EFTA01249981

Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 41 of 52 
172. 
By virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, 
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § 
1595 by Plaintiff, who is a victim of the violations. 
173. 
Defendant, by and through its management and personnel, participated 
in a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, 
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would 
be used to cause Plaintiff to commit a commercial sex act. 
174. 
As a direct and proximate result of Defendant corporation's 
commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 
1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, 
Plaintiff has in the past suffered and will continue to suffer injury and pain; 
emotional distress; psychological and psychiatric trauma; mental anguish; 
humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of 
enjoyment of life; invasion of privacy; and other damages associated with ' actions. 
Plaintiff will incur further medical and psychological expenses. These injuries are 
permanent in nature and Plaintiff will continue to suffer from them in the future. In 
addition to these losses, Plaintiff has incurred attorneys' fees and will be required do 
so in the future. 
WHEREFORE, Plaintiff demands judgment against Defendant, Maple, Inc., 
for compensatory and general damages, attorney's fees, punitive damages and such 
41 
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EFTA_00095947 
EFTA01250021

Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 42 of 52 
other and further relief as this Court deems just and proper. Plaintiff hereby demands 
trial by jury on all issues triable as of right by a jury. 
COUNT VII 
CAUSE OF ACTION AGAINST 
FINANCIAL TRUST COMPANY. INC. 
PURSUANT TO 18 U.S.C. & 1595 
175. 
Plaintiff adopts and realleges paragraphs 1 through 129 above. 
176. 
Defendant, by and through its management and personnel, within the 
special maritime and territorial jurisdiction of the United States, in interstate and 
foreign commerce, and/or affecting interstate and foreign commerce, knowingly 
recruited, enticed, harbored, transported, provided, obtained, maintained, 
patronized, solicited by any means Plaintiff. 
177. 
Defendant, by and through its management and personnel, knew that 
means of fraud or coercion, and/or combinations of such means, would be used, and 
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In 
doing so, Defendant corporation violated 18 U.S.C. §1591. 
178. 
Defendant, by and through its management and personnel knowingly 
benefitted, financially and by receiving things of value, from participating in a 
venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in 
violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in 
such violations. In so doing, Defendant corporation violated 18 U.S.C. § 1593A. 
42 
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EFTA_00095948 
EFTA01250022

Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 43 of 52 
179. 
Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 
1591. In so doing, violated 18 U.S.C. § 1594(a). 
180. 
Defendant, by and through its management and personnel, conspired 
with other members of the enterprise, and with other persons and companies, known 
and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 
U.S.C. § 1594(c). 
181. 
Additionally, Defendants conspired with each other, and with other 
persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants 
violated 18 U.S.C. § 1594(b). 
182. 
By virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, 
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § 
1595 by Plaintiff, who is a victim of the violations. 
183. 
Defendant, by and through its management and personnel, participated 
in a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, 
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would 
be used to cause Plaintiff to commit a commercial sex act. 
184. 
As a direct and proximate result of Defendant corporation's 
commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 
1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, 
Plaintiff has in the past suffered and will continue to suffer injury and pain; 
43 
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EFTA_00095949 
EFTA01250023

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emotional distress; psychological and psychiatric trauma; mental anguish; 
humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of 
enjoyment of life; invasion of privacy; and other damages associated with ' actions. 
Plaintiff will incur further medical and psychological expenses. These injuries are 
permanent in nature and Plaintiff will continue to suffer from them in the future. In 
addition to these losses, Plaintiff has incurred attorneys' fees and will be required do 
so in the future. 
WHEREFORE, Plaintiff demands judgment against Defendant, Financial 
Trust Company, Inc., For compensatory and general damages, attorney's fees, 
punitive damages and such other and further relief as this Court deems just and 
proper. Plaintiff hereby demands trial by jury on all issues triable as of right by a 
ju►'y 
COUNT VIII 
CAUSE OF ACTION AGAINST NES. LLC 
PURSUANT TO 18 U.S.C. 6 1595 
185. 
Plaintiff adopts and realleges paragraphs I through 129 above. 
186. 
Defendant, by and through its management and personnel, within the 
special maritime and territorial jurisdiction of the United States, in interstate and 
foreign commerce, and/or affecting interstate and foreign commerce, knowingly 
recruited, enticed, harbored, transported, provided, obtained, maintained, 
patronized, solicited by any means Plaintiff. 
44 
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EFTA_00095950 
EFTA01250024

