EFTA00192670

GRAND JURY PRESENTATION OPERATION LEAP YEAR I. INTRODUCTION A. New Indictment 1. Summarize Changes 2. Summarize Current Charges 3. Review Law/Instructions 4. Go through legal allegations in introduction B. Summarize How the Evidence Will Be Presented 1. Chart 2. Break Overt Acts into Two Categories: a. Meetings/Sexual Activity — Grouped by victim — Testimony re Interviews with the Girls b. Flights — Manifests C. Take Questions D. Call Special Agent Kuyrkendall H. RETURN DOCUMENTS RECEIVED IN RESPONSE TO SUBPOENAS ISSUED SINCE THE LAST DOCUMENT RETURN. A. Have additional subpoenas been issued on behalf of this grand jury regarding Operation Leap Year? And have documents been received in response to those subpoenas? What subpoenas were issued and what items were received? Did you bring those records with you today? KUYRICENDALL SUBSTANTIVE TESTIMONY A. Hand out summary chart 1. Review renumbering of Jane Does a. S/A Kuyrkendall: Can you explain to the grand jury how the Jane Does have been renumbered? (They were numbered to try to appear in a more chronological order depending on their Page 1 of 11 EFTA00192670 first known contact with Mr. Epstein) b. S/A Kuyrkendall: Which of these girls has the grand jury already heard testimony about? 2. • Go over how chart is organized a. S/A Kuyrkendall: What does each column refer to? 3. Generally review references to transcript pages a. S/A Kuyrkendall: What does the list of transcript pages refer to? How was that list created? B. Go through the allegations in the Introductory Section of the Indictment. Summarize evidence that hasn't already been presented (I think just the high school allegations) C. Hand out flight chart 1. What does this chart refer to? What does each column mean? 2. Flip to a few overt acts and read the text aloud. What is the evidence in support of these allegations? (Flight manifests) 3. Remind the grand jury how the flight manifests were obtained. 4. So, for each flight referenced in the overt acts, what evidence was relied upon? And did you bring those flight manifests with you? Let's mark those manifests as Composite Grand Jury Exhibit Number JE-1. 5. There are several dozen manifests contained within Exhibit IE-1. Have you marked in any way the manifests related to the flights referenced in the indictment? And in reviewing those manifests, what information will the grand jurors find? [Airplane used. Date. Departure airport. Arrival airport. Arrival time. Passenger names.] D. Discuss telephone records 1. Flip to a few overt acts and read the text aloud. What is the evidence in support of these allegations? (Telephone records) Page 2 of 11 EFTA00192671 2. Remind the grand jury how the telephone records were obtained and whose telephone records were obtained. Were there any records that you tried to obtain that you couldn't? 3. Have you pulled the telephone records that contain the telephone calls referred to in the indictment? And did you bring them with you? Have you marked in any way the telephone bills that reference the calls listed in the indictment? And in reviewing those billing records, what information will the grand juror's find? (Telephone number called. Time and date of call. Call length.) TAKE A BREAK BEGIN TESTIMONY REGARDING THE GIRLS IV. JANE DOES 1 and 2 A. Who is Jane Doe #1? 1. Has she been interviewed? In addition to her statements, who else provided information regarding Jane Doe #1? 2. During what period of time did Jane Doe #1 have contact with JE? 3. How old was she during that time frame? 4. How did she meet JE? 5. And what sexual activity was she involved in with JE? 6. Did she recruit anyone to go to JE's home? B. Who is Jane Doe #2? I. Has she been interviewed? In addition to her statements, who else provided information regarding Jane Doe #2? 2. During what period of time did Jane Doe #2 have contact with JE? 3. How old was she during that time frame? Page 3 of 11 EFTA00192672 4. How did she meet JE? 5. And what sexual activity was she involved in with JE? 6. How much was she paid for performing sexual massages for JE? 7. Did she recruit any of the other Jane Does to go to JE's home? 8. Please take us through the evidence supporting the overt acts related to Jane Doe #2. 9. What did Jane Doe #2 say about whether JE knew her age? 10. Who would contact Jane Doe #2 to make appointments? How would she be contacted? 11. Does your testimony cover the evidence supporting the allegations in overt acts 1 through 18? 12. Let's refer to Count 2. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #2 to engage in commercial sex acts knowing that she was under 18? JANE DOE #3 ( W.) A. Who is Jane Doe #3? Have you testified about her previously? B. Has she been interviewed? C. During what period of time did Jane Doe #3 have contact with JET D. How old was she during that time frame? E. How did she meet JE? F. And what sexual activity was she involved in with JET G. How much was she paid? H. Did she recruit anyone to go to JE's home? What did she tell you about Page 4 of 11 EFTA00192673 JE's recruiting requests? Were there girls whom Jane Doe #3 brought to Epstein's home whom he didn't like? Did he allow them to massage him? I. Did he ever become frustrated when JD#3 wasn't able to find a young girl for him? J. Does your testimony cover the evidence supporting the allegations in overt acts 19 through 31? K. Let's refer to Count 12. 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 #3 to engage in prostitution and in sexual activity for which a person can be charged with a criminal offense? [Florida violations — Jane Doe #3 was under the age of 16 when she *as involved with Epstein, so he could be charged with lewd and lascivious molestation, lewd and lascivious conduct, and lewd and lascivious exhibition based upon his touching of Jane Doe #3's breasts and genitals, his solicitation of Jane Doe #3 to commit a lewd and lascivious act, and his masturbation and exposure of his genitals in her presence.] VI. JANE DOES #4, 5, and 6 MI Ha C., and NM P.) A. Who are Jane Does #4, 5, and 67 Have you testified about them previously? B. Have they been interviewed? In addition to their statements, who else provided information regarding Jane Does #4, 5, and 6? C. During what period of time did Jane Does #4, 5, and 6 have contact with JE? D. How old were they during that time frame? E. What sexual activity did Jane Does #4 and #5 engage in with JE? F. Did either of them take anyone else to JE's home? G. What sexual activity was Jane Doe #6 involved in with JE? H. Did she take anyone else to JE's home? Page 5 of 11 EFTA00192674 I. Does your testimony cover the evidence supporting the allegations in overt acts 32-45? J. Let's refer to Count 3. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #4 to engage in commercial sex acts knowing that she was under 18? K. Let's refer to Count 13. 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 #4 to engage in prostitution? VII. TESTIMONY REGARDING GIRLS ALREADY COVERED IN GRAND JURY - JANE DOES 9, 10, 14, 15, 16 (Alex,liala,..1, and ) A. JANE DOE #9 (Alex H.) 1. Who is Jane Doe #9? 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 tune did Jane Doe #9 have contact with JE? 3 How old was she during that time frame? 4. And please summarize the sexual activity that Jane Doe #9 was involved in with JE? a. Was she involved in sexual activity with any of the other defendants? 5. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 66-73, 75-77, 80-83, and 90? 6. Let's refer to Count 4. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #9 to engage in Page 6 of 11 EFTA00192675 commercial sex acts knowing that she was under 18? 7. Let's refer to Count 15. 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 #9 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 #9 and Kellen? 8. What was the activity for which a person could be charged with an offense [Vaginal intercourse between an adult over 24 and a 16 or 17 year old minor — violates Fl. Stat. 794.05] B. JANE DOE #10 (B.) 1. Who is Jane Doe #10? 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 #10 have contact with JE? 3. How old was she during that time frame? 4. Please summarize the sexual activity that Jane Doe #10 was involved in with JE? 5. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 67, 74, 78-79, 81, 84-89, 147? 6. Let's refer to Count 5. Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #10 to engage in commercial sex acts knowing that she was under 18? 7. Let's refer to Count 16. 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 #10 to engage in prostitution? How many telephone calls have you been able to Page 7 of 11 EFTA00192676 document between Jane Doe #10 and Kellen? VIII. OTHER BACKGROUND INFO A. Background re defendants and intro section — February 6, 2007 NK Transcript and May 8, 2007 NK Transcript pp. 17-end. B. ASK ABOUT ITEMS TO BE BROUGHT FOR FINAL PRESENTATION - MASSAGE BEDS!!! JANE DOE #14 la E.) 1. Who is Jane Doe #14? 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 #14 have contact with JE? 3. How old was she during that time frame? 4. Please summarize the sexual activity that Jane Doe #14 was involved in with JE? 5. Does your prior testimony and your testimony today cover the evidence supporting the allegations in overt acts 112-131? 6. Let's refer to Count 8, Is the evidence you just summarized the basis for the allegation that JE and SK procured Jane Doe #14 to engage in commercial sex acts knowing that she was under 18? 7. Let's refer to Count 19. 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 #14 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 Nand Kellen? Page 8 of 11 EFTA00192677 a. How old was Jane Doe #14 during this period? And what is the sexual activity that she and JE engaged in that also violated Fl. Stat. 794.05? [Sexual intercourse btwn adult over 24 and a minor.] D. JANE DOE #15 (=NZ.) 1. Who is Jane Doe #15? 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 #15 have contact with JE? 3. How old was she during that time frame? 4. Please summarize the sexual activity that she was involved in with JE? 5. Does your prior testimony and testimony here today cover the evidence supporting the allegations in overt acts 132-148, 175? 6. Let's refer to Count 9. Is the evidence you just summarized the basis for the allegation that JE, SK, and Adriana Ross procured Jane Doe #15 to engage in commercial sex acts knowing that she was under 18? 