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Jane Doe #10 for bringing her. Epstein asked Jane Doe #11 to leave her phone number because he 
wanted to see her again. 
Jane Doe #11 advised that she never went back and she stopped talking to Jane Doe #10 because 
she was upset over what happened. Jane Doe #10's phone records show three calls to Jane Doe #11 on 
12/18/04, which is consistent with her recollection of the time frame. 
1. Overt Acts Based upon Activity with Jane Doe #11 
Because there was no direct conduct between Epstein's group and Jane Doe #11, the only act 
related to Jane Doe #11 is 
causing Jane Doe #10 to call Jane Doe #11. 
#_. On December 18, 2004, Defendant 
caused Jane Doe #10 to make one or more 
telephone calls to a telephone used by Jane Doe #11. 
2. Substantive Offenses related to Jane Doe # 11 
Count 
Date(s) 
Offense 
Statute 
Defendant(s) 
14 
12/18/04 
Use of cellular phone to persuade, 
induce, or entice Jane Doe #3 to 
engage in prostitution 
2422(b) 
EPSTEIN 
L. JANE DOE #12 (
. 
Jane Doe # 12 attended William T. Dwyer High School. She was recruited by 
to go 
to Epstein's house when she was 16 years' old. M 
also went to Epstein's house and performed 
sexual services starting when she was 15. 
refused to speak to police and the FBI, telling them 
that she was still in love with Epstein. 
was compelled via 6001 immunity to provide information. 
e 
She admitted that she brought around 30 girls to Epstein's house, including Jane Doe #12. 
says 
that she considers Epstein to be "the awesomest guy in the world," and she would marry him if he asked 
her. When asked if she ever brought a girl that Epstein did not like, she said: 
Yeah, once. I made a mistake. 
I brought a black girl. Not that 
Jeffrey is a racist. He still paid 
her, but he wouldn't let her 
massage him. 
is too volatile and hostile to be called as a witness for the United States, but her statement is so 
damaging that Epstein can't use her either. 
approached Jane Doe #12 in Ma or June 2004 and was told that she could model lingerie 
for a wealthy Palm Beach man for money. 
and Jane Doe #12 traveled by Yellow Cab from Jane 
Doe #12's house in West Palm Beach to Epstein's house. They met Epstein outside the house and he 
took them in to the kitchen where the chef made them something to eat. Epstein and 
led Jane 
Doe #12 upstairs to the dressing area. El. 
went into the bathroom and came out wearing only a 
towel. Epstein laid on his stomach and 
and Jane Doe #12 began massaging his legs and feet. 
Jane Doe #12 asked 
why they were doing this and 
replied that it was part of the routine. 
Epstein told 
to leave and told Jane Doe #12 to get comfortable and take off her clothes. Epstein 
turned onto his back and started touching her breasts and her vagina (over her panties) while he 
masturbated. The massage ended when he ejaculated. Epstein told Jane Doe #12 that there was $200 
on the dresser for her. One of Epstein's employees was ordered to drive 
and Jane Doe #12 home, 
which he did. (A former pi. 
manager reports driving girls home on several occasions.) Jane Doe 
#12 reports that she called 
after she got home saying that she wanted to report Epstein to the 
authorities but 
talked her out of it. 
Jane Doe #12 returned to Epstein's home 2 or 3 times. The first time that she returned she again 
stayed in her panties and Epstein touched her while he masturbated. The next time she returned, Epstein 
told Jane Doe #12 to take all of her clothes off, saying she was here for that reason. Jane Doe #12 
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complied and Epstein fondled her breasts and vagina while he masturbated. Epstein instructed Jane 
Doe #12 not to tell anyone what happened during the massages. 
Epstein had gotten Jane Doe # 12's phone number after the first massage and 
would call to 
make appointments. Jane Doe #12 started avoiding their calls. Jane Doe #12 took a Xanax before each 
meeting with Epstein. It is believed that 
provided the Xanax, but she denies it. 
1. Overt Acts Based u on Activity with Jane Doe #12 
# 
. On July 4, 2004, Defendant 
caused one or more telephone calls to be made to a 
telephone used by Jane Doe #12. 