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187. 
Defendant, by and through its management and personnel, knew that 
means of fraud or coercion, and/or combinations of such means, would be used, and 
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In 
doing so, Defendant corporation violated 18 U.S.C. §1591. 
188. 
Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 
1591. In so doing, violated 18 U.S.C. § 1594(a). 
189. 
Defendant, by and through its management and personnel, conspired 
with other members of the enterprise, and with other persons and companies, known 
and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 
U.S.C. § 1594(c). 
190. 
Additionally, Defendants conspired with each other, and with other 
persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants 
violated 18 U.S.C. § I 594(b). 
191. 
By virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, 
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § 
1595 by Plaintiff, who is a victim of the violations. 
192. 
Defendant, by and through its management and personnel, participated 
in a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, 
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would 
be used to cause Plaintiff to commit a commercial sex act. 
45 
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EFTA_00095951 
EFTA01250025

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193. 
As a direct and proximate result of Defendant corporation's 
commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 
1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, 
Plaintiff has in the past suffered and will continue to suffer injury and pain; 
emotional distress; psychological and psychiatric trauma; mental anguish; 
humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of 
enjoyment of life; invasion of privacy; and other damages associated with' actions. 
Plaintiff will incur further medical and psychological expenses. These injuries are 
permanent in nature and Plaintiff will continue to suffer from them in the future. In 
addition to these losses, Plaintiff has incurred attorneys' fees and will be required do 
so in the future. 
WHEREFORE, Plaintiff demands judgment against Defendant, NES, Inc., for 
compensatory and general damages, attorney's fees, punitive damages and such 
other and further relief as this Court deems just and proper. Plaintiff hereby demands 
trial by jury on all issues triable as of right by a jury. 
COUNT IX 
CAUSE OF ACTION AGAINST 
HBRK ASSOCIATES. INC. PURSUANT TO 18 U.S.C. & 1595 
194. 
Plaintiff adopts and realleges paragraphs 1 through 129 above. 
195. 
Defendant, by and through its management and personnel, within the 
special maritime and territorial jurisdiction of the United States, in interstate and 
46 
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EFTA_00095952 
EFTA01250026

Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 47 of 52 
foreign commerce, and/or affecting interstate and foreign commerce, knowingly 
recruited, enticed, harbored, transported, provided, obtained, maintained, 
patronized, solicited by any means Plaintiff. 
196. 
Defendant, by and through its management and personnel, knew that 
means of fraud or coercion, and/or combinations of such means, would be used, and 
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In 
doing so, Defendant corporation violated 18 U.S.C. §1591. 
197. 
Defendant, by and through its management and personnel knowingly 
benefitted, financially and by receiving things of value, from participating in a 
venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in 
violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in 
such violations. In so doing, Defendant corporation violated 18 U.S.C. § 1593A. 
198. 
Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 
1591. In so doing, violated 18 U.S.C. § 1594(a). 
199. 
Defendant, by and through its management and personnel, conspired 
with other members of the enterprise, and with other persons and companies, known 
and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 
U.S.C. § 1594(c). 
47 
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EFTA_00095953 
EFTA01250027

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200. 
Additionally, Defendants conspired with each other, and with other 
persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants 
violated 18 U.S.C. § 1594(b). 
201. 
By virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, 
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § 
1595 by Plaintiff, who is a victim of the violations. 
202. 
Defendant, by and through its management and personnel, participated 
in a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, 
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would 
be used to cause Plaintiff to commit a commercial sex act. 
203. 
As a direct and proximate result of Defendant corporation's 
commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 
1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, 
Plaintiff has in the past suffered and will continue to suffer injury and pain; 
emotional distress; psychological and psychiatric trauma; mental anguish; 
humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of 
enjoyment of life; invasion of privacy; and other damages associated with ' actions. 
Plaintiff will incur further medical and psychological expenses. These injuries are 
permanent in nature and Plaintiff will continue to suffer from them in the future. In 
48 
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EFTA_00095954 
EFTA01250028

Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 49 of 52 
addition to these losses, Plaintiff has incurred attorneys' fees and will be required do 
so in the future. 
WHEREFORE, Plaintiff demands judgment against Defendant, HBRK 
Associates, Inc., for compensatory and general damages, attorney's fees, punitive 
damages and such other and further relief as this Court deems just and proper. 
Plaintiff hereby demands trial by jury on all issues triable as of right by a jury. 
COUNT X 
CAUSE OF ACTION AGAINST JEGE. INC. 
PURSUANT TO 18 U.S.C. & 1595 
204. 
Plaintiff adopts and realleges paragraphs I through 129 above. 
205. 
Defendant, by and through its management and personnel, within the 
special maritime and territorial jurisdiction of the United States, in interstate and 
foreign commerce, and/or affecting interstate and foreign commerce, knowingly 
recruited, enticed, harbored, transported, provided, 
patronized, solicited by any means Plaintiff. 
206. 
Defendant, by and through its management and personnel, knew that 
means of fraud or coercion, and/or combinations of such means, would be used, and 
were in fact used, in order to cause Plaintiff to engage in commercial sex acts. In 
doing so, Defendant corporation violated 18 U.S.C. §1591. 
207. 
Defendant, by and through its management and personnel knowingly 
benefitted, financially and by receiving things of value, from participating in a 
49 
obtained, maintained, 
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EFTA_00095955 
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Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 50 of 52 
venture (the Epstein sex trafficking venture enterprise) which had engaged in acts in 
violation of 18 U.S.C. § 1592 and 1595(a), knowing that the venture had engaged in 
such violations. In so doing, Defendant corporation violated 18 U.S.C. § 1593A. 
208. 
Furthermore, Defendant corporation attempted to violate 18 U.S.C. § 
1591. In so doing, violated 18 U.S.C. § 1594(a). 
209. 
Defendant, by and through its management and personnel, conspired 
with other members of the enterprise, and with other persons and companies, known 
and unknown, to violate 18 U.S.C. § 1591. In so doing, Defendant violated 18 
U.S.C. § 1594(c). 
210. 
Additionally, Defendants conspired with each other, and with other 
persons known and unknown, to violate 18 U.S.C. § 1592. In so doing, Defendants 
violated 18 U.S.C. § 1594(b). 
211. 
By virtue of Jeffrey Epstein's violations of 18 U.S.C. §§ 1591, 1592, 
1593A, and 1594, Defendant is subject to civil causes of action under 18 U.S.C. § 
1595 by Plaintiff, who is a victim of the violations. 
212. 
Defendant, by and through its management and personnel, participated 
in a venture with Jeffrey Epstein's enterprise by knowingly recruiting, transporting, 
soliciting, obtaining, and maintaining Plaintiff knowing that fraud or coercion would 
be used to cause Plaintiff to commit a commercial sex act. 
50 
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EFTA_00095956 
EFTA01250030

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213. 
As a direct and proximate result of Defendant corporation's 
commission of the aforementioned criminal offenses enumerated in 18 U.S.C. § 
1591, 1593A, and 1594, and the associated civil remedies provided in § 1595, 
Plaintiff has in the past suffered and will continue to suffer injury and pain; 
emotional distress; psychological and psychiatric trauma; mental anguish; 
humiliation; confusion; embarrassment; loss of self-esteem; loss of dignity; loss of 
enjoyment of life; invasion of privacy; and other damages associated with' actions. 
Plaintiff will incur further medical and psychological expenses. These injuries are 
permanent in nature and Plaintiff will continue to suffer from them in the future. In 
addition to these losses, Plaintiff has incurred attorneys' fees and will be required do 
so in the future. 
WHEREFORE, Plaintiff demands judgment against Defendant, JEGE, Inc., 
for compensatory and general damages, attorney's fees, punitive damages and such 
other and further relief as this Court deems just and proper. Plaintiff hereby demands 
trial by jury on all issues triable as of right by a jury. 
51 
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EFTA_00095957 
EFTA01250031

