Investigation into Potential Co-Conspirators of Jeffrey Epstein
This memorandum details the investigative steps taken since the indictment of Jeffrey Epstein in this District on July 2, 2019 and analyzes the extent to which certain of Epstein's associates and employees may or may not be criminally liable for their conduct during their employment with Epstein.
I. Background
On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging Jeffrey Epstein with one count of sex trafficking of minors, in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371.
The prosecution memorandum in support of that indictment detailed the evidence gathered regarding Epstein and his associates during our Office's pre-indictment investigation. That evidence revealed that beginning in at least 2002, Epstein enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash. He undertook this activity in at least two different locations, including his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence"). In both New York and Florida. Epstein perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to Epstein, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. Epstein paid his victims hundreds of dollars in cash for each separate encounter.
Moreover, Epstein actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion. Epstein created a vast network of underage victims — as young as 14 — in locations including New York and Palm Beach. In creating and maintaining a network of minor victims whom he abused, Epstein worked with others, including employees and associates who facilitated his exploitation of minors by, among other things, contacting victims and scheduling their sexual encounters with Epstein, both in New York and in Florida.
Epstein was arrested on July 6, 2019, and the Indictment against him was unsealed on July 8, 2019. That same day, our Office held a press conference asking anyone with information, including any victims, to come forward and meet with investigators. In the wake of the press conference, numerous victims and witnesses came forward and were interviewed by the FBI and our Office.
On or about August 10, 2019, Epstein committed suicide while in custody at the Metropolitan Correctional Center. Since his death, we have continued the investigation that remained ongoing following the return of the Indictment against Epstein into potential co-conspirators. In particular, that investigation focused on Ghislaine Maxwell, and Leslie Groff. This memo details the steps taken in this investigation since July 2019, summarizes the potential charges for the conduct at issue, and analyzes the evidence against certain of Epstein's associates and employees: Leslie Groff, and Ghislaine Maxwell. The potential charges against Maxwell will be further analyzed in a separate prosecution memorandum, which is expected to seek authorization to charge Maxwell with federal offenses for her role in facilitating the transport of minors for illegal sex acts.
II. Investigative Steps Taken
Since the Indictment was unsealed on July 5, 2019, our Office and the FBI have been contacted by numerous potential witnesses—both directly and through their attorneys. Every unrepresented person who contacted the investigative team—either through the FBI tip line or by calling our Office—was contacted in the first instance by an FBI agent for an initial screening interview. The FBI then provided our Office with the names and contact information of individuals who appeared to have information pertinent to our investigation. The AUSAs and case agents then conducted follow up interviews of those identified individuals. In addition, the investigative team initiated contact with numerous witnesses about whom we learned both through our investigation and through press reporting. Although some individuals declined to be interviewed, we ultimately conducted dozens of witness interviews and proffers. At the same time, following the unsealing of the Indictment, our Office and the FBI took numerous additional investigative steps, including the execution of search warrants, the review of financial records and other documents, and meetings with attorneys for numerous subjects of the investigation.
This section walks through the information gathered during our continuing investigation since Epstein's arrest in July 2019. First, we summarize interviews conducted with victims who were abused as minors. Second, we summarize interviews conducted with victims who were abused as adults. Third, we summarize interviews conducted with victims who were not abused. Fourth, we summarize interviews with individuals who are subjects of the investigation. Fifth, we summarize our interview with one victim.
Finally, we walk through other investigative steps, such as attorney proffers, search warrants, and document review.