7. Let's refer to Count 20. Is the evidence you just summarized the basis for the allegation that JE, SK, and Adriana Ross used a facility of interstate commerce to persuade, induce, and entice Jane Doe #15 to engage in prostitution? How many telephone calls have you been able to document between Jane Doe #15 and Kellen? And how many telephone calls between Jane Doe #15 and Ross? E. JANE DOE #16 al D.) 1. Who is Jane Doe #16? Have you testified about her previously? Page 9 of 11 EFTA00192678 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 you just summarized the basis for the allegation that JE, SK, Adriana Ross, and Nadia Marcinkova 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 you just summarized the basis for the allegation that JE, SK, Adrian Ross, and Nadia Marcinkova 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 Marcinkova? 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 EFTA00192679 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 EFTA00192680 E. JANE DOE # 16 a D.) and JANE DOE # 17 MIS 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 JE? 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 HE D.) and JANE DOE # 17 al. 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 JE, 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 EFTA00192681 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 Marcinkova? 17. 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) 18. Does your prior testimony and your testimony today cover the evidence supporting the allegations and overt acts 150-155? 19. Let's 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? EFTA00192682 F. JANE DOE # 7 EMI 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? I3 10. Let's refer to Countili%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? lit; 01 Tcd-wr Mil tor Yr_cietu: a nrAt_ ejjjt EFTA00192683 G. JANE DOE # 8 lalit 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 lime 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? EFTA00192684 JANE DOE # 12 Ell= S.) 1. 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 YE? 7. How much was she paid? 8. Did she recruit anyone to go to JB'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 YE, 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 3E, 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? EFTA00192685 I. JANE DOE # 13 (al.) 1. Who is Jane Doe 11 13? Have you testified about her previously? 2. Has she been interviewed? 3. During what period of time did Jane Doe 11 13 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, 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 Doe # 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 telephone calls have you been able to document between Jane Doe # 13 and Kellen? EFTA00192686 J. JANE DOE # 18 MEI 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 M? 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 182-188, 190? 10. Let's refer to Count 23. Is the evidence you just summarized the basis for the allegation that M, 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 telephone calls have you been able to document between Jane Doe # 18 and Kellen? EFTA00192687 K. JANE DOE # 19 Mt 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 the 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 189-190? EFTA00192688 4-(z_flos OPERATION LEAP YEAR REVISED INDICTMENT SUMMARY CHART (by victiml 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 1 ATTORNEY WORK PRODUCT EFTA00192689 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 N'34- 1, 27 5/22/07 NK Transcript pp. 4-13 15 3 June 1987 12/04 - 6/5/05 132-148, 175 \lil, 27 3/20/07 NK Transcript pp. 4-22 5/15/07 NK Transcript 3-17 Transcript pp. 23-25, 27-28 16 8 October 1987 2/05 - 10/05 '0, 149-151, 156- . \1 ),*2.1, 181 27, 28, 29 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 MC. 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 EFTA00192690 A-/2_q/c)? COURT DISTRICT STATES UNITED FLORIDA OF DISTRICT SOUTHERN No: Case 371 § U.S.C. 18 1591(a)(1) § U.S.C. 18 1591(a)(2) § U.S.C. 18 2422(6) § U.S.C. 18 2423(e) § U.S.C. 18 2423(d) § U.S.C. 18 2423(b) § U.S.C. 18 AMERICA OF STATES UNITED vs. EPSTEIN, JEFFREY KELLEN, SARAH Mucinska," "Adriana a/k/a ROSS, ADRIANA MARCINKOVA, NADIA and Defendants. INDICTMENT that: charges Jury Grand The BACKGROUND Indictment: this to relevant times all At KELLEN, SARAH defendants employed EPSTEIN JEFFREY Defendant 1. perform, to MARCINKOVA NADIA and Mucinska," "Adriana a/k/a ROSS, ADRIANA assistants. personal as services things, other among EFTA00192691 L.G. employed EPSTEIN JEFFREY Defendant 2. other among perform, to assistant. personal a as services things, KELLEN SARAH and EPSTEIN JEFFREY Defendants '3 3! and H.R., T.M., paid other among perform, to A.F. services. recruiting things, property a owned EPSTEIN JEFFREY Defendant 4. Way, Brillo El 358 at located Florida of District Southern the in Florida, Beach, Palm El "358 as to referred (hereinafter Way"). Brillo property a owned EPSTEIN JEFFREY Defendant 5. Street, 71st East 9 at located (hereinafter York New York, New residence"). York New "the as to referred was EPSTEIN JEFFREY Defendant 6. a INC., JEGE, of owner principal the business sole INC.'s JEGE, corporation. Delaware and operation the to related activities aircrifttearing 727-31 Boeing a of ownership N908JE. number tail L_ A; president, as served EPSTEIN JEFFREY Defendant 7. sole and director, sole had and INC., JEGE, of shareholder operations. its of all direct to power the was EPSTEIN JEFFREY Defendant 8. Inc., Air, Hyperion of owner principal the Inc.'s Air, Hyperion corporation. Delaware a operation the to related activities solebusiness h aiit..afttearing -1159B G Gulfstream a of ownership and N909JE. number tail president, as served EPSTEIN JEFFREY Defendant 9. sole and director, sole had and Inc., Air, Hyperion of shareholder operations. its of all direct to power the EFTA00192692 a 794.05, Section Statutes Florida to Pursuant 10. older or age of years 24 "person years 17 or 16 person a with activity sexual in engages who the of felony a commits age of section, "this of purposes For deg*." second vaginal or anal, oral, means activity' `sexual another; of organ sexual the with, union or by, penetration not does activity sexual however, Statutes Florida purpose." medical de fi bona a for done act an include states 794.021 Section victim] the [of age the of "ignorance that "misrepresentation neither that and defense," no is belief de fi bona a victim]-iqr [the by age of age specified the over is person such that [shall] defense." a be , 1- 800.04(5Xa) Sections Statutes Florida to Pursuant 11. adult an 800.04(5)(c)(2), and or lewd a in touches intentionally "who area, genital genitals, breasts, the manner lascivious covering clothing the or buttocks, or or age, of years 16 than less person a of them, or forces so agglio of years 16 under person a entices commits perpetrator, the touch lascivious or lewd degree second the of felony a is which molestation," older or age of years 12 is victim the if age. of years 16 than less but 800.04(6)(a) Sections Statutes Florida to Pursuant 12. adult an 800.04(6)(b), and age of yearA 16 under person a touches [i]ntentionally "who manner lascivious or lewd a in age of years 16 under person a [s]olicits or commits act lascivious or lewd a commit to lewd of felony a is which conduct," lascivious or degree. second the 3 EFTA00192693 and 800.04(7)(a) Sections Statutes Florida to Pursuant 13.. adult an 800.04(7)(c), [i]ntentionally (2) masturbates; [i]ntentionally (1) "who: or lewd a in genitals the exposes other any commits [i]ntentionally (3) or Manner; lascivioUs involve not does that act sexual • with contact sexual or physical actual limited not but including, victim, the the . . . to activity sexual involving act any of simulation less is who victim a of presence the in than which exhibition," lascivious or lewd commits age, of years 16 second the of felony a is degree. 800.04(2), Section Statutes Florida to Pursuant 14. of lack victim's the "[n]either consent victim's the nor chastity 800.04]." [Section by proscribed crimes the to defense a is perpetrator's "[t]he 800.04(3), Section Statutes Florida to Pursuant 15. ignorance her or his of misrepresentation victim's the age, victim's the of bona perpetrator's the or age, defense a as raised canno4e age victim's the of belief fide [Section under prosecution a in 800.04]." a 800.02, Section Statutes Florida to Pursuant 16. any commits who "person person another with act lascivious and unnatural second the of misdemeanor a commits degree." over was EPSTEIN JEFFREY Defendant 17. any have not did and 24 of age the license. medical 4 EFTA00192694 her of period the During 18. #4 Doe Jane Defendants, the with involvement High Central Beach Palm and School High Wellington attended Beach Palm in School • County:: her of period the During 19. #5 Doe Jane Defendants, the with involvement County. Beach Palm in School High Wellington attended their of period the During 20. 8 6, # Does Jane Defendants, the with involvement School High Central Beach Palm attended 12 and County. Beach Palm in her of period the - During 71. #7 Doe Jane Defendants, the with involvement School High Dwyer T. William attended County. Beach Palm in with involvement their of periods the During 22. 9, # Does Jane Defendants, the High Beach Palm Royal attended 19 and 18, 17, 16, 15, 14, County. Beach Palm in School with involvement er of period the During 23. #10 Doe Jane Defendants, the School High Worth Lake attended County. Beach Palm in her of period the During 24. #11 Doe Jane Defendants, the with involvement School, Arts Performing Professional the attended New in located school, high public a York. New York, with involventent her of period the During 25. #13 Doe Jane Defendants, the School High Leonard I. John attended County. Beach Palm in 5 EFTA00192695 1. COUNT 371) § U.S.C. 18 (Conspiracy: of 25 through 1 Paragraphs 26.,, by incorporated and -alleged re are Indictment this herein. forth set fully though as reference 2001, as early as least at From 27. Jury, Grand the to unknown being date exact the 2005, October around or in through of District Southern the in County, Beach Palm in Defendants, the elsewhere, and Florida, EPSTEIN, JEFFREY ICELLBN, SARAH Mucinska," "Adriana a/k/a ROSS, ADRIANA and MARCINKOVA, NADIA confederate conspire, combine, willfully and knowingly did and other each with agree and against offense an commit to unknown and known others with to is, that States, United the - commerce foreign dr interstate of means or facility a use and induce, persuade, knowingly to attained not had who individuals entice prostitution, in engage to years 18 of age the in 2422(6). Section Code, States United 18, Title of violation Conspiracy the of Object and Purpose rc6nspiracy the of object and purpose the was It 28. the under females procure to and Way Brillo El 358 to travel to 18 of age JEFFREY that so residence York New the engage money, for exchange in could, EPSTEIN females minor those with conduct lewd in prurient EPSTEIN's JEFFREY satisfy to order in interests. 