# 
On July 10, 2004, Defendant 
caused one or more telephone calls to be made to a 
telephone used by Jane Doe #12. 
2. Substantive Offenses with Jane Doe #12 
Count 
Date(s) 
Offense 
Statute 
Defendant(s) 
15 
7/4/04- 
7/19/04 
Use of cellular phone to persuade, 
induce, or entice Jane Doe #3 to 
engage in prostitution 
2422(b) 
EPSTEIN 
20 
7/4/04 
Travel in interstate commerce with 
intent to engage in illicit sexual 
conduct 
2423(b) 
EPSTEIN 
HYPERION 
21 
7/16/04 
Travel in interstate commerce with 
intent to engage in illicit sexual 
conduct 
2423(b) 
EPSTEIN 
HYPERION 
57 
7/4/04- 
7/19/04 
Recruiting, enticing, providing, or 
obtaining by any means a person 
knowing that the person has not 
attained the age of 18 years and will 
be 
caused 
to 
engage 
in 
a 
commercial sex act. 
1591(a)(1) 
EPSTEIN 
M. JANE DOE #13 
Jane Doe # 13 attended John I Leonard High School in Greenacres. She was recruited by another 
girl, who will be the subject of a superseding indictment. 
When Jane Doe # 13 arrived at Epstein's home, her recruiter led her upstairs. When Epstein 
entered, he asked both of them to remove their tops. Both started massaging his back, then Epstein 
asked the recruiter to leave. When the recruiter was gone, Epstein asked Jane Doe #13 to remove the 
rest of her clothes; Jane Doe #13 complied. Epstein told Jane Doe #13 to talk dirty to him, and Epstein 
masturbated. 
Jane Doe #13 estimates that she went to Epstein's home about 10 times. After the first massage 
was completed, Epstein asked for her telephone number. Jane Doe #13 wrote the information, down on 
a notepad bearing Epstein's name. Jane Doe #13 was paid $200 for each massage. She also brought 2 
other girls was paid $200 for each girl she brought. Epstein always made the payments. Epstein asked 
Jane Doe #13 to have sexual intercourse and promised to pay more money if she did. Jane Doe #13 
declined. 
In addition to masturbating himself, Epstein used the back massager/vibrator on Jane Doe #14's 
vagina. Epstein fondled Jane Doe # 13's breasts and buttocks, and digitally penetrated her vagina. 
Epstein asked Jane Doe # 13 how old she was and she said she would be turning 18 in the spring. 
She told Epstein several times that she was 17, she gave Epstein a school photo and wrote on the back 
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that she couldn't wait to turn 18. Jane Doe # 13 and Epstein discussed Jane Doe # 13's age. Epstein 
said he couldn't wait until she turned 18 so they could travel to Paris together and so she could be his 
personal masseuse. 
Jane Doe # 13 received calls from 
and 
to set up appointments, usually at least one a 
day in advance, sometimes the appointments were made before Ep
i arrived in Palm Beach. There 
are records of approximately 40 calls between Jane Doe # 13 and M, 
and 6 calls between Jane Doe 
# 13 and 
. Jane Doe # 13 still had 
number programmed into her cell phone. Jane Doe # 
13 came forward after press coverage revealed that Epstein passed a lie detector test saying that he 
didn't know any girls were under 18. Jane Doe # 13 repeated that Epstein knew she was under 18 and 
also thought that Epstein knew that the recruiter also was 17. 
CREDIBILITY ISSUE 
While she was a juvenile, Jane Doe # 13 was arrested for marijuana possession and shoplifting. 
1. Overt Acts based upon Activity with Jane Doe #13 
#. On August 19, 2004, Defendants EPSTEIN, 
, traveled from Van Nuys, 
California to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by Defendant, JEGE, 
INC. 
#. On August 21, 2004, Defendant 
caused one or more telephone calls to be made to a 
telephone used by Jane Doe # 13. 
#. On September 16, 2004, Defendants EPSTEIN, I
, and 
traveled from 
New York, New York to Palm Beach County, Florida aboard the Boeing 727 aircraft owned by 
Defendant, JEGE, INC. 
#. On October 29, 2004, Defendants EPSTEIN, 
. and 
traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft 
owned by Defendant, HYPERION, AIR, INC. 
