCHEZ, ESQ. 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00225210

By signing this Addendum, Epstein asserts and certifies that the above has been read and 
explained to him. Epstein hereby states that he understands the clarifications to the Non-
Prosecution Agreement and agrees to comply with them. 
Dated: /0 /3 DA '7 
Date': 
Dated: 
Dated: 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
By: 
11‘ e
 finiet.-- 
/54141
4 A. MARIE VILLAFARA 
ASSISTANT U.S. ATTORNEY 
JEFFREY BPSTER4 
GERALD LEFCOURT, ESQ. 
COUNSEL TO JEFFREY EPSTEIN 
LILLY A 
ANCHEZ, ES 
ATTORNEY FOR JEFFREY EPSTEIN 
EFTA00225211

U.S. Department nfitist ire 
United States Attorney 
Southern District of Florida 
R ALEXANDER ACOSTA 
UNITEDSTATES ATTORNEY 
DELIVERY BY FACSIMILE 
Lilly Ann Sanchez 
Fowler White Burnett, PA 
1395 Brickell Ave, 14th Floor 
Miami, FL 33131 
Re: 
Jeffrey Epstein 
Dear Ms. Sanchez: 
99 N F. 4 Sinter 
Mont A. DM 
0031 961-9100 • rettphone 
(J03) .110-044 • Foonnik 
December 19, 2007 
I write to follow up on the December 14th meeting between defense counsel and the Epstein 
prosecutors, as well as our First Assistant, the Miami FBI Special Agent in Charge and myself.' I 
write to you because I am not certain who among the defense team is the appropriate recipient of this 
letter. I address issues raised by several members of the defense team, and would thus ask that you 
please provide a copy of this letter to all appropriate defense team members. 
First, I would like to address the Section 2255 issue.2 As I stated in my December 4" letter, 
my understanding is that the Non-Prosecution Agreement entered into between this Office and Mr. 
Epstein responds to Mr. Epstein's desire to reach a global resolution of his state and federal criminal 
liability. Under this Agreement, this District has agreed to defer prosecution for enumerated sections 
Over the past two weeks, we have received several hundred pages of arguments and exhibits from defense counsel. 
This is not the forum to respond to the several items raised, and our silence should not be interpret as agreement; I 
would, however, like to address one issue. Your December I I d' letter states that as a result of defense counsel 
objections to the appointment process, die USAO proposed an addendum to the Agreement to provide for the use of 
an independent third party selector. As I recall this matter, before I had any knowledge of defense counsel 
objections, I sua sponge proposed the Addendum to Mr. Lctkowitz at an October meeting in Palm Beach. I did this 
in an attempt to avoid what I foresaw would likely be a litigious selection process. It was only after I proposed this 
change that Mr. Lefkowitz raised with me his enumerated concerns. 
2 Section 2255 provides that: "haply person who, while a minor, was a victim of a violation of (enumerated sections 
of Title IC and who suffers personal injury as a result of such violation . .. may sue in any appropriate United States 
District Court and shall recover the actual damages such person sustains and the cost of the suit including a 
reasonable attorney's fee." 
EFTA00225212