6 EFTA00192696 Means and Manner which by means and manner The 29. sought participants other and Defendants the of object and purpose the accomplish to following: the included conspiracy the conspiracy the of part was It (a) KELLEN, SARAH Defendants that MARCINKOVA, NADIA Mucinska," "Adriana a/k/a ROSS, ADRIANA other and via females minor contact would participants telephones other and cellular of use the to females minor for appointments arrange York New the and Way Brillo El 358 to travel to EPSTEIN JEFFREY dant - Ddin allow to residence them. with conduct lewd in engage to conspiracy the of part a trther fi was It (b) JEFFREY Defendants that a/k/a ROSS, ADRIANA and KELLEN, SARAH EPSTEIN, NADIA Mucinska," "Adriana payments make would participants other and MARCINKOVA, be to payments cause or to, engaging exchangtihr in females minor to, made conduct. lewd in conspiracy the of part a further was It (c) JEFFREY Defendants that ROSS, ADRIANA KELLEN, SARAH EPSTEIN, other and Mucinska," "Adriana a/k/a females ask would participants engage to females minor other recruit to with conduct lewd in EPSTEIN. JEFFREY Defendant of part a further was It (d) JEFFREY Defendants that conspiracy the ROSS, ADRIANA KELLEN, SARAH EPSTEIN, other and Mucinska," "Adriana a/k/a payments cause or to, payments make would participants for recruiters the to, made be to 7 EFTA00192697 females minor additional bringing York New the and Way Brillo El 358 to to residence EPSTEIN. JEFFREY Defendant with conduct lewd in engage conspiracy the of part a further was It (e) JEFFREY Defendant that females minor pay would EPSTEIN NADIA Defendant with conduct lewd in engage to EPSTEIN's JEFFREY Defendant satisfy to MARCINKOVA interests. prurient Acts Overt and conspiracy this of furtherance In 30. was there thereof, objects the effect to at herein, co-conspirators the leastane'of at by committed overt following the of one least Florida, of District Southern the in others, among acts, elsewhere: and #2 and #1 Does Jane Defendant 2001, of beginning the around or In (1) EPSTEIN JEFFREY was who #1, Doe bane wit activity sexual in engaged girl, -old -year seventeen a then was who #2, Doe Jane of presence the in girl. -old -year fourteen a then KELLEN SARAH Defendant 2001, around or In (2) the from #2 Doe Jane led upstairs Way Brillo El 358 of kitchen 358 at bedroom EPSTEIN's JEFFREY Defendant to Way. Brillo El , . masturbated EPSTEIN DefendaniJEFFREY 2001, around or In (3) the in fourteen a then was who #2, Doe Jane of presence girl. -old -year asked EPSTEIN JEFFREY Defendant 2001, around or In (4) #2, Doe Jane masturbated. he while nipples his to.pinch old, years' fourteen then was who 8 EFTA00192698 made EPSTEIN JEFFREY Defendant 2001, around or In (5) of payment a #2. Doe Jane to $300 SARAH Defendant 2001, around or In (6) call telephone a placed ICELLEN appointment an make to #2 Doe Jane by used telephone a to travel to #2 Doe Jane for Way. Brillo El 358 to engaged EPSTEIN JEFFREY 2001, around or In (7) intercourse sexual in in female unidentified an with was who #2, Doe Jane of presence the fourteen- a then . girl. -old year paid EPSTEIN JEFFREY Defendant 2001, around or In (8) Jane to $300 girl, -old -year fourteen a then was who #2, Doe female unidentified an allowing for #2 Doe Jane on sex oral perform to presence. EPSTEIN's in Defendant of employee an 2003, 11, eh Iv about or On (9) JEFFREY message telephone written a prepared EPSTEIN EPSTEIN's JEFFREY Defendant for #2. Doe Jane from received call telephone a regarding review asked EPSTEIN JEFFREY Defendant 2003, around or In (10) #2 Doe Jane be would, who friends younger any had she if similar in engaging in interested him. with activities KELLEN SARAH Defendant 2003, around or In (11) photographs nude took -year sixteen a then was who #2, Doe Jane of girl. -old EFTA00192699 made KELLEN SARAH Defendant 2003, around or In (12) of payment a posing for exchange in #2 Doe Jane to $500 photographs. nude for KELLEN SARAH Defendant 2003, around or In (13) ; that #2 Doe Jane told KELLEN asked had EPSTEIN JEFFREY Defendant ofJane photographs nude take to #2. Doe masturbated EPSTEIN JEFFREY Defendant 2003, around or In (14) the in was who #2, Janc,Doe of presence girl. -old -year sixteen a then made EPSTEIN JEFFREY Defendant 2003, oraround In (15) of payment a was who #2, Doe Jane to $200 girl. -old -year sixteen a then placed KELLEN SARAH Defendant 2003, around or In (16) call telephone a appointment an make to #2 Doe Jane by used telephone a to travel to #2 Doe Jane for Way. Brillo El 358 to KELLEN SARAH Defendant 2004, 23, April about or On (17) a placed #2. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2004, 2, May about or On (18) a placed #2. Doe Jane by used telephone a to call telephone #3 Doe Jane masturbated EPSTEIN JEFFREY Defendant 2003, around or In (19) the in was who #3, Doe Jane of presence girl. -old -year fteen fi a then 10 EFTA00192700 made EPSTEIN JEFFREY Defendant 2003, around or In (20) of payment a #3. Doe Jane to $200 KELLEN SARAH Defendant 2004, 26, October about or On (21) 9 a placed , #3. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2004, 30, October about or On (22) a placed #3. Doe Jane by used telephone a to call telephone EPSTEIN JEFFREY Defendant 2004, around In.pr (23) Doe Jane directed seventeen or sixteen- a then was who #3, and female adult an straddle to girl, -old -year breasts. female's adult the touch to EPSTEIN JEFFREY Defendant 2004, around or In (24) massaging a placed female adult an of vagina the on device was who #3, Doe Jane of presence the in then girl. seventeen-year-0cl or sixteen- a made EPSTEIN JEFFREY Defendant 2004, around or In (25) of payment a #3. Doe Jane to $200 EPSTEIN JEFFREY Defendant 2004, around or In (26) Doe Jane instructed nipples. his rub to #3 EPSTEIN JEFFREY Defendant 2004, around or In (27) massaging a placed was who #3, Doe Jane of vagina the on device -old -year seventeen or sixteen- a then girl. 11 EFTA00192701 EPSTEIN JEFFREY Defendant 2004, around or In (28) #3 Doe Jane asked come to females additional recruit to Way. Brillo El 358 to Defendant of one 2004, 8, November about or On (29) JEFFREY written a prepared employees EPSTEIN's Defendant for message telephone a regarding review EPSTEIN's JEFFREY #3 Doe Jane from received call telephone him." for female a have "I read: that placed KELLEN SARAH Defendant 2005, 14, January about or On (30) a #3. Doe Jane by used telephone a to call telephone EPSTEIN's JEFFREY Defendant of one 2005, 29, January about or On (31) message telephone written a prepared employees JEFFREY Defendant for call telephone a regarding review EPSTEIN's read: that #3 Doe Jane from received him." for female a have "I #6 and #5. #4, Does Jane KELLEN SARAH Defendant 2004, of half first the around or In (32) led bedroom EPSTEIN% JEFFREY Defendant to #5 Doe Jane and #4 Doe Jane El 358 at Way. Brillo • EPSTEIN JEFFREY Defendant 2004, of half first the around or In (33) #4 Doe Jane and age, her about #4 Doe Jane asked age. true her with responded 12 EFTA00192702 Defendant 2004, of half fast the around or In (34) EPSTEIN JEFFREY was who #4, Doe Jane of presence the in masturbated -girl, -old -year seventeen a then was who #5, Doe Jane and girl. -old -year seventeen a then Defendant 2004, of half rst fi the around or In (35) EPSTEIN JEFFREY was who #4, Doe Jane instructed girl, -old -year seventeen a then his with play to nipples. Defendant 2004, of half first the around or In (36) EPSTEIN JEFFREY was who #4, Jaa"Doe instructed girl, -old -year seventeen a then her remove to clothing. ) 37 ( EPSTEIN JEFFREY Defendant 2004, of half rst fi the around or In was who #4, Doe Jane of vagina the stroked girl. -old -year seventeen a then Defendant 2004, of half thsrst around or In (38) paid EPSTEIN JEFFREY #4. Doe Jane to $200 Defendant 2004, of half rst fi the around or In (39) paid EPSTEIN JEFFREY #5. Doe Jane to $200 Defendant 2004, of half first the around or In (40) EPSTEIN JEFFREY alttnded. she school high what #6 Doe Jane asked Defendant 2004, of half first the around or In (41) EPSTEIN JEFFREY so leave to #4 Doe Jane instructed alone. him massage could #6 Doe Jane that 13 EFTA00192703 EPSTEIN JEFFREY Defendant 2004, of half rst fi the around or In (42) girl. -old -year sixteen a then was who #6, Doe Jane of presence the in masturbated EPSTEIN JEFFREY Defendant 2004, of half rst fi the around or In (43) girl. -old -year sixteen a then was who #6, Doe Jane penetrated digitally EPSTEIN JEFFREY Defendant 2004, of half rst fi the around or In (44) a then was who #6, Doe Jane of vagina the on massager vibrating large a placed sixteen-year-old,girl. EPSTEIN JEFFREY Defendant 2004, of half rst fi the around or Iii (45) #6. Doe Jane to paid be to $200 of payment a caused #8 and #7 Does Jane who T.M., led EPSTEIN JEFFREY Defendant 2004, July around or In (46) -old -years sixteen a then was who #7, Doe Jane gik„and -old -year een ft fi a then was JEFFREY Defendant to upstairs Way Brillo El 358 of kitchen the from girl, Way. Brillo El 358 at bedroom EPSTEIN's or one made KELLEN SARAH Defendant 2004, 4, July about or On (47) #7. Doe by-Jpe used telephone a to calls telephone more a placed KELLEN SARAH Defendant 2004, 5, July about or On (48) T.M. by used telephone a to call telephone EFTA00192704 masturbated EPSTEIN JEFFREY Defendant 2004, July around or In (49) in was who #8, Doe Jane of presence the girl. -old -year seventeen a then EPSTEIN JEFFREY Defendant 2004, July around or In (50) the stroked was who #8, Doe Jane of vagina girl. -old -year seventeen a then EPSTEIN JEFFREY Defendant 2004, July around or In (51) paid #8. Doe Jane to $200 approximately paid EPSTEIN JEFFREY Defendant 2004, July around 14..or (52) to $200 to #8 Doe Jane recruiting for T.M. Way. Brillo El 358 to travel KELLEN SARAH Defendant 2004, July around or In (53) #8 Doe Jane told #8 Doe Jane pay would EPSTEIN JEFFREY Defendant that a with returned she if friend. KELLEN SARAH Defendant 2004, 5, Jule about or On (54) or one placed #7. Doe Jane by used telephone a to calls telephone more KELLEN SARAH Defendant 2004, 15, July about or On (55) a placed #8. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2004, 15, July about or On (56) a placed T.M. by used telephone a to call telephone KELLEN SARAH Defendant 2004, 16, July about or On (57) or one placed by used telephone a to calls telephone more #7. Doe Jane 15 EFTA00192705 KELLEN SARAH Defendant 2004, 16, July about or On (58) a placed T.M. by used telephone a to call telephone Defendant of one 2004, 17, July about or On (59) 1 EPSTEIN's JEFFREY message telephone written a prepared employees JEFFREY Defendant for a regarding review EPSTEIN's & "Me read: that T.M. from received call telephone any tomorrow come can #7] Doe [Jane alone". [T.M.] or time masturbated EPSTEIN JEFFREY Defendant 2004, July around 1,9.9r (60) in was who #7, Doe Jane - of presence the girl. -old -year sixteen a then EPSTEIN JEFFREY Defendant 2004, July around or In (61) Jane instructed girl, -old -year sixteen a then was who #7, Doe nipples. his rub to EPSTEIN JEFFREY Defendant 2004, July around or In (62) the stroked 4 who #7, Doe Jane of vagina girl. -old -year sixteen a then made EPSTEIN JEFFREY Defendant 2004, July around or In (63) a #7. Doe Jane to $200 of payment EPSTEIN JEFFREY Defendant 2004, July around or In (64) Doe Jane told occurred had what. anyone to reported she if that #7 JEFFREY Defendant at happen could things bad home, EPSTEIN's her. to placed KELLEN SARAH Defendant 2004, 24, July about or On (65) a #8. Doe Jane by used telephone a to call telephone j ; 16 EFTA00192706 #10 and #9 Does Jane placed KELLEN SARAH Defendant 2004, 15, July about or On (66) or one #9. Doe Jane by used telephone a to calls telephone niorei KELLEN SARAH Defendant 2004, 16, July about or On (67) Jane caused calls telephone more or one make to #9 Doe #10. Doe Jane by used telephone a to KELLEN SARAH Defendant 2004, 17, July about or On (68) a placed #9. Doe Jane by used telephone call-to,.a telephone KELLEN SARAH Defendant 2004, 18, July about or On (69) a placed #9. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2004, 22, July about or On (70) a placed #9. Doe Jane by used telephone a to call telephone EPSTEIN JEFFREY Defendant 2004, July around or In (71) the fondled seventeen a then was who #9, Doe Jane of breasts girl. -old -year masturbated EPSTEIN JEFFREY Defendant 2004, July around or In (72) in was who #9, Doe Jane of presence the girl. -old -year seventeen a then made EPSTEIN JEFFREY Defendant 2004, July around or In (73) a #9. Doe Jane to $200 of payment placed KELLEN SARAH Defendant 2004, 22, July about or On (74) a #10. Doe Jane by used telephone a to call telephone 17 EFTA00192707 Defendants 2004, of half last the around or In (75) and EPSTEIN JEFFREY engaged MARCINKOVA NADIA intercourse sexual and sex oral in presence the in seventeen a then was who #9, Doe Jane o girl. -old -year Defendant 2004, of half last the around or In (76) EPSTEIN JEFFREY was who #9, Doe Jane of vagina the into penis his inserted forcibly seventeen- a then girl. -old year Defendant 2004, of half last the around /w (77) made EPSTEIN JEFFREY . , #9. Doe Jane to - $300 of payment a Defendant 2004 of half last the around or In (78) EPSTEIN JEFFREY was who #10, Doe Jane of vagina the rubbed girl. -old -year seventeen a then Defendant 2004, of half last the around or In (79) made EPSTEIN JEFFREY #10. Dile Jane to $200 of payment a Defendant 2004, 28, November about or On (80) EPSTEIN JEFFREY employees his of one for arranged Doe Jane to cash with lled fi envelope an provide to #9. KELLEN SARAH Defendant 4,2004, December about or On (81) provided EPSTEIN JEFFREY Defendant to message written a 10, and 9 # Does Jane regarding pm 4:00 @ work to like would #10] Doe "[Jane stating: #9] Doe [[Jane possible. if movie the today.] 5:00 for scheduled is 7:30". @ is placed KELLEN SARAH Defendant 2004, 29, December about or On (82) #9. Doe Jane by used telephone a to call telephone a 18 EFTA00192708 Defendants 2004, 30, December about or On (83) and EPSTEIN JEFFREY Broadway of purchase the caused KELLEN SARAH birthday eighteenth an as tickets #9. Doe Jane for gfft Defendant 2005, January or 2004 of half last the around or In (84) JEFFREY was who #10, Doe Jane of presence the in masturbated EPSTEIN seventeen- a then girl. -old year Defendant 2005, January or 2004 of half last the around lu.gr (85) JEFFREY was who #10, Doe Jane of breasts the - fondled EPSTEIN -old -year seventeen a then KELLEN SARAH Defendant 2005, 14, January about or On (86) one placed a to calls telephone more or #10. Doe Jane by used telephone ROSS, ADRIANA Defendant 2005, 27, JaiiiiEuy about or On (87) a/k/a more or one placed Mucinska," "Adriana Jane by used telephone a to calls telephone #10. Doe KELLEN SARAH Defendant 2005, 28, January about or On (88) one placed #10. Doe Jane by used telephone a to calls telephone more or MARCINKOVA NADIA Defendant 2005, 1, February about or On (89) a to calls telephone more or one placed #10. Doe Jane by used telephone EPSTEIN JEFFREY Defendant 2005, February around or In (90) a caused #9 Doe Jane to made be to $200 of payment travel to #16 Doe Jane recruiting for to Way. Brillo El 358 19 EFTA00192709 #11 Doe Jane EPSTEIN JEFFREY Defendant 2004, around or In (91) #11 Doe Jane told more him bring and nd fi to her pay would te that girls. EPSTEIN JEFFREY Defendant 2004, around or In (92) Jane to $200 paid female minor a recruiting for #11 Doe home. York New his to travel to EPSTEIN JEFFREY Defendant 2004, around or In (93) #11 Doe Jane asked girls. more getting be would she when Defendant of one 2005, 5, April about or On (94) EPSTEIN's JEFFREY message written a prepared employees EPSTEIN's JEFFREY Defendant for review #11 Doe Jane from received call telephone a regarding have she does "Re read: that over away was I — meet can you friends new any spoken not have I so weekend the be will Doe] Jane [unidenAtfled But, new. anyone to know I and today later around back be should others The work. to wants really she know me Let Thursday. around Doe]." Jane [unidentified about KELLEN SARAH Defendant 2005, 22, June about or On (95) a placed #11. Jane,pcke by used telephone a to call telephone #13 ilitd #12 Does Jane Defendant of employee an 2004, 2, August about or On (96) JEFFREY written a prepared EPSTEIN EPSTEIN's JEFFREY Defendant for message telephone received call telephone a regarding review stated: that #12 Doe Jane and T.M. from maybe and weekend all available are "They too". ilt] Doe [Jane 20 EFTA00192710 KELLEN SARAH Defendant 2004, 21, August about or On (97) a placed #13. Doe Jane by used telephone a to call telephone • the around or In (98) Y EPSTEIN 14(12EY -J Defendant 2004, of half last was who #12, Doe Jane of presence the in masturbated girl. -old -year seventeen a then Defendant 2004, of half last the around or In (99) EPSTEIN JEFFREY was who #12, Doe Jane penetrated digitally girl. -old -year seventeen a then Defendant 2004, of half last the around Ins (100) EPSTEIN JEFFREY 4: I on device massaging a place to attempted was who #12, Doe Jane of vagina the then girl. -old -year seventeen a made EPSTFJN JEFFREY Defendant 2004, of half last the around or In (101) #12. Doe Jane to $200 of payment a asked EPSTEIN JEFFREY Defendant 2004, of half last the around or In (102) her about girl, -old -year seventeen a then was who #12, Doe Jane age. Defendant 2004, of half last the around or In (103) told EPSTEIN JEFFREY her take would he that #12 Doe Jane eighteen. turned she when Angeles Los to EPSTEIN JEFFREY Defendants 2004, of half last the around or In (104) and #13 Doe Jane recruit to #12 Doe Jane caused KELLEN SARAH El 358 to travel to Way. Brillo EPSTEIN JEFFREY Defendant 2004, of half last the around or In (105) was who #13, Doe Jane of presence the in masturbated girl. -old -year seventeen a then 21 EFTA00192711 Defendant 2004, of end the around or In (106) placed EPSTEIN JEFFREY was who #13, Doe Jane of vagina the on device massaging a - -year seventeen a then girl. old made EPSTEIN DefendantJEFFREY 2004, of half last the around or In (107) #13. Doe Jane to $200 of payment a Defendant 2004, of half last the around or In (108) EPSTEIN JEFFREY was who #13, Doe Jane penetr,cl digitally girl. -old -year seventeen a then Defendant 2004, of half last the oraround Iv (109) asked EPSTEIN JEFFREY seventeen a then was who #13, Doe Jane age. her about girl, -old -year Defendant 2004, of half last the around or In (110) told EPSTEIN JEFFREY her take to wanted he that #13 Doe Jane Doe Jane because not could he but Paris to yeafold. eighteen yet not was #13 Defendant 2004, of half last the around or In (111) asked EPSTEIN JEFFREY especially home, his to iends fr her bring to #13 Doe Jane [Jane like looked who "girls #13]." Doe #14 Doe Jane SARAH Defendant 2004, of half last the around or In (112) led ICELLEN upstairs Way Brillo El 358 of kitchen the from #14 Doe Jane JEFFREY Defendant to Way. Brillo El 358 at bedroom EPSTEIN's Defendant 2004, of half last the around or In (113) asked EPSTEIN JEFFREY her provide to #14 Doe Jane number. telephone 22 EFTA00192712 Defendant 2004, of half last the around or In (114) EPSTEIN JEFFREY was who #14, Doe Jane instructed nipples. his pinch to girl, -old -year seventeen a then Defendant 2004, of half last the around or In (115) , EPSTEIN JEFFREY was who #14, Doe Jane of presence the in masturbated girl. old seventeen-year a then Defendant 2004, of half last the around or In (116) made EPSTEIN JEFFREY #14. Doe Jane to $300 of payment a and 2004 of end the around -or In (117) Defendant 2005, of beginning the I., c. was who #14, Doe Jane penetrated digitally EPSTEIN JEFFREY seventeen- a then girl. -old year and 2004 of end the around or In (118) Defendant 2005, of beginning the was who #14, Doe Jane asked EPSTEIN JEFFREY girl, -old -year seventeen a then and birthday eighteenth forAr plans any had she whether had she that acknowledged eighteen. turned yet not Defendant 2004, 23, December about or On (119) EPSTEIN JEFFREY wire Union Western a caused #14. Doe Jane to sent be to order transfer Defendant 2005, of quarter first the around or In (120) EPSTEIN JEFFREY was who #14, Doe Tane of vagina the on device massaging a placed seventeen- a then girl. -old year Defendant 2005, of quarter rst fi the around or In (121) EPSTEIN JEFFREY was who #14, Doe Jane with intercourse sexual in engaged -old -year seventeen a