#. On January 1, 2005, Defendants EPSTEIN, 
, and 
traveled from Anguilla, British West Indies.to Palm Beach County, Florida aboard the Gulfstream 
aircraft owned by Defendant, HYPERION, AIR, INC. 
#. On January 4, 2005, Defendant 
caused one or more telephone calls to be made to a 
telephone used by Jane Doe #13. 
#. On January 6, 2005, Defendant EPSTEIN traveled from Teterboro, New Jersey to Palm Beach 
County, Florida aboard the Gulfstream aircraft owned b Defendant, HYPERION, AIR, INC. 
#. On February 24, 2005, Defendants EPSTEIN, 
and 
traveled from Teterboro, New Jersey to Palm Beach County, Florida aboard the Gulfstream aircraft 
owned by Defendant HYPERION, AIR, INC. 
2. Substantive Offenses related to Jane Doe #13 
Count 
Date(s) 
Offense 
Statute 
Defendant(s) 
16 
8/21/04- 
5/27/05 
Use of cellular phone to persuade, 
induce, or entice Jane Doe #3 to 
engage in prostitution 
2422(b) 
EPSTEIN 
26 
9/16/04 
Travel in interstate commerce with 
intent to engage in illicit sexual 
conduct 
2423(b) 
EPSTEIN 
JEGE 
27 
10/29/04 
Travel in interstate commerce with 
intent to engage in illicit sexual 
conduct 
2423(b) 
EPSTEIN 
HYPERION 
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34 
1/1/05 
Travel in interstate commerce with 
intent to engage in illicit sexual 
conduct 
2423(b) 
EPSTEIN 
HYPERION 
35 
1/6/05 
Travel in interstate commerce with 
intent to engage in illicit sexual 
conduct 
2423(b) 
EPSTEIN 
HYPERION 
40 
2/24/05 
Travel in interstate commerce with 
intent to engage in illicit sexual 
conduct 
2423(b) 
EPSTEIN 
HYPERION 
58 
8/21/04- 
5/27/05 
Recruiting, enticing, providing, or 
obtaining by any means a person 
knowing that the person has not 
attained the age of 18 years and will 
be 
caused 
to 
engage 
in 
a 
commercial sex act. 
1591(a)(1) 
EPSTEIN 
fiEach of the airplanes is held in a separate "shell corporation," JEGE, Inc., and Hyperion Air, Inc. 
Epstein is the shareholder in both of these corporations and they serve no purpose other than to hold and 
maintain the airplanes for Epstein's personal use. Because these assets are not held as personal property in 
Epstein's name, I have indicted the two corporations, which will be named as co-conspirators and as aiders and 
abettors in the relevant offenses. 
2F During a meeting, Epstein's current attorneys, Gerald Lefcourt and Lilly Ann Sanchez, admitted that 
attorney Roy Black instructed Epstein to have the CPUs removed, but they insisted that those instructions were 
given well in advance of the execution of the search warrant — not in res onse to a "leak." 
F3
 since gotten married and is now "M 
." I will refer to her as 
since 
that is the name she used during the relevant period. 
a sOf the 12 underage girls who are the subject of the indictment, 9 attended Royal Palm Beach High 
School, 1 attended Lake Worth High School, 1 attended William T. Dwyer High School, and 1 attended John I. 
Leonard High School. There are ten other girls whose telephone records are still being analyzed, some of whom 
will probably be the subject of a superseding indictment. Some of those girls came forward following the press 
coverage of the state investigation. We anticipate that more girls will come forward after Epstein's arrest. 
USometimes Epstein made the payment and asked for the phone number, sometimes it was the assistant. 
FAkttached as Appendix A are materials received from counsel for Epstein, including their legal analysis. 
The points they raise are addressed in this memo. 
EZSection 2421 was originally referred to as the Mann Act. Sections 2422 and 2423 are more recent 
additions, which focus on children. All three sections are sometimes jointly referred to as the Mann Act. 
a lNote that there is an Eleventh Circuit Pattern Jury Instruction for attempted enticement of a minor. In 
that instruction, the Eleventh Circuit included a willfulness requirement — including a requirement that the 
defendant believe that the individual was under eighteen. Those additional requirements apply to a charge of 
attempted enticement because attempt is a specific intent offense that requires the United States to prove that the 
defendant "knowingly and willfully intended to commit the offense" — i.e. , that he intended to commit the crime. 