I • 
of Title 18 in favor of prosecution by the State of Florida, provided that the Mr. Epstein satisfies 
three general federal interests: (I) that Mr. Epstein plead guilty to a "registerable" state offense; (2) 
that this state plea include a binding recommendation for a sufficient term of imprisonment; and (3) 
that the Agreement not harm the interests of his victims. 
With this in mind, I have considered defense counsel arguments regarding the Section 2255 
portions of the Agreement. As I previously observed, our intent has been to place the victims in the 
same position as they would have been had Mr. Epstein been convicted at trial. No more; no less. 
From our meeting, it appears that the defense agrees that this was the intent. During the course of 
negotiations that intent was reduced to writing in Paragraphs 7 and 8, which as I wrote previously, 
appear far from simple to understand. I would thus propose that we solve our disagreements over 
interpretations by saying precisely what we mean, in a simple fashion. I would replace Paragraphs 7 
and 8 with the following language: 
"Any person, who while a minor, was a victim of a violation of an offense enumerated in 
Title 18, United States Code, Section 2255, will have the same rights to proceed under 
Section 2255 as she would have had, if Mr. Epstein been tried federally and convicted of an 
enumerated offense. For purposes of implementing this paragraph, the United States shall 
provide Mr. Epstein's attorneys with a list of individuals whom it was prepared to name in an 
Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial authority 
interpreting this provision, including any authority determining which evidentiary burdens if 
any a plaintiff must meet, shall consider that it is the intent of the parties to place these 
identified victims in the same position as they would have been had Mr. Epstein been 
convicted at trial. No more; no less." 
Second, I would like to address the issue of victim's rights pursuant to Section 3771. I 
understand that the defense objects to the victims being given notice of time and place of Mr. 
Epstein's state court sentencing hearing. I have reviewed the proposed victim notification letter and 
the statute. I would note that the United States provided the draft letter to defense as a courtesy. In 
addition, First Assistant United States Attorney Sloman already incorporated in the letter several 
edits that had been requested by defense counsel. I agree that Section 3771 applies to notice of 
proceedings and results of investigations of federal crimes as opposed to the state crime. We intend 
to provide victims with notice of the federal resolution, as required by law. We will defer to the 
discretion of the State Attorney regarding whether he wishes to provide victims with notice of the 
state proceedings, although we will provide him with the information necessary to do so if he wishes. 
Third, I would like to address the issue raised segarding Florida Statute Section 796.03. At 
our meeting, Professor Dershowitz took the position that Mr. Epstein believes that his conduct does 
not satisfy the elements of this offense. His assertion raises for me substantial concerns. This Office 
will not, and cannot, be a party to an agreement in which Mr. Epstein pleads guilty to an offense that 
he believes he did not commit. We are considering how best to proceed. 
2 
EFTA00225213

Finally, 1 would like to address a more general point. Our Agreement was first signed on 
September 241h, 2007. Pursuant to paragraph II , Mr. Epstein was to use his best efforts to enter his 
guilty plea and be sentenced no later than October 26, 2007. As outlined in correspondence between 
our prosecutors and defense counsel, this deadline came and went. Our prosecutors reiterated to 
defense counsel several times their concerns regarding delays, and in fact, asked me several weeks 
ago to declare the Agreement in breach because of those delays. I resisted that invitation. 1 share 
this fact because it is background to my frustration with what appears to be an I d' hour appeal, 
weeks before the now scheduled January 461 plea date. 
This said, the issues raised are important and must be fully vetted irrespective of timeliness 
concerns. We hope to preserve the January 44 date. I understand that defense counsel shares our 
desire not to move that appearance and will work with our office to expedite this process over the 
next several days. With this in mind, a r in the event that defense counsel may wish to seek review 
of our determinations in Washington 
, I spoke this past Monday with the Assistant Attorney 
General Fisher, to inform her of a possible appeal, to ask her to grant the potential request for review, 
and to in fact review this case in an expedited manner to attempt to preserve the January 4th plea date. 
I want to again reiterate that it is not the intention of this Office ever to force the hand of a 
defendant to enter into an agreement against his wishes. Your client has the right to proceed to trial, 
and he shout do so if he believes that he did not commit the elements of the charged offense. 
I will respond to the pending issues shortly. In the interim, I would ask that you 
communicate your position with respect to the sections 2255 and 3371 issues as quickly as possible. 
Sincerely, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
cc: 
Alice Fisher, Assistant Attorney General 
Jeffrey Sloman, First Assistant U.S. Attorney 
AUSA A. Marie Villafatla 
3 
EFTA00225214

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(aX2) 
18 U.S.C. § 2422(b) 
18 U.S.C. § 242 
18 U.S.C. § 2423k 
18 U.S.C. § 2423 ) 
UNITED STATES &AMERICA 
a. 
vs. 
FFREY EPSTEIN, 
and 
Defendants. 
INDICTMENT 
The Grand Jury charges that: 
BACKGROUND 
At all times relevant to this Indictment: 
I. 
Defendant JEFFREY EPSTEIN employed defendants 
" and 
among other things, services as personal assistants. 
to perform, 
EFTA00225215