then girl. 23 EFTA00192713 Defendant 2005, of quarter first the around or In (122) EPSTEIN JEFFREY was who #14, Doe Jane on sex oral performed girl. -old -year seventeen a then Defendant 2005, of quarter rst fi the around or In (123) . EPSTEIN JEFFREY d?' #14. Doe Jane to $600 of payment a made KELLEN SARAH Defendant 2005, 8, January about or On (124) a placed #14. Doe Jane by used telephone a to call telephone ROSS, ADRIANA Defendant 2005, 9, January about or On (125) a/k/a call telephone a placed Mucibika," "Adriana #14. Doe Jane by used telephone a to Defendant of one 2005, 26, January about or On (126) EPSTEIN's JEFFREY message telephone written a prepared employees ROSS's ADRIANA Defendant for #14 Doe Jane from received call a regarding review for confirming is "She read: that 5:30". ROSS, ADRIANA Defendant 2005, 26, January about or On (127) a/k/a call telephone a placed Mucinska," "Adriana #14. Doe Jane by used telephone a to KELLEN SARAH Defendant 2005, 1, February about or On (128) a placed #14. Doe Jane by used telephone a to call telephone ROSS, ADRIANA Defendant 2005: 1, March about or On (129) a/k/a call telephone a placed Mucinska," "Adriana #14. Doe Jane by used telephone a to ROSS, ADRIANA Defendant 2005, 21, March about or On (130) a/k/a a placed Mucinska," "Adriana #14. Doe Jane by used telephone a to calls telephone 24 EFTA00192714 KELLEN SARAH Defendant 2005, 29, March about or On (131) a placed. #14. Doe Jane by used telephone a to call telephone #15 Doe Jane KELLEN SARAH Defendant 2004, 6, December about or On (132) placed #15. Doe Jane by used telephone a to call telephone a SARAH Defendant 2004, 14, December about or On (133) placed ICELLEN #15. Doe Jane by used telephone a to call telephone a KELLEN SARAH Defendant 2005, of half rst fi the -around or In (134) led upstairs Way Brillo El 358 of kitchen the om fr #15 Doe Jane JEFFREY Defendant to Way. Brillo El 358 at bedroom EPSTEIN's Defendant 2005, of half rst fi the around or In (135) EPSTEIN JEFFREY who;Was #15, Doe Jane instructed nipples his pinch to girl, -old -year seventeen a then masturbated. he while Defendant 2005, of half rst fi the around or In (136) EPSTEIN JEFFREY #15. Doe Jane of breasts the fondled Defendant 2005, of half rst fi the around or In (137) EPSTEIN JEFFREY #15,'• Doe Jane to $200 of payment a made ROSS, ADRIANA Defendant 2005, 7, January about or On (138) ailda a placed MUCINSKA," "ADR1ANA Doe Jane by used telephone a to call telephone #15. 25 EFTA00192715 KELLEN SARAH Defendant 2005, 4, February about or On (139) a placed #15. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2005, 10, February about or On (140) i v 1 placed #15. Doe Jane by used telephone a to call telephone a KELLEN SARAH Defendant 2005, 21, February about or On (141) placed #15. Doe Jane by used telephone a to call telephone a KELLEN SARAH Defendant 2005, 24, February about or On (142) placed #15: Doe Jane by used telephone a to call telephone a placed KELLEN SARAH Defendant 2005, 17, March about or On (143) a #15. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2005, 30, March about or On (144) a placed #15. Doe Jane by telephonetised a to call telephone KELLEN SARAH Defendant 2005, 31, March about or On (145) a placed #15. Doe Jane by used telephone a to call telephone ROSS, ADRIANA Defendant 2005, 31, March about or On (146) a/k/a cah telephone a placed Mucinska," "Adriana #15. Doe Jane by used telephone a to . Defendant of one 2005, 1, April about or On (147) EPSTEIN's JEFFREY EPSTEIN's JEFFREY Defendant for note a prepared employees read: that review 2'Oclock". around Fri on #10] Doe #15]/[Jane Doe [Jane "10:30 provided EPSTEIN JEFFREY Defendant 2005, June around or In (148) Jane Secret of gift a with #15 Doe birthday. eighteenth her for lingerie 26 EFTA00192716 #17 & #16 Does Jane Defendant 2005, February around or In (149) EPSTEIN JEFFREY , was who #16, Doe Jane of presence the in xiastµrbated girl. -old -year seventeen a then • Defendants 2005, of quarter first the around or In (150) EPSTEIN JEFFREY #16 Doe Jane caused KELLEN SARAH and #17 Doe Jane to call telephone a place to Way. Brillo El 358 to travel to her ask to Defendant 2005, of quarter rst fi the around or In (151) EPSTEIN JEFFREY #16 Doe Jane to made be payment:to a caused travel to #17 Doe Jane recruiting for Way. Brillo El 358 to Defendant 2005, of quarter rst fi the around or In (152) EPSTEIN JEFFREY was who #17, Doe Jane of presence the in masturbated girl. -old -year sixteen a then Defendant 2005, of quarter the'first around or In (153) EPSTEIN JEFFREY -J ... was who #17, Doe Jane instructed her of all remove to girl, -old -year sixteen a then clothing. Defendant 2005, of quarter rst fi the around or In (154) EPSTEIN JEFFREY was who #17, Doe Jane of vagina the on device massaging a placed - sixteen a then girl. -old year EPSTEIN JEFFREY Defendant 2005, of quarter first the around or In (155) was who #17, Doe Jane to $200 of payment a made girl. -old -year sixteen a then 27 EFTA00192717 Defendant 2005, of months nine first the around or In (156) JEFFREY on device massaging a placed EPSTEIN was who #16, Doe Jane of vagina the then girl. iiiernteen-year-old months nine rst fi the around or In (157) JEFFREY Defendant 2005, of was who #16, Doe Jane asked EPSTEIN she old how girl, -old -year seventeen a then old. years seventeen was she that responded she and was, Defendant 2005, of months nine first the around or In (158) JEFFREY MARCINKOVA NADIA Defendant with activity sexual ain g' enga EPSTEIN the in was who #I6, Doe Jane of presence girl. -old -year seventeen a then Defendant 2005, of months nine first the around or In (159) JEFFREY was who #16, Doe Jane asked EPSTEIN to girl, -old -year seventeen a then the touch MARCINKOVA. NADIA Defendant of breast . , ROSS, ADRIANA Defendant 2005, 11, April about or On (160) a/k/a call telephone a placed Mucinska," "Adriana #16. Doe Jane by used telephone a to KELLEN SARAH Defendant 2005, 11, April about or On (161) a placed #16. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2005, 11, April about or On (162) a left stating: EPSTEIN JEFFREY Defendant for message work can #16] Doe "[Jane 4pm." at tomorrow KELLEN SARAH Defendant 2005, 19, May about or On (163) a placed #16. Doe Jane by used telephone a to call telephone 28 EFTA00192718 KELLEN SARAH Defendant 2005, 30, June about or On (164) a placed #16. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2005, 2, July about or On (165) 1, a placed #16. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2005, 22, July about or On (166) a placed #16. Doe Jane by used telephone a to call telephone placed KELLEN SARAH Defendant 2005, 18, August about or On (167) a #16. Doe Jane by used callitti‘a-telephone telephone ROSS, ADRIANA Defendant 2005, 19, August about or On (168) a/k/a call telephone a placed Mucinska," "Adriana #16. Doe Jane by used telephone a to MARCINKOVA NADIA Defendant 2005, 21, August about or On (169) #16. Doe Jane by used telephone a to call telephone a placed ROSS, ADRIANA Defendant 2005, 3, September about or On (170) a/k/a call telephone a placed Mucinska," "Adriana #16. Doe Jane by used telephone a to placed KELLEN SARAH Defendant 2005, 18, September about or On (171) #16. Doe Jane by used telephone a to call telephone a KELLEN SARAH Defendant 2005, 19, September about or On (172) a sent #161 Doe Jane by used telephone a to message text KELLEN SARAH Defendant 2005, 29, September about or On (173) placed #16. Doe Jane by used telephone a to call telephone a 29 EFTA00192719 ROSS, ADRIANA Defendant 2005, 30, September about or On (174) a/k/a call telephone a placed Mucinska," "Adriana #16. Doe Jane by used telephone a to KELLEN SARAH Defendant 2005, 1, October about or On (175) a left EPSTEIN JEFFREY Defendant for message telephone #15] Doe "[Jane stating: 4PM". — #16] Doe [Jane and AM 11 at confirmed KELLEN SARAH Defendant 2005, 2, October about or On (176) a placed #16. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2005, 3, October about or Chi (177) a placed #16. Doe Jane by used telephone a to call telephone KELLEN SARAH Defendant 2005, 3, October about or On (178) a left EPSTEIN JEFFREY Defendant for message telephone will #16] Doe "[Jane stating: . late". hour /2 be Defendant 2005, October, of week rst fi the around or In (179) JEFFREY was who #16, Doe Jane with intercourse sexual in engaged EPSTEIN a then girl. -old -year seventeen Defendant 2005, October, of week rst fi the around or In (180) JEFFREY $350.00 of payment a made EPSTEIN seventeen- a then was who #16, Doe Jane to girl. -old year around or In (181) JEFFREY Defendant 2005, October, of week rst fi the Secret of gift a provided EPSTEIN her for #16 Doe Jane to lingerie birthday. eighteenth 30 EFTA00192720 #19 and #18 Does Jane was #18 Doe Jane 2003, of half last the around or In (182) A.F. by approached willing be would she whether asked was and Defendant to massage a provide to $200. for exchange in EPSTEIN JEFFREY Defendant 2003, of half last the around or In (183) asked EPSTEIN JEFFREY number. telephone her provide to #18 Doe Jane KELLEN SARAH Defendant 2003, 27, August around or On (184) placed #18. Doe Jane by used telephone call-to•a telephone a Defendant 2003, of half last the around or In (185) EPSTEIN JEFFREY was who #18, Doe Jane of presence the in masturbated -girl. -old -year seventeen a then KELLEN SARAH Defendant 2003, 16, November around or On (186) placed #18: Doe Jane by used telephone a to call telephone a Defendant 2003, of half last the around or In (187) EPSTEIN JEFFREY was who #18, Doe Jane penetrated digitally -girl. -old -year seventeen a then Defendant 2003, of half last the around or In (188) asked EPSTEIN JEFFREY females other recruit to #18 Doe Jane Way. Brillo El 358 to travel to EPSTEIN JEFFREY Defendant 2004, 5, March about or On (189) Jane asked girl, -old -year seventeen a then was who #19, Doe to refused she when leave to shirt. her remove 31 EFTA00192721 verbally EPSTEIN JEFFREY Defendant 2004, 5, March about or On (190) she when Way Brillo El 358 to #19 Doe Jane bringing for #18 Doe Jane reprimanded him. for undress to willing iwot r ia j' Travel Defendants' The SARAH EPSTF,IN, JEFFREY Defendants 2004, 11, March about or On (191) to Jersey, New Teterboro, from traveled MARCINKOVA NADIA and KELLEN, Air, Hyperion by owned aircraft Gulfstream the aboard Florida County, Beach Palm Inc. SARAH EPSTEIN, JEFFREY Defendants 2004, 1, May about or On (192) Palm to York New York, New from traveled IVIARCINKOVA NADIA