Case 1:19-cv-07772-ALC-DCF Document 1 Filed 08/20/19 Page 52 of 52 
Dated: August 20, 2019. 
Respectfully Submitted, 
(SEEKING ADMISSION PRO HAC VICE) 
52 
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EFTA_00095958 
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EXHIBIT A 
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EFTA 00095959 
EFTA01250033

Caassit 1191S0NIE961),IFOABOD0Dortomebt 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
••••••••••••••••••••••• 
UNITED STATES OF AMERICA. 
x 
USDC SDNY 
DOCUMENT 
.LECTRONICALLY FILED 
L
D±TE FILED: 
Government, 
19 CR. 490 (RMB) 
- against - 
ORDER 
JEFFREY EPSTEIN, 
Defendant. 
-3C 
The Clerk is respectful') requested to docket the enclosed documents which were 
discussed at today's bail hearing. 
Dated: New York, New York 
July 15, 2019 
?Kg 
RICHARD M. BERMAN 
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EFTA_00095960 
EFTA01250034

CEDase:19.4lko0004S3CARMOCPodiximemodAt 41141444614144.4a4658183
(IS v Jeffrey Epuein, I9-cr-490 (RMR) 
ASSET SUMMARY - JUNE 30, 2019 
_, 
6/30/19 
Asset 
Value 
Cash 
$ 
56,547,773 
• 
Fixed Income 
$ 
14,304,679 
• 
Equities 
$ 
112,679,138 
• 
Hedge Funds & Private Equity 
$ 
194,986,301 
I Properties 
"*" 
9 East 71st Street, New York, NY 10021 
$ 
55.931,000 
49 Zorro Ranch Road, Stanley New Mexico 87056 
$ 
17.246,208 
358 El Brillo Way, Palm Beach, FL 33480 
$ 
12,380,209 
22 Avenue Foch,Paris France 75116 
$ 
8,672&823 
$ 
22,498,600 
$ 
63,874,223 1
Great St James Island No. 6A USVI 00802 (parcels A,B,C) 
—I" 
Little St James Island No. 6B USVI 00802 (parcels A,B,C) 
Total Assets 
$ 
559,120,954 
' 
Values reflect gross numbers that are not net of tax 
** All properties are valued at assessed values as per the most recent 
property tax bills 
n• Note the United States Attorney's office for the Southern District of New York 
has stated that the value of this home is $77,000,000 as compared to the 
market value shown above per the June 1, 2019 property tax bill 
"" Note this property is valued at cost basis, however the assessment on 
the most recent tax bill is $4,857,500 
I 
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EFTA 00095961 
EFTA01250035

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 1 of 15 
EXHIBIT B 
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EFTA_00095962 
EFTA01250036

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 2 of 15 
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK 
 
 
x 
UNITED. STATES OF AMERICA 
JEFFREY EPSTEIN, 
Defendant. 
x 
SEALED 
INDICTMENT 
19 Cr. 
19 CRIM 490 
COUNT ONE 
(Sex Trafficking Conspiracy) 
The Grand Jury charges: 
OVERVIEW 
1. 
As set forth herein, over the course of many 
years, JEFFREY EPSTEIN, the defendant, sexually exploited and 
abused dozens of minor girls at his homes in Manhattan, New 
York, and Palm Beach, Florida, among other locations. 
2. 
In particular, from at least in or about 2002, up 
to and including at least in or about 2005, JEFFREY EPSTEIN, the 
defendant, enticed and recruited, and caused to be enticed and 
recruited, minor girls to visit his mansion in Manhattan, New 
York (the "New York Residence") and his estate in Palm Beach, 
Florida (the "Palm Beach Residence") to engage in sex acts with 
him, after which he would give the victims hundreds of dollars 
in cash. Moreover, and in order to maintain and increase his 
supply of victims, EPSTEIN also paid certain of his victims to 
recruit additional girls to be similarly abused by EPSTEIN. In 
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EFTA 00095963 
EFTA01250037