11th Cir. Pattern Jury Instr., Special Instr. 11 ("Attempt(s)") (2003). Where, as here, the offense is completed, 
the statutory language requires only that the defendant knowingly persuade, induce, or entice someone to engage 
in prostitution or criminal sexual activity. 
F2In Bonner v. City of Prichard, 661 F. 2d 1206 (11th Cir. 1981), the Eleventh Circuit adopted as binding 
precedent all Fifth Circuit decisions rendered prior to October 1, 1981. 
have used the Florida Statutes in effect at the time that the offenses occurred. They have not 
changed since then although, as shown below, amendments are currently pending. 
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F! 
There currently is legislation pending before the Florida Legislature increasing the penalties related to 
child prostitution. The section defining "prostitution" has been renumbered but the language remains the same. 
That chapter also has an offense of obtaining a person for "lewdness," (Proposed Fl. Stat. 796.07), which is 
defined as "any indecent or obscene act." (Proposed Fl. Stat. 796.011(4)) 
" 2"Sexual activity" is defined as "the oral, anal, or vaginal penetration by, or union with, the sexual 
organ of another or the anal or vaginal penetration of another by any other object; however, sexual activity does 
not include an act done for a bona fide medical purpose." Fl. Stat. § 800.04(1)(a). 
The Florida Legislature currently is amending § 800.04(7) making it a second-degree felony to 
commit lewd or lascivious exhibition in front of any victim, regardless of the victim's age. 
!F 4"An `overt act' is any transaction or event, even one which may be entirely innocent when considered 
alone, but which is knowingly committed by a conspirator in an effort to accomplish some object of the 
conspiracy." 11th Cir. Pattern Jury Instr., Offense Instr. 13.1 (2003). 
Although Hersh specifically mentions "sexual activity with a minor," knowledge of age is not 
required, as discussed above. 
Part G contains the guidelines for calculating the offense levels for "Offenses Involving Commercial 
Sex Acts, Sexual Exploitation of Minors and Obscenity." 
E
Section 1594(a) makes it a crime for any person to attempt to violate Section 1591. 
F
On one occasion, Banasiak was directed to give money by Ghislaine Maxwell. Maxwell is the 
daughter of the late Robert Maxwell, a British newspaper tycoon. Maxwell is credited with bringing Epstein into 
high society, and it appears that at some time they were romantically involved. Maxwell also has been 
implicated in another act of molesting a young girl, which is discussed in the 404(b) section below. 
F3The Jury Instruction requires proof of three elements: 
First: that the Defendant knowingly conducted a financial transaction; 
Second : that the financial transaction involved property used to conduct or facilitate specified 
unlawful activity; and 
Third : that the Defendant engaged in the financial transaction with the intent to promote the 
carrying on of specified unlawful activity. 
Eleventh Cir. Pattern Jury Instr., Offense Instr. 70.4 (2003). 
a l Tobon-Builes was decided prior to the enactment of 31 U.S.C. § 5324(a), which created a criminal 
offense for causing a domestic financial institution to fail to file a required report, such as a CTR. 
From the descriptions provided by the girls and by the police officers who conducted the search of the 
home, attached to Epstein's master bedroom was a large room that contained a steam shower, dressing area, and 
closets. This space was adjacent to the regular master bathroom. Because some activity occurred in the 
bedroom itself, I will use the term "dressing area" to refer to the space where the sexual massages occurred. 
E
More telephone calls occurred, but calls placed to JD#1's home telephone from Epstein's home 
telephone (or vice-versa) were not captured in the cellular phone records in our possession. 
Although the telephone contact with JD#4 continued through October 2005, she turned 18 on June 30, 
2005. 
a 4One of the messages retrieved from the message pad was a call from David Copperfield asking 
Epstein to return his call. 
F
As discussed below, there are six girls who will be included in a superseding indictment, once their 
telephone records are received and analyzed. Jane Doe #17 is one of those girls. 
F.6A number of these photographs were seized during the search of Epstein's home. 
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