EPSTEIN
page 6 / 155 . OCR, unverified
this way, EPSTEIN created a vast network of underage victims for
him to sexually exploit in locations including New York and
Palm Beach.
3.
The victims described herein were as young as 14
years old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for various reasons, often particularly
vulnerable to exploitation.
EP~TEIN intentionally sought out
minors and knew that many of his victims were in fact under the
age of 18, including because, in some instances, minor victims
expressly told him their age.
4.
In creating and maintaining this network of minor
victims in multiple states to sexually abuse and exploit,
JEFFREY EPSTEIN, the defendant, worked and conspired with
others, including employees and associates who facilitated his
conduct by, among other things, contacting victims and
scheduling their sexual encounters with EPSTEIN at the New York
Residence and at the Pa.lm Beach Residence.
FACTUAL BACKGROUND
5.
During all time periods charged in this
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with
multiple residences in the continental United States, including
the New York Residence and the Palm Beach Residence.
.
Beginning in at least 2002, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
Case 1:19-cv-10577 Document 1-1 Filed 11/14/19 Page 4 of 15
recruited, dozens of minor girls to engage in sex acts with him,
after which EPSTEIN paid the victims hundreds of dollars in
cash, at the New York Residence and the Palm Beach Residence.
7.
In both New York and Florida, JEFFREY EPSTEIN,
the defendant, perpetuated this abuse in similar ways.
Victims
were initially recruited to provide "massages" to EPSTEIN, which
would be performed nude or partially nude , would become
increasingly sexual in nature, and would typically include one
or more sex acts.
EPSTEIN paid his victims hundreds of dollars
in cash for each encounter.
Moreover, EPSTEIN actively
encouraged certain of his victims to recruit additional girls to
be similarly sexually abused.
EPSTEIN incentivized his victims
to become recruiters by paying these victim-recruiters hundreds
of dollars for each girl that they brought to EPSTEIN.
In so
doing, EPSTEIN maintained a steady supply of new victims to
exploit.
The New York Residence
8.
At all times relevant to this Indictment, JEFFREY
EPSTEIN, the defendant, possessed and controlled a multi-story
private residence on the Upper East Side of Manhattan, New York,
i.e., the New York Residence.
Between at least in or about 2002
and in or about 2005 , EPSTEIN abused numerous minor victims at
the New York Residence by causing these victims to be recruited
to engage in paid sex acts with him.
Case 1:19-cv-10577 Document 1-1 Filed 11/14/19 Page 5 of 15
9.
When a victim arrived at the New York Residence,
she typically would be escorted to a room with a massage table,
where she would perform a massage on JEFFREY EPSTEIN, the
defendant.
The victims, who were as young as 14 years of age,
were told by EPSTEIN or other individuals to partially or fully
undress before beginning the "massage."
During the encounter,
EPSTEIN would escalate the nature and scope of physical contact
with his victim to include, among other things, sex acts such as
groping and direct and indirect contact with the victim's
genitals.
EPSTEIN typically would also masturbate during these
sexualized encounters, ask victims to touch him while he
masturbated, and touch victims ' genitals with his hands or with
sex toys.
10.
In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash.
Victims typically were paid hundreds
of dollars in cash for each encounter.
11.
JEFFREY EPSTEIN, the defendant, knew that many of
his New York victims were underage, including because certain
victims told him their age.
Further, once these minor victims
were recruited, mariy were abused by EPSTEIN on multiple
subsequent occasioni at the New York Residence.
EPSTEIN
sometimes personally contacted victims to schedule appointments
at the New York Residence.
In other instances, EPSTEIN directed
Case 1:19-cv-10577 Document 1-1 Filed 11/14/19 Page 6 of 15
employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12.
Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN.
When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash.
Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse