EFTA00225672

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 NADIA 
MARCINK0VA 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 leastoneof 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 wi4ane 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 EPSTEEN's bedroom at 358 
El Brillo Way. 
(3) 
In or around 2001, DefendantJEFFREY 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 
EFTA00225832

Manner and Means 
29. 
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 IMME, 
a/k/a "Adriana Mucinska," NADIA MARCINKOVA, and other 
participants would contact minor females via the use of cellular and other telephones to 
arrange appointments for minor females to travel to 358 El Brillo Way and the New York 
residence to allow Defendant JEFFREY EPSTEIN to engage in lewd conduct with them. 
(b) 
It was further a part of the conspiracy that Defendants JEFFREY 
EPSTEIN, a, 
and 
a/k/a "Adriana Mucinska," 
and other participants would make payments to, or cause payments to be 
made to, minor females in exchangefor engaging in lewd conduct. 
(c) 
It was further a part of the conspiracy that Defendants JEFFREY 
EPSTEIN, 
Ma, 
a/k/a "Adriana Mucinska," and other 
participants would ask females to recruit other minor females to engage in lewd conduct with 
Defendant JEFFREY EPSTEIN. 
(d) 
It was further a part of the conspiracy that Defendants JEFFREY 
EPSTEIN, 
a, 
a/k/a "Adriana Mucinska," and other 
participants would make payments to, or cause payments to be made to, the recruiters for 
7 
EFTA00225833

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, 
ADRIANA ROSS, a/k/a "Adriana Mucinska," 
and 
NADIA MARCINKOVA, 
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 dr 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 
28. 
It was the purpose and object of the conspiracy to procure females under the 
age of 18 to travel to 358 El Brillo Way and the New York residence so that JEFFREY 
EPSTEIN could, in exchange for money, engage in lewd conduct with those minor females 
in order to satisfy JEFFREY EPSTEIN's prurient interests. 
6 
EFTA00225834

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: 
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, Beach 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 ofiler 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 involvernent with the Defendants, Jane Doe #13 
attended John I. Leonard High School in Palm Beach County. 
5 
EFTA00225835

13. 
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 
lascivions 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. 
Pursuafit 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 cannoplbe 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 wa-S over the age of 24 and did not have any 
medical license. 
4 
EFTA00225836

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 degree." For purposes of "this section, `sexual activity' means oral, anal, or vaginal 
penetration by, or union with, the sexual organ of another; however, sexual activity does not 
include an act done for a bona fide medical purpose." Florida Statutes Section 794.021 states 
that "ignorance of the age [of the victim] is no defense," and that neither "misrepresentation 
of age by [the victim].nor a bona fide belief that such person is over the specified age (shall] 
be a defense." 
11. 
Pursuant to Florida Statutes Sections 800.04(5)(a) and 800.04(5)(c)(2), an adult 
t ho 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 agetio 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(6)(b), an adult 
"who [i]ntentionally touches a person under 16 yearA 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 
EFTA00225837

2. 
Defendant JEFFREY EPSTEIN employed L.G. to perform, among other 
things, services as a personal assistant. 
4 1 
;Defendants JEFFREY EPSTEIN and SARAH KELLEN paid T.M., H.R., and 
A.F. to perform, among other things, recruiting services. 
4. 
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"). 
5. 
DefendtCSt JEFFREY 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 JEGE, INC., a 
Delaware corporation. JEGE, INC.'s sole business activities related to the operation and 
ownership of a Boeing 727-31 aircrifthearing tail number N908J13. 
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 solehusiness activities related to the operation 
and ownership of a Gulfstream G-1159B aircrafttearing tail number N909JE. 
9. 
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. 
i 
2 
EFTA00225838

*/z_qlog 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT O1? FLORIDA 
21 
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.Q. § 2423(e) 
18 U.S.C. § 2423(d) 
18 U.S.C. § 2423(b) 
UNITED STATES 4AMERICA 
1 
vs. 
FFREY EPSTEIN, 
and NAD A 
ARCINK 
, 
Defendants. 
INDICTMENT 
The Grand Jury charges that: 
BACKGROUND 
At all times relevant to this Indictment: 
1. 
Defendant JEFFREY EPSTEIN employed defendants 
a/k/a "Adriana Mucinska," and NADIA MARCINKOVA to perform, 
among other things, services as personal assistants. 
I! 
EFTA00225839

New Jane 
Doe # 
Old 
Jane 
Doe # 
DOB 
Range of activity 
dates 
Overt Acts 
Substantive 
Counts 
GJ Transcript Pages 
13 
13 
May 1987 
8/04 -5/05 
96, 97, 104-111 
7, 18 
14 
5 
June 1987 
11/04 - 3/05 
.112-131 
\iiitNi, 27 
\
cAl, 
5/22/07 NK Transcript 
pp. 4-13 
15 
3 
June 1987 
12/04 - 6/5/05 
132-148, 175 
27 
3/20/07 NK Transcript 
pp. 4-22 
5/15/07 NK Transcript 
m
i. 3-17
Transcript 
pp. 23-25, 27-28 
16 
8 
October 1987 
2/05 - 10/05 
\30, 149-151, 156- 
181 
x+10 '21, 27, 
29 
28, 
5/22/07 NK Transcript 
pp. 39-47 
17 
9 
April 1988 
2/05 - 3/05 
150-155 
\.22 
18 
n/a 
February 1986 
8/03 - 3/04 
182-188, 190 
23 
19 
n/a 
May 1986 
3/04 
189-190 
n/a 
T.M. 
n/a 
July 1988 
2003-2005 
48, 52, 56; 58,.59 
n/a 
5/8/07 NK Transcript 
pp. 3-12 
A.F. 
n/a 
n/a 
n/a 
182 
n/a 
Transcript 
pp. 5-13, 27 
5/8/07 NK Transcript 
pp. 24-25 
CONFIDENTIAL & PRIVILEGED 
2 
ATTORNEY WORK PRODUCT 
EFTA00225840

4-12A/os 
OPERATION LEAP YEAR 
REVISED INDICTMENT SUMMARY CHART (by victitul 
New Jane 
Doe # 
Old 
Jane 
Doe # 
DOB 
Range of activity 
dates 
Overt Acts 
Substantive 
Counts 
GJ Transcript Pages 
1 
n/a 
August 1983 
1998 - 2003 
1 
n/a 
2 
n/a 
January 1987 
2001 to 2003 
1-18 
2 
5/8/07 NK Transcript 
pp. 6-7 
3 
n/a 
October 1987 
2003 
19-31 
12 
4 
n/a 
August 1986 
2004 
32-38, 41 
3 
5 
n/a 
October 1986 
2004 
32, 34, 39 
n/a 
6 
n/a 
June 1987 
2004 
40-45 
n/a 
7 
12 
April 1988 
7/04 
46, 47, 54, 57, 
59-64 
13, 26 
8 
n/a 
November 1986 
7/04 - 11/04 
49-53, 55, 65 
14, 26 
9 
6 
December 1986 
7/04 - 12/04 
66-73, 75-77, 80- 
83, 90 
4, 15, 26 
5/22/07 NK Transcript 
pp. 16-27 
10 
7 
February 1987 
7/04 - 11/05 
67, 74, 78-79, 81, 
84-89, 147 
5, 16, 26 
5/22/07 NK Transcript 
pp. 25-37 
11 
n/a 
October 1986 
2004-2005 
91-95 
n/a 
12 
14 
April 1987 
8/04 - 2/05 
96, 98-104 
6, 17 
CONFIDENTIAL & PRIVILEGED 
ATTORNEY WORK PRODUCT 
EFTA00225841

K. 
JANE DOE # 19 a 
H.) 
1. 
Who is Jane Doe # 19? Have you testified about her previously? 
2. 
Has she been interviewed? 
3. 
During what period of time did Jane Doe # 19 have contact with JE? 
4. 
How old was she during that time frame? 
5. 
How did she meet JE? 
6. 
And what sexual activity was she involved in with JET 
7. 
How much was she paid? 
8. 
Did she recruit anyone to go to JE's home? 
9. 
Does your testimony cover the evidence supporting the allegations in overt acts 
189-190? 
EFTA00225842

J. 
JANE DOE # 18 (a 
A.) 
1. 
Who is Jane Doe # 18? Have you testified about her previously? 
2. 
Has she been interviewed? 
3. 
During what period of time did Jane Doe # 18 have contact with JE? 
4. 
How old was she during that time frame? 
5. 
How did she meet JE? 
6. 
And what sexual activity was she involved in with JE? 
7. 
How much was she paid? 
8. 
Did she recruit anyone to go to JE's home? 
9. 
Does your testimony cover the evidence supporting the allegations in overt acts 
182-188, 190? 
10. 
Let's refer to Count 23. Is the evidence you just summarized the basis for the 
allegation that JE, and SK used a facility of interstate commerce to persuade, 
induce and entice Jane Doe # 18 to engage in prostitution and in sexual activity 
for which a person can be charged with an offense? 
a. 
How many tele hone calls have you been able to document between Jane 
Doe # 18 and 
? 
EFTA00225843

I. 
JANE DOE # 13 (Dainya N.) 
1. 
Who is Jane Doe # 13? Have you testified about her previously? 
2. 
Has she been interviewed? 
3. 
During what period of time did Jane Doc # 13 have contact with JE? 
4. 
How old was she during that time frame? 
5. 
How did she meet YE? 
6. 
And what sexual activity was she involved in with JE? 
7. 
How much was she paid? 
8. 
Did she recruit anyone to go to JEs home? 
9. 
Does your testimony cover the evidence supporting the allegations in overt acts 
96, 97, 104-111? 
10. 
Let's refer to Count 07. Is the evidence you just summarized the basis for the 
allegation that JE, and SK procured Jane Doc # 13 to engage in commercial sex 
acts knowing that she was under 18? 
11. 
Let's refer to Count 18. Is the evidence you just summarized the basis for the 
allegation that JE, and SK used a facility of interstate commerce to persuade, 
induce and entice Jane Doe # 13 to engage in prostitution and in sexual activity 
for which a person can be charged with an offense? 
a. 
How many telsl
 calls have you been able to document between Jane 
Doe # 13 and 
EFTA00225844

JANE DOE # 12 (a 
S.) 
I. 
Who is Jane Doe # 12? Have you testified about her previously? 
2. 
Has she been interviewed? 
3. 
During what period of time did Jane Doe # 12 have contact with JE? 
4. 
How old was she during that time frame? 
5. 
How did she meet JE? 
6. 
And what sexual activity was she involved in with JE? 
7. 
How much was she paid? 
8. 
Did she recruit anyone to go to JE's home? 
9. 
Does your testimony cover the evidence supporting the allegations in overt acts 
96, 98-104? 
10. 
Let's refer to Count 06. Is the evidence you just summarized the basis for the 
allegation that JE, and SK procured Jane Doe # 12 to engage in commercial sex 
acts knowing that she was under 18? 
11. 
Let's refer to Count 17. Is the evidence you just summarized the basis for the 
allegation that JE, and SK used a facility of interstate commerce to persuade, 
induce and entice Jane Doe # 12 to engage in prostitution and in sexual activity • 
for which a person can be charged with an offense? 
a. 
How many telephone calls have you been able to document between Jane 
Doe # 12 and Kellen? 
EFTA00225845

G. 
JANE DOE # 8 a 
E.) 
1. 
Who is Jane Doe # 8? Have you testified about her previously? 
2. 
Has she been interviewed? 
3. 
During what period of time did Jane Doe # 8 have contact with JE? 
4. 
How old was she during that time frame? 
5. 
How did she meet JE? 
6. 
And what sexual activity was she involved in with JE? 
7. 
How much was she paid? 
8. 
Did she recruit anyone to go to JE's home? 
9. 
Does your testimony cover the evidence supporting the allegations in overt acts 
49-53, 55, 65? 
EFTA00225846

F. 
JANE DOE # 7 
L.) 
1. 
Who is Jane Doe # 7? Have you testified about her previously? 
2. 
Has she been interviewed? 
3. 
During what period of time did Jane Doe #1 have contact with JE? 
4. 
How old was she during that time frame? 
5. 
How did she meet JE? 
6. 
And what sexual activity was she involved in with JE? 
7. 
How much was she paid? 
8. 
Did she recruit anyone to go to JE's home? 
9. 
Does your testimony cover the evidence supporting the allegations in overt acts 
46, 47, 54, 57, 59-64? 3,
10. 
Let's refer to Count N.Is the evidence you just summarized the basis for the 
allegation that JE and SK used a facility of interstate commerce to persuade, 
induce and entice Jane Doe # 7 to engage in prostitution and in sexual activity 
for which a person can be charged with an offense? How many telephone calls 
have you been able to document between Jane Doe # 7 and Kellen? 
1. 
Dt: a -raki,, /1/44:1 ter vcc. Y1AA: 
Wirt- 
-ebt 
EFTA00225847