and KELLEN, INC. JEGE, by owned aircraft 727 Boeing the aboard Florida County, Beach SARAH EPSTEIN, JEFFREY Defendants 2004, Mai14, about or On (193) Beach Palm to Canada from traveled MARCINKOVA NADIA and KELLEN, C. IN JEGE, by owned aircraft 727 Boeing the aboard Florida County, and EPSTEIN JEFFREY Defendants 2004, 11, June about or On (194) Florida County, Beach Palm to Illinois Chicago, from traveled KELLEN SARAH Inc. Air, Hyperion by owned aircraft Gulfstream the aboard and EPSTEIN JEFFREY Defendants 2004, 20, June about or On (195) Beach Palm to Islands Virgin U.S. the from traveled MARCINKOVA NADIA INC. JEGE, by owned aircraft 727 Boeing the aboard Florida County, , 32 EFTA00192722 Defendants 2004, 4, July about or On (196) SARAH EPSTEIN, JEFFREY MARCINKOVA NADIA and KELLEN, Colorado Aspen, from traveled Palm to aboard Florida County, each Air, Hyperion by owned aircraft Gulfstream the Inc. Defendants 2004, 16, July about or On (197) SARAH EPSTEIN, JEFFREY MARCINKOVA NADIA and KELLEN, Jersey New Teterboro, from traveled to aboard Florida County, Beach Palm Air, Hyperion by owned aircraft Gulfstream the Inc. Defendants 2004, 22, July about On`or (198) SARAH EPSTEIN, JEFFREY MARCINKOVA NADIA and KELLEN, Islands Virgin U.S. the from traveled to aboard Florida County, Beach Palm INC. WOE, by owned aircraft 727 Boeing the Defendants 2004, 19, August about or On (199) and EPSTEIN JEFFREY California Nuys, Van from travgled MARCINKOVA NADIA County, Beach Palm to by owned aircraft 727 Boeing the aboard Florida INC. JEGE, Defendants 2004, 25, August about or On (200) EPSTEIN, JEFFREY MARCINKOVA NADIA and KELLEN, SARAH Palm to Ecuador from traveled by owned aircraft 727 Boeing the aboard Florida County, Beach INC. JEGE, SARAH EPSTEIN, JEFFREY Defendants 2004, 2, October about or On (201) MARCINKOVA NADIA and KELLEN, Islands Virgin U.S. the from traveled to aboard Florida County, Beach Palm C. IN JEGE, by owned aircraft 727 Boeing the 33 EFTA00192723 Defendants 2004, 29, October about or On (202) and EPSTEIN JEFFREY traveled MARCINKOVA NADIA Beach Palm to Jersey New Teterboro, from Air, Hyperion by owned aircraft Gulfstream the aboard Florida County, Inc. Defendants 2004, 10, November about or On (203) and EPSTEIN JEFFREY New Teterboro, from traveled KELLEN SARAH County, Beach Palm to Jersey Air, Hyperion by owned aircraft Gulfstream the aboard Florida Inc. Defendants 2004, 18, November about or On (204) EPSTEIN, JEFFREY _ a/lc/a ROSS, ADRIANA KELLEN, SARAH NADIA and Mucinska," "Adriana New Teterboro, from traveled MARCINKOVA Florida County, Beach Palm to Jersey Air, Hyperion by owned aircraft Gulfstream the aboard Inc. Defendants 2004, 3, December about or On (205) EPSTEIN, JEFFREY a/k/a ROSS, ADRI'ANA and KELLEN, SARAH from traveled Mucinska," "Adriana Florida County, Beach Palm to York New York, New aircraft 727 Boeing the aboard INC. JEGE, by owned Defendant 2004, 13, December about or On (206) EPSTEIN JEFFREY Islands Virgin U.S. the from traveled aboard Florida, County, Beach Palm to the Air, Hyperion by owned aircraft Gulfstream Inc. Defendants 2004, 17, December about or On (207) and EPSTEIN JEFFREY traveled MARCINKOVA NADIA Beach Palm to Jersey New Teterboro, from Air, Hyperion by owned aircraft Gulfstream the aboard Florida County, Inc. • ti 34 EFTA00192724 SARAH EPSTEIN, JEFFREY Defendants 2005, 1, January about or On (208) MARCINKOVA NADIA and KELLEN, Indies West British Anguilla, from traveled aboard Florida County, Beach Pslm to Hyperion by owned aircraft Gulfstream the Inc. Air, EPSTEIN JEFFREY Defendant 2005, 6, January about or On (209) traveled Florida, County, Beach Palm to Jersey New Teterboro, from Gulfstream the aboard Inc. Air, Hyperion by owned aircraft Defendants 2005, 14, January about :or dif (210) EPSTEIN, JEFFREY Mucinska," "Adriana a/k/a ROSS, ADRIANA KELLEN, SARAH NADIA and Virgin U.S. the from traveled MARCINKOVA County, Beach Palm to Islands JEGE, by owned aircraft 727 Boeing the aboard Florida, INC. Defendants 2005, 19, Urinary about or On (211) EPSTEIN, JEFFREY Mucinska," "Adriana a/k/a ROSS, ADRIANA KELLEN, SARAH NADIA and York New York, New from traveled MARCINKOVA Florida County, Beach Palm to JEGE, by owned aircraft 727 Boeing the aboard EPSTEIN, JEFFREY Defendants 2005, 3, February about or On MARCINKOVA NADIA and KELLEN, SARAH to Ohio, Columbus, from traveled aboard Florida, County, Beach Palm INC. JEGE, by owned aircraft 727 Boeing the EPSTEIN, JEFFREY Defendants 2005, 10, February about or On (213) a/k/a ROSS, ADRIANA KELLEN, SARAH NADIA and Mucinska," "Adriana 35 EFTA00192725 York New York, traveled•fromNew MARCINKOVA Florida, County, Beach Palm to INC. JEGE, by owned aircraft 727 Boeing the aboard Defendants 2005, 21, February about or On (214) EPSTEIN, JEFFREY MARCINKOVA NADIA and KELLEN, SARAH Virgin U.S. the from traveled aboard Florida, County, Beach Palm to Islands by owned aircraft 727 Boeing the JEGE, Defendants 2005, 24, February about or On (215) EPSTEIN, JEFFREY MARCINKOVA NADIA and ICELBEN, SARAH New Teterboro, from traveled aboard Florida, County, Beach Palm to Jersey by owned aircraft Gulfstream the Inc. Air, Hyperion Defendants 2005, 4, March about or On (216) EPSTEIN, JEFFREY MARCINKOVA NADIA and Mucinska," "Adritina a/k/a ROSS, ADRIANA traveled Florida County, Beach Palm to York New York, New from 727 Boeing the aboard INC. JEGE, by owned aircraft EPSTEIN JEFFREY Defendant 2005, 18, March about or On (217) traveled Florida County, Beach Palm to York New York, New from 727 Boeing the aboard INC. JEGE, by owned aircraft EPSTEIN JEFFREY Defendant 2005, 31, March about or On (218) traveled Florida, County, Beach Palm to York New York, New from 727 Boeing the aboard INC. JEGE, by owned aircraft 36 EFTA00192726 Defendants 2005, 19, May about or On (219) SARAH EPSTEIN, JEFFREY Mucinska," "Adriana a/k/a ROSS, ADRIANA and KELLEN, from traveled Florida, County, Beach Palm to Jersey New teterboro, aircraft Gulfstream the aboard Inc. Air, Hyperion by owned Defendants 2005, 30, June about or On (220) and EPSTEIN JEFFREY New Teterboro, from traveled KELLEN SARAH County, Beach Palm to Jersey Air, Hyperion by owned aircraft Gulfstream the aboard Florida Inc. Defendants 2005, 22, July about or pa` (221) and EPSTEIN JEFFREY New Teterboro, from traveled KELLEN SARAH County, Beach Palm to Jersey Air, Hyperion by owned aircraft Gulfstream the aboard Florida Inc. Defendants 2005, 18, August about or On (222) EPSTEIN, JEFFREY MARCINKOVA NADIA and Mucinska," "Adriana a/k/a ROSS, ADRIANA traveled Florida County, Beach Palm to Jersey New Teterboro, from Gulfstream the aboard Inc. Air, Hyperion by owned aircraft EPSTEIN JEFFREY Defendants 2005, 3, September about or On (223) and Mucinska," "Adriana a/k/a ROSS, ADRIANA Islands Virgin U.S. the from traveled aboard Florida County, Beach Palm to Hyperion by owned aircraft Gulfstream the Inc. Air, Defendants 2005, 18, September about or On (224) EPSTEIN, JEFFREY a/k/a ROSS, ADRIANA and KELLEN, SARAH from traveled Mucinska," "Adriana 37 EFTA00192727 Florida County, Beach Palm to York New County, Westchester Gulfstream the aboard Inc. Air, Hyperion by owned aircraft Defendants 2005, 29, September about or On (225) EPSTEIN, JEFFREY MARCINKOVA NADIA and Mucinska," "Adriana a/k/a ROSS, ADRIANA aveled fr Florida County, Beach Palm to Jersey New Teterboro, from Gulfstream the aboard Inc. Air, Hyperion by owned aircraft Section Code, States United 18, Title of violation in All 371. 10 THROUGH 2 COUNTS 1591(a)(1)) § U.S.C. 18 Trafficking: (Sex are Indictment this of 25 through 1 Paragraphs 31. by incorporated and -alleged re herein. forth set fully though as reference as enumerated dates the about or On 32. dates exact the below, listed count each to in:P Jury, Grand the to unknown being Florida, of District Southern the in County, Beach ilm ja knowingly, did below listed Defendants the elsewhere, and and interstate affecting and in by obtain and provide, entice, recruit, commerce, foreign is, that person, a means any the knowing below, sted li count each in person 18 of age the attained not had person the that engage to caused be would and years defined as act sex commecoial a in § U.S.C. 18 in 1591(c)(1): Defendant(s) Involved Minor .., Date(s) Count EPSTEIN JEFFREY #2 Doe Jane 2004 - 2001 2 KELLEN SARAH 38 EFTA00192728 Defendant(s) Involved Minor Date(s) Count 3 , • 2004 January through 2004 July EPSTEIN JEFFREY #4 Doe Jane KELLEN SARAH 2004 July 4 through 29, December 2004 EPSTEIN JEFFREY #9 Doe Jane KELLEN SARAH 2004 July 5 through 2005 31, January EPSTEIN JEFFREY #10 Doe Jane KELLEN SARAH -2004 Mid 6 through 2005 22, April EPSTEIN JEFFREY #12 Doe Jane KELLEN SARAH 2004 August 7 through 2005 27, May EPSTEIN JEFFREY #13 Doe Jane KELLEN SARAH 2004 November 8 through 2005 March #14 Doe Jane .. .` EPSTEIN JEFFREY KELLEN SARAH ROSS, ADRIANA Mucinska" "Adriana a/k/a 2004 December 9 through 2005 5, June EPSTEIN JEFFREY #15 Doe Jane KELLEN SARAH ROSS, ADRIANA Mucinska" "Adriana a/k/a 2005 February 10 through of week first 2005 October #1§ Doe Jane . , EPSTEIN JEFFREY KELLEN SARAH ROSS, ADRIANA Mucinska" "Adriana a/k/a MARCINKOVA NADIA 1591(a)(1) Sections Code, States United 18, Title of violation in All 2. and 39 EFTA00192729 11 COUNT 1591(a)(2)) § U.S.C. 18 Trafficking: (Sex of 25 through 1 Paragraphs 33. and -alleged re are Indictment this by incorporated herein. forth set fully though ai reference as early as least at From 34. 2005, October about or in through 2001 about or in unknown being dates exact the County, Beach Palm in Jury, Grand the to Southern the in elsewhere, and Florida, of District defendants, the KELLEN, SARAH ; Mucinska," "Adrian a/k/a ROSS, .IDRIANA and MARCINKOVA, NADIA by or financially benefit, knowingly did participation from value, of anything receiving a in had which 1591(c)(3), § U.S.C. 18 in defined as venture, described act an in engaged in at 1591(a)(1), § U.S.C. 18 of violation obtaining and providing, enticing, recruiting, the is, affecting or in person, a means any by knowing commerce, interstate or person the that be would and years 18 of age the attained not had persons commercial a in engage to caused 1591(c)(1); § U.S.C. 18 in defined as act sex Code, States United 18, Title of violation in 2. and 1591(b)(2), 1591(a)(2), Sections 12 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement are Indictment this of 25 through 1 Paragraphs 35. by incorporated and -alleged re herein. forth set fully though as reference 40 EFTA00192730 2003 of spring the around or in From 36. 