Case 1:19-cv-07772-ALC-DCF Document 1-2 Filed 08/20/19 Page 3 of 15 
this way, EPSTEIN created a vast network of underage victims for 
him to sexually exploit in locations including New York and 
Palm Beach. 
3. 
The victims described herein were as young as 14 
years old at the time they were abused by JEFFREY EPSTEIN, the 
defendant, and were, for various reasons, often particularly 
vulnerable to exploitation. EPSTEIN intentionally sought out 
minors and knew that many of his victims were in fact under the 
age of 18, including because, in some instances, minor victims 
expressly told him their age. 
4. 
In creating and maintaining this network of minor 
victims in multiple states to sexually abuse and exploit, 
JEFFREY EPSTEIN, the defendant, worked and conspired with 
others, including employees and associates who facilitated his 
conduct by, among other things, contacting victims and 
scheduling their sexual encounters with EPSTEIN at the New York 
Residence and at the Palm Beach Residence. 
FACTUAL BACKGROUND 
5. 
During all time periods charged in this 
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with 
multiple residences in the continental United States, including 
the New York Residence and the Palm Beach Residence. 
6. 
Beginning in at least 2002, JEFFREY EPSTEIN, the 
defendant, enticed and recruited, and caused to be enticed and 
2 
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EFTA_00095964 
EFTA01250038

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recruited, dozens of minor girls to engage in sex acts with him, 
after which EPSTEIN paid the victims hundreds of dollars in 
cash, at the New York Residence and the Palm Beach Residence. 
7. 
In both New York and Florida, JEFFREY EPSTEIN, 
the defendant, perpetuated this abuse in similar ways. Victims 
were initially recruited to provide "massages" to EPSTEIN, which 
would be performed nude or partially nude, would become 
increasingly sexual in nature, and would typically include one 
or more sex acts. EPSTEIN paid his victims hundreds of dollars 
in cash for each encounter. Moreover, EPSTEIN actively 
encouraged certain of his victims to recruit additional girls to 
be similarly sexually abused. EPSTEIN incentivized his victims 
to become recruiters by paying these victim-recruiters hundreds 
of dollars for each girl that they brought to EPSTEIN. In so 
doing, EPSTEIN maintained a steady supply of new victims to 
exploit. 
The New York Residence 
8. 
At all times relevant to this Indictment, JEFFREY 
EPSTEIN, the defendant, possessed and controlled a multi-story 
private residence on the Upper East Side of Manhattan, New York, 
i.e., the New York Residence. Between at least in or about 2002 
and in or about 2005, EPSTEIN abused numerous minor victims at 
the New York Residence by causing these victims to be recruited 
to engage in paid sex acts with him. 
3 
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9. 
When a victim arrived at the New York Residence, 
she typically would be escorted to a room with a massage table, 
where she would perform a massage on JEFFREY EPSTEIN, the 
defendant. The victims, who were as young as 14 years of age, 
were told by EPSTEIN or other individuals to partially or fully 
undress before beginning the "massage." During the encounter, 
EPSTEIN would escalate the nature and scope of physical contact 
with his victim to include, among other things, sex acts such as 
groping and direct and indirect contact with the victim's 
genitals. EPSTEIN typically would also masturbate during these 
sexualized encounters, ask victims to touch him while he 
masturbated, and touch victims' genitals with his hands or with 
sex toys. 
10. In connection with each sexual encounter, JEFFREY 
EPSTEIN, the defendant, or one of his employees or associates, 
paid the victim in cash. Victims typically were paid hundreds 
of dollars in cash for each encounter. 
11. JEFFREY EPSTEIN, the defendant, knew that many of 
his New York victims were underage, including because certain 
victims told him their age. Further, once these minor victims 
were recruited, many were abused by EPSTEIN on multiple 
subsequent occasions' at the New York Residence. EPSTEIN 
sometimes personally contacted victims to schedule appointments 
at the New York Residence. In other instances, EPSTEIN directed 
4 
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EFTA 00095966 
EFTA01250040