persuade, induce and entice Jane Doe # 16 to engage in prostitution and in sexual 
activity for which a person can be charged with an offense? 
a. 
How many to 
one calls have you been able to document between Jane 
Doe # 16 and 
Between Jane Doe # 16 and Ross? And between 
Jane Doe # 16 and 
? 
17. 
What was the sexual activity that Jane Doe # 16 and B3 engaged in that also 
violated Fl. Stat. 794.05? (Sexual intercourse between an adult over 24 and a 
minor) 
. 
18. 
Does your prior testimony and your testimony today cover the evidence 
supporting the allegations and overt acts 150-155? 
19. 
Lees refer to Count 22. Is the evidence you just summarized the basis for the 
allegation that JE and SK used a facility of interstate commerce to persuade, 
induce and entice Jane Doe # 17 to engage in prostitution and in sexual activity 
for which a person can be charged with an offense? 
EFTA00225848

E. 
JANE DOE # 16 (MI D.) and JANE DOE # 17 a 
D.) 
1. 
Who is Jane Doe # 16? Have you testified about her previously? 
a. 
Is there anything that you want to clarify or add regarding your earlier 
testimony? 
2. 
Please remind the grand jury, during what period of time did Jane Doe # 16 have 
contact with JE? 
3. 
How old was she during that time frame? 
4. 
Please summarize the sexual activity that Jane Doe # 16 was involved in with JE? 
5. 
Did Jane Doe # 16 recruit anyone to go to JE's home? 
JANE DOE # 17 a 
D.) 
6. 
Who is Jane Doe # 17? Have you testified about her previously? 
7. 
Has she been interviewed? 
8. 
During what period of time did Jane Doe # 17 have contact with JET 
9. 
How old was she during that time frame? 
10. 
How did she meet JE? 
11. 
And what sexual activity was she involved in with JE? 
12. 
How much was she paid? 
13. 
Did she recruit anyone to go to JE's home? 
JANE DOE 16 ( 
D.) and JANE DOE # 17 (- 
D.) 
14. 
Does your prior testimony and your testimony today cover the evidence 
supporting the allegations and overt acts 90, 149-151 and 156-181? 
15. 
Let's refer to Count 10. Is the evidence you just summarized the basis for the 
allegation that 3E, SK, AR and NM procured Jane Doe # 16 to engage in 
commercial sex acts knowing that she was under 18? 
16. 
Let's refer to Count 21. Is the evidence you just summarized the basis for the 
allegation that JE, SK, AR and NM used a facility of interstate commerce to 
EFTA00225849

B. 
Now, with respect to each of those girls, can you summarize for the grand 
jury your efforts to independently corroborate their statements? What 
physical evidence corroborates their statements to law enforcement? 
Page 11 of 11 
EFTA00225850

a. 
Is there anything that you want to clarify or add regarding 
your earlier testimony? 
2. 
Please remind the grand jury, during what period of time did Jane 
Doe #16 have contact with JE? 
3. 
How old was she during that time frame? 
4. 
Please summarize the sexual activity that Jane Doe #16 was involved 
in with JE? 
5. 
Does your prior testimony and your testimony today cover the 
evidence supporting the allegations in overt acts 90, 149-151, and 
156-181? 
6. 
Let's refer to Count 10. Is the evidence ou just summarized the 
basis for the allegation that JE, SK, 
and 
a
procured Jane Doe #16 to engage in commercial sex 
acts knowing that she was under 18? 
7. 
Let's refer to Count 21. Is the evidence ou ust summarized the 
basis for the allegation that JE,. SK, 
and 
a
used a facility of interstate commerce to persuade, 
induce, and entice Jane Doe #16 to engage in prostitution and in 
sexual activity for which a person can be charged with an offense? 
a. 
How many telephone calls have you been able to document 
between Jane Doe #16 and Kellen? Between Jane Doe #16 
and Ross? And between Jane Doe #16 and a? 
8. 
What was the sexual activity that Jane Doe #16 and JE engaged in 
that also violated Fl. Stat. 794.05? [Sexual intercourse between an 
adult over 24 and a minor] 
IX. 
PRIOR DRUG USE/MENTAL HEALTH ISSUES 
A. 
Today we have discussed 11 victims — Jane Does 1 through 6, 9, 10, and 14 
through 16. Are you aware of whether any of them have used illicit drugs 
or have had mental health issues? Please summarize. 
Page 10 of 11 
EFTA00225851