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(aX2) 
18 U.S.C. § 2422(6) 
18 U.S.C. § 2423( 
18 U.S.C. § 2423( 
18 U.S.C. § 2423( 
UNITED STATES RAMERICA 
vs. 
JEFFREY EPSTEIN, 
M
an
" " 
'ana Mucinska," 
9 
Defendants. 
INDICTMENT 
The Grand Jury charges that: 
BACKGROUND 
At all times relevant to this Indictment: 
I. 
Defendant JEFFREY EPSTEIN employed defendants 
"and 
among other things, services as personal assistants. 
to perform, 
EFTA00225216

2. 
Defendant JEFFREY EPSTEIN. employed L.G. to perform, among other 
things, services as a personal assistant. 
31 
Defendants JEFFREY EPSTEIN and 
_FL? 
paid I., I.
 and 
to perform, among other things, recruiting services. 
4. 
Defendant JEFFREY EPSTEIN owned a propetty located at 358 El Brillo Way, 
Palm Beach, Florida, in the Southern District of Florida (hereinafter referred to as "358 El 
Brillo Way"). 
5. 
De fen thintlEFFREY EPSTEIN owned a property located at 9 East 71st Street, 
New York, New York (hereinafter referred to as "the New York residence"). 
6. 
Defendant JEFFREY EPSTEIN was the principal owner of WOE, INC., a 
Delaware corporation. JEGE, INC.'s sole business activities related to the operation and 
ownership of a Boeing 727-31 aircrjeft,bearing tail number N908JE. 
7. 
Defendant JEFFREY EPSTEIN served as president, sole director, and sole 
shareholder of JEGE, INC., and had the power to direct all of its operations. 
8. 
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. 
9. 
Defendant JEFFREY EPSTEIN served as president, sole director, and sole 
shareholder of Ilyperion Air, Inc., and had the power to direct all of its operations. 
2 
EFTA00225217

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 degtee." 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] no( a bona tide belief that such person is over the specified age [shall] 
t4: 
be a defense." 
11. 
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 agetil so touch the perpetrator, commits lewd or lascivious 
molestation," which is a felony of the second degree i f 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 [i]ntentionally 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 
EFTA00225218

13. 
Pursuant to Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult 
"who: (I) [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]tle 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]." 
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-over the age of 24 and did not have any 
medical license. 
4 
EFTA00225219

18. 
During the period of her involvement with the Defendants, Jane Doe #4 
attended Wellington High School and Palm Beach Central High School in Palm Beach 
County.
L._ 
19. 
During the period of her involvement with the Defendants, Jane Doe #5 
attended Wellington High School in Palm Beach County. 
20. 
During the period of their involvement with the Defendants, Jane Does # 6, 8 
and 12 attended Palm )3each Central High School in Palm Beach County. 
21. 
During the period of her involvement with the Defendants, Jane Doe #7 
attended William T. Dwyer High School 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 Royal Palm Beach High School in Palm Beach County. 
23. 
During the period °fret involvement with the Defendants, Jane Doe #10 
attended Lake Worth High School in Palm Beach County. 
24. 
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. 
25. 
During the period of her involverftent with the Defendants, Jane Doe #13 
attended John I. Leonard High School in Palm Beach County. 
5 
EFTA00225220

COUNT 1, 
(Conspiracy: 18 U.S.C. § 371) 
26... 
Paragraphs 1 through 25 of this Indictment are re-alleged and incorporated by 
reference its 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, 
did knowingly and willfully combine, conspire, confederate and agree with each other and 
with others known and unknown to cpmmit an offense against the United States, that is, to 
t
use a facility or means of interstate Or faireign 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 
28. 
It was the purpose and object of thcbnspiracy 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 
EFTA00225221