2005, 2, October about or on through the Jury, Grand the to unknown being dates exact District Southern the in County, Beach Palm in defendants, the elsewhere, and Florida, of EPSTEIN JEFFREY and KELLEN, SARAH of means or facility a use did telephone, the is, that commerce, interstate knowingly to had who person a was who #3, Doe Jane entice and induce persuade, of age the attained not and in•prostitution engage to years, 18 charged be can person a which for activity sexual a in that offense, criminal a with 800.04(5)(a), Sections Statutes Florida of violations is 800.04(7)(a); and 800.04(6)(a), 2422(b) Sections Code, States United 18, Title of violation in 2. and 13 COUNT 1 2422(h)) § U.S.C. 18 Minor: a of (Enticement are Indictment this of 25 through 1 Paragraphs 37. by incorporated and -alleged re herein. forth set fully though as reference unknown being dates exact the 2004, July around or In 38. in Jury, Grand the to Florida, of District Southern the in County, Beach Palm defendants, the elsewhere, and EPSTEIN JEFFREY and KELLEN, SARAH commerce, interstate of means or facility a use did knowingly to telephone, the is, that who person a was who #7, Doe Jane entice and induce persuade, of age the attained not had 41 EFTA00192731 prostitution; in engage to years, 18 Sections Code, States United 18, Title of violation in 2. and 2422(b) 14 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement this of 25 through 1 Paragraphs 39. by incorporated and -alleged re are Indictment herein. forth set fully though as reference 2004 July around or in From 40. 2004, October around or in through exact the Jury, Grand the to unknown being dates of District Southern the in County, Beach Palm in defendants, the elsewhere; and Florida, EPSTEIN JEFFREY and KELLEN, SARAH commerce, interstate of means or facility a use did knowingly to telephone, the is, that who person a was who #8, Ddee Jane entice and induce persuade, of age the attained not had prostitution; in engage to years, 18 Sections Code, States United 18, Title of violation in 2. and 2422(b) 15 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement are Indictment this of 25 through 1 Paragraphs 41. by incorporated and -alleged re herein. forth set fully though as reference 2004 July around or in From 42. 2004, 29, December around or on through the Jury, Grand the to unknown being dates exact District Southern the in County, Beach Palm in defendants, the elsewhere, and Florida, of 42 EFTA00192732 EPSTEIN JEFFREY and KELLEN, SARAH commerce, interstate of means or facility a use did knowingly to telephone, the is, that who person a was who #9, Doe Jane entice and induce persuade, of age the attained not had and prostitution in engage to years, 18 charged be can person a which for activity sexual a in Section Statutes Florida of violation a is that offense, criminal a with of violation in 794.05; 2422(b) Sections Code, States United 18, Title 2. and 16 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement are Indictment this of 25 through 1 Paragraphs 43. by incorporated and -alleged re herein. forth set fully though as reference 2004 July around or in From 44. 2005, 31, January about or on through exact the unknown being dates Grand the• to defendants, the elsewhere, and Florida, of District Southern the in County, Beach Palm in EPSTEIN JEFFREY and KELLEN, SARAH commence; interstate of means or facility a use did knowingly to telephone, the is, that who person a was who #10, Doe Jane entice and induce persuade, age the attained not had prostitution; in engage to years, 18 of Sections Code, States United 18, Title of violation in 2. and 2422(b) 43 EFTA00192733 17 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement Indictment this of 25 through 1 Paragraphs 45. by incorporated and -alleged re are herein. forth set fully though leid referene 2004 of middle the around or in From 46. 2005, 22, April about or on through the Jury, Grand the to unknown being dates exact District Southern the in County, Beach Palm in defendants, the elsewhere, and Florida, of EPSTEIN JEFFREY and KELLEN, SARAH commerce, interstate of means or facility a use did knowingly to telephone, the is, that was who #12, Doe Jane entice and induce persuade, age the attained not had who person a prostitution; in engage to years, 18 of Sections Code, States United 18, Title of violation in 2. and 2422(b) 18 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement of 25 through 1 Paragraphs 47. by incorporated and -alleged re are Indictment this herein. forth set fully though as reference .1P 2004 August around or in From 48. 2005, 27, May about or on through exact the Jury, Grand the to unknown being dates of District Southern the in County, Beach Palm in defendants, the elsewhere, and Florida, EPSTEIN JEFFREY and KELLEN, SARAH 44 EFTA00192734 of means or facility a use did is, that commerce, interstate knowingly to telephone, the was who #13, Doe Jane entice and induce persuade, attained not had who person a age the prostitution; in engage ;to y 18 of Sections Code, States United 18, Title of violation in 2. and 2422(b) 19 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement of 25 through 1 Paragraphs 49. and -alleged re are Indictment this by incorporated herein. forth set ray though as reference 2004 November around or in From 50. 2005, March around or in through exact the Jury, Grand the to unknown being dates of District Southern the in County, Beach Palm in defendants, the elsewhere, and Florida, EPSTEIN, JEFFREY KELLEN, SARAH Mucinska," "Adriana a/k/a ROSS, ADRIANA and of means or facility a use did telephone, the is, that commerce, interstate knowingly to was who #14, Doe Jane entice and induce persuade, attained not had who person a age the and prostitution in engage to years, 18 of be can person a which for activity sexual a in that offense, criminal a with charged 794.05; Section Statutes Florida of violation a is in 2422(b) Sections Code, States United 18, Title of violation 2. and 45 EFTA00192735 20 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement are Indictment this of 25 through 1 Paragraphs 51. by incorporated and -alleged re I • herein. forth set fully though id ference re or on 2004.,through December around or in From 52. exact the 2005, 5, June about Jury, Grand the to unknown being dates of District Southern the in County, Beach Palm in defendants, the elsewhere, and Florida, EPSTEIN, JEFFREY and ICELLEN, SARAH Mucinska," "Adriana a/k/a ROSS, ADRIANA of means or facility a use did telephone, the is, that commerce, interstate knowingly to who person a was who #15, Doe Jane entice and induce persuade, age the attained not had Code, States United 18, Title of violation prostitutioniin in engage to years, 18 of Sections 2. and 2422(b) 21 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement of 25 through 1 Paragraphs 53. by incorporated and -alleged re are Indictment this herein. forth set fully though as reference 2005 February around or in From 54. of week first the around or in through unknown being dates exact the 2005, October County, Beach Palm in Jury, Grand the to in elsewhere, and Florida, of District Southern the defendants, the 46 EFTA00192736 EPSTEIN, JEFFREY KELLEN, SARAH Mucinska," "Adriana a/k/a ROSS, ADRIANA MARCINKOVA, NADIA and I 11 „ knowingly to telephone, the is, that commerce, interstate of means or aticility use did of age the attained not had who person a was who #16, Doe Jane entice or induce persuade, charged be can person a which for activity sexual a in and prostitution in engage to years, 18 of violation in 794.05; Section Statutes Florida of violation a is that offense, criminal a with 2. and 2422(b) Sections Statabode, United 18, Title 22 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement by incorporated and -alleged re are Indictment this of 25 through 1 Paragraphs 55. herein. forth set fully though as reference exact the 2005, April around or in through 2005 Feb/nary around or in From 56. of District Southern the in County, Beach Palm in Jury, Grand the to unknown being dates defendants, the elsewhere, and Florida, EPSTEIN, JEFFREY and KELLEN, SARAH Mucinska," "Adriana a/k/a ROSS, ADRIANA knowingly to telephone, the is, that commerce, interstate of means or facility a use did age the attained not had who person a was who #17, Doe Jane entice and induce persuade, Sections Code, States United 18, Tide of violation in prostitution; in engage to years, 18 of 2. and 2422(b) 47 EFTA00192737 23 COUNT 2422(b)) § U.S.C. 18 Minor: a of (Enticement of 25 through 1 Paragraphs 57. by incorporated and -alleged re are Indictment this herein. forth set fully though referenee-as 2003 August around or in From 58. 2004, February around or in through exact the Jury, Grand the to unknown being dates of District Southern the in County, Beach Palm in defendants, the elsewhere, and Florida, EPSTEIN, JEFFREY and KELLEN, SARAH commerce, interstate of means or facility a use did knowingly to telephone, the is, that was who #18, Doe Jane entice and induce persuade, age the attained not had who person a prostitution; in engage to years, 18 of Sections Code, States United 18, Title of violation in 2. and 2422(b) 24 COUNT 2423(e)) § U.S.C. 18 Travel: to (Conspiracy this of 25 through 1 Paragraphs 59. by incorporated and -alleged re are indictment herein. the for set fully as reference 2001 as early as least at From 60. 2005, October around or in through exact the Jury, Grand the to unknown being dates Defendants, the EPSTEIN, JEFFREY KELLEN, SARAH Mucinska," "Adrian a/k/a ROSS, ADRIANA and MARCINKOVA, NADIA 48 EFTA00192738 unknown and known others with and other each with conspire willfully and knowingly did as conduct, sexual illicit in engaging of purpose the for commerce interstate in travel to States United 18, Title of violation in person, another with 2423(f), § U.S.C. in defined 2423(e). Section Code, States United 18, Title of violation in all 2423(b); Section Code, 25 COUNT 2423(d)) § U.S.C. 18 Another: of Travel Unlawful of (Facilitation by incorporated and -alleged re are Indictment this of 25 through 1 Paragraphs 61. herein. forth set though as reference 2005, October around or in through 2001 about or in as early as least at From 62. Southern the in County, Beach Palm in Jury, Grand the to unknown being dates exact the Defendant, the elsewhere, and Florida, of District KELLEN, SARAH facilitate and arrange gain, financial private or vantage at commercial of purpose the for did, was person such that knowing Epstein, Jeffrey Defendant is that person„ a of travel the as conduct, sexual illicit in engaging of purpose the for commerce interstate in traveling 2423(d). Section Code, States United 18, Title of violation in 2423(f); § U.S.C. 18 in defined 29 THRAIJGH 26 COUNTS 2423(6)) § U.S.C. 18 Qinduct: Sexual Illicit in Engage to (Travel by incorporated and -alleged re are Indictment this of 25 through 1 Paragraphs 63. herein. forth set fully though as reference place a from below, listed count each to as enumerated dates the about or On 64. the Florida, of District SoutiOrii the inside place a to Florida of District Southern the outside 49 EFTA00192739 in engaging of purpose the for commerce interstate in traveled below listed Defendant(s) age, of years 18 under person a with 2423(f), § U.S.C. 18 in defined as conduct sexual illicit below: count each in listed person(s) the is, that Defendant(s) Involved Minor(s) Date(s) Count #7 Doe Jane 7/16/2004 26 #8 Doe Jane #9 Doe Jane #10 Doe Jane EPSTEIN JEFFREY KELLEN SARAH MARCINKOVA NADIA #14 Doe Jane 3/31/2005 27 #15 Doe Jane #16 Doe Jane EPSTEIN JEFFREY KELLEN SARAH ROSS, ADRIANA Mucinska" "Adriana a/k/a EPSTEIN JEFFREY #16 Doe Jane 9/18/2005 28 KELLEN SARAH ROSS, ADRIANA Mucinska" "Adriana a/k/a #16 Doe Jitie 9/29/05 29 ..,_ EPSTEIN JEFFREY KELLEN SARAH ROSS, ADRIANA Mucinska" "Adriana a/k/a MARCINKOVA NADIA 2. and 2423(b) Sections Code, States United 18, Title of violation in All 1 FORFEITURE defendants, the indictment, this of 1 in_Count alleged violation the of conviction Upon and Mucinska," "Adriana a/k/a ROSS, ADRIANA KELLEN, SARAH EPSTEIN, JEFFREY personal, or real property, any States United the to forfeit shall MARCINKOVA, NADIA violation. the to traceable proceeds from derived is or constitutes which ti - 50 EFTA00192740 Title 2461; Section Code, States United 28, Title to Pursuant Code, States United 18, Section Code, States United 21, Title and 981(a)(1)(C); Section 853. subject being as above described property litfiq or act any of result a as forfeiture, to ADRIANA KELLEN, SARAH EPSTEIN, JEFFREY defendants, the of omission ROSS, MARCINKOVA, NADIA and Mucinska," "Adriana a/lc/a diligence; due of exercise the upon located be cannot (1) with deposited or to, sold or transferred been has (2) person; third a of jurisdiction the beyond -Placed been has (3) Court; the diminished substantially been has (4) or value; in which property other with commingled been has (5) without subdivided be cannot difficulty; putluant States, United the of intent the is it 853(p), Section Code, States United 21, Title to of property other any of forfeiture seek to above the of value the to up defendants the property. forfeitable Title 2461; Section Code, States United 28 Title to pursuant All States United 18, Section Code, States United 21 Title and 981(a)(1)(C); Section Code, 853. 2 FORFEITURE alleged violations the of any of conviction Upon indictment, this of 12-29 Counts in ROSS, ADRIANA KELLEN, SARAH EPSTEIN, JEFFREY defendants, the "Adriana a/k/a shall MARCINKOVA, NADIA and Mucinska," property, any States United the to forfeit real traceable or constituting personal, or obtained procdeds other or profits gross to such from 51 EFTA00192741 or used personal, or real property, any and offense; or commit to used be to intended to offense, such of commission the promote following: the to limited not but including Beach, Palm Way, Brillo El 358 at located land of parcel A a. Florida buildings, all including 33480, easements and attachments, fixtures, improvements, found described particularly more and thereon, or therein as: Bravo El 39, Lot of feet 24.3 West the and 40 Lot of all Being as Park, 9, Page 9, Book Plat in recorded Florida County, Beach Palm of records the in and Park, Bravo El 40, Lot of West lying pOrtion that BEING 27, Section in as East, 43 Range South, 43 Township Public 9, Page 9, Book Plat in recorded on bounded being Florida, County, Beach Palm of Records the by West the and seawall concrete existing an of side West thereof extension northerly the drawing Inc., Brady, & Adair the on shown as 1981, 25, March dated -I298, IS as shoreline the by East the on bounded and Bravo El of plat the on shown by South and North the on bounded and Park, the of extensions Westerly the 0.07 containing 40, Lot of respectiyely lines South and North or more acres, less. 2253. Section Code, States United 18, Title to Pursuant described property forfeitable the of any If this of section forfeiture the in indictment, EPSTEIN, JEFFREY defendants the of omission or act any of result a as KELLEN, SARAH MARCINKOVA, NADIA and Mucinska," "Adriana a/k/a ROSS, ADRIANA upon located be cannot (a) diligence; due of exercise the sold or transferred been has (b) person; third a with, deposited or to, of jurisdiction the beyond placed been has (c) Court; the diminished substantially been has (d) or value; in 52 EFTA00192742 without divided be cannot which property other with commingled been has (e) difficulty; 2253(o), Section Code, States United 18, Title to pursuant States, United the of theifii4t is it above the of value the to up defendant said of property other any of forfeiture seek to property. forfeitable 2253. Section Code, States United 18, Title to Pursuant 3 FORFEITURE V • indictment, this of 2-11 Counts in alleged violations the of any convictotof Upon "Adrian ailda ROSS, ADRIANA KELLEN, SARAH EPSTEIN, JEFFREY defendants, the real property, any States United the to forfeit shall MARCINKOVA, NADIA and Mucinska," commission the facilitate to or commit to used be to intended or used was that personal, or any from derived or constituting personal, or propertreal any and violation; such of violation, such of result a as indirectly, or directly obtained, person such that proceeds following: the to limited not but including Florida Beach, Palm Way, Brillo El 358 at located land of parcel A a. found easements and attachments, mxtures, fi improvements, buildings, all including 33480, , r rl as: described particularly more and thereon, or therein as Park, Bravo El 39, Lot of feet 24.3 West the and 40 Lot of all Being Florida County, Beach Palm of records the in 9, Page 9, Book Plat in recorded and 27, Section in Park, Bravo El 40, Lot of West lying portion that BEING Public 9, Page 9, Book Plat in recorded as East, 43 Range South, 43 Township the by West the on bounded being Florida, County, Beach Palm of Records 53 EFTA00192743 West side of an existing concrete seawall and the northerly extension thereof as shown on the Adair & Brady, Inc., drawing IS-1298, dated March 25, 1981, and bounded on the East by the shoreline as shown on the plat of El Bravo Park, and bounded on the North and South by the Westerly extensions of the North and South lines respectively of Lot 40, containing 0.07 acres, more or less. Pursuant to Title 18, United States Code, Section 1594(b). A TRUE BILL. FOREPERSON R. ALEXANDER ACOSTA UNITED STATES ATTORNEY A. MARIE VILLAFARA • • ASSISTANT UNITED STATES ATTORNEY 77 54 EFTA00192744 BLACK Rov SREBNICK M. HOWARD KORNSPAN A. SCOTT STUPAPP A. LARRY NEYRA MARIA PERCZEK JACKIE SHAPIRO A.J. MARK JARED BLACK SREBNICK KORNSPAN &STUMPF PA.= 2009 9, December Esq. Villafafia, Marie A. Attorney States United Assistant Office Attorney's States United Florida of District Southern Avenue Australian South 500 400 Suite 33401 Florida Beach, Palm West Epstein Jeffrey RE: Marie: Dear FONSECA-NADER JESSICA PHILLIPS P. KATHLEEN ANTHON AARON JR. BF.ATON, MARCOS O'BRIEN P. MATTHEW SOLILIKIAS J. JENIPER FOX NOAH REglack@Royalack.com -Mail: E Epstein's Jeffrey whether asking 2, November on letter a me emailed You to map Google a reviewed I has. It constant. remained employment of place location the and employment of place that between distance the that confirm the that (and miles 3 than less is Police Beach Palm by stopped was he where work). of place his to route direct a on was walking was he where location have matters other because letter your to respond to while a us taken has It -dollar billion massive the weeks, five past the Over effort. and time our consumed Monday, On exposed. been has Rothstein Scott by run and created conspiracy Brad partner his Rothstein, charging lawsuit RICO civil state a led fi Epstein Mr. resulted that process of abuses fraudulent and tortuous with others and Edwards, this with enclosed is Complaint the of copy A Epstein. Mr. to injury serious in letter. =if and MIE represents firm Rothstein's know, ou Mr. against actions civil rought have who plaintiffs the of three Wilde, litigation the used that enterprise criminal a was firm Rothstein The Epstein. We scheme. ponzi -dollar billion its into investors lure to Epstein Mr. against criminal government's the used co-conspirators his and Rothstein that believe example: For fraud. their further and perpetrate to means a as investigation www.Royfflack.com • 305-358-2006 Fax: 305-371-6421. Phone: • 33131 Florida Miami. • 1300 Suite Boulevard. Biscayne 5. 201 EFTA00192745 Esq. Villafafia, Marie A. 2009 9, December 3 Page once lawyers, Rothstein the So NPA. the of breach a constitute would part our further and perpetrate to government federal the of power the using are again, For extreme. been has cases these tigating li of expense the And fraud. their crimes, Rothstein the of aware was believe not do I who Josefsberg, Bob example, fees. legal in million $2 over demanding now is his and Rothstein claims, investors' the of some by brought lawsuit a As media strategy, litigation The bait. as Epstein Jeffrey used Edwards partner were Edwards and Rothstein of initiatives investigatory and pronouncements, position the advance to than rather deceptions Rothstein's support to calculated with contact had you if that so attention your to facts these bring I clients. his of you Epstein, Mr. concerning past the in him with associated those or Edwards future. the in them of any with communications continuing not consider Mr. about talk to person in you with conference short a ke li would I several discuss to system, justice criminal state the through progress Epstein's about, information accurate have you sure make to want I that issues outstanding Epstein Mr. provide can I that so importantly, most perspective, my from and, are you when dates some me email you If forward. going counsel proper with hopefully office your in meeting short a schedule can we month, this available ends. year the before Black Roy RB/wg Enclosure PA Stumpf, & Komspan Srebnick, Black. EFTA00192746