EPSTEIN
page 2 / 129 . OCR, unverified
other minor girls, some as young as 12 years old, were transported to Defendant's Palm Beach
mansion by Defendant's employees, agents, and/or assistants in order to provide Defendant with
"massages."
12.
Many of the instances of illegal sexual conduct committed by Defendant were
perpetrated with the assistance, support, and facilitation of at least three assistants who helped
him orchestrate this child exploitation enterprise. These assistants would often arrange times for
underage girls to come to Defendant's residence, transport or cause the transportation of
underage girls to Defendant's residence, escort the underage girls to the massage room where
Defendant would be waiting or would enter shortly thereafter, urge the underage girls to remove
their clothes, deliver cash from Defendant to the underage girls and/or their procurers at the
conclusion of each "massage appointment," and, upon information and belief, take nude
photographs and/or videos of the underage girls for Defendant with and/or without their
knowledge. Defendant would pay the procurer of each girl's "appointment" hundreds of dollars.
Podhurst Orseck, P.A.
West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
www.podhurst.com
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 4 of 27
13.
Epstein designed this scheme to secure a private place in Defendant's Palm Beach
mansion where only persons employed and invited by Epstein would be present, so as to reduce
the chance of detection of Defendant's sexual abuse and prostitution as well as to make it more
difficult for the minor girls to flee the premises and/or to credibly report his actions to law
enforcement or other authorities. The girls were usually transported by his employees, agents,
and/or assistants or by a taxicab paid for by Defendant in order to make it difficult for the girls to
flee his mansion.
14.
Upon arrival at Defendant's Palm Beach mansion, each underage victim would
generally be introduced to one of Defendant's assistants, who would gather the girl's personal
contact information. The minor girl would then be led up a flight of stairs to a room that
contained a massage table and a large shower. The staircase leading to the room was plastered
with nude photographs of young girls, including some photographs depicting two or more young
girls engaged in lewd acts. Upon information and belief, Defendant, Jeffrey Epstein, had such
photographs in each of his six homes and/or on his computers.
15.
At times, if it was the girl's first "massage" appointment, another female would
be in the room to "lead the way" until Defendant would have her leave. Generally, Defendant
would start his massage wearing only a small towel, which eventually would be removed.
Defendant and/or the other female would direct the girl to massage him, giving the minor girl
specific instructions as to where and how he wanted to be touched, and then direct her to remove
her clothing. He would then perform one or more lewd, lascivious, and sexual acts, including
masturbation, fondling the minor's breasts and/or sexual organs, touching the minor's vulva,
vagina, and/or anus with a vibrator and/or back massager and/or his finger(s) and/or his penis,
digitally penetrating her vagina, performing intercourse, oral sex, and/or anal sex, and/or
coercing or attempting to coerce the girl to engage in lewd acts and/or prostitution and/or
Podhurst Orseck, P.A.
Case 9:09-cv-80656-KAM Document 1 Entered on FLSD Docket 05/04/2009 Page 5 of 27
enticing the then mmor girl to engage in sexual acts with another female in Defendant's
presence. The exact degree of molestation and frequency with which the sexual exploitations
took place varied and is not yet completely known; however, Defendant committed such acts
regularly on a daily basis and, in most instances, several times a day. In order to facilitate the
daily exchanges of money for sexual assault and abuse, Defendant kept U.S. currency readily
available.
16.
Defendant, Epstein, traveled to his mansion in Palm Beach for the purpose of
luring minor girls to his mansion to sexually abuse and/or batter them. He used the telephone to
contact these minor girls for the purpose of coercing them into acts of prostitution and to enable
himself to commit sexual battery against them and/or acts of lewdness in their presence, and he
conspired with others, including assistants and/or his driver(s) and/or pilot(s), and his socialite
friend/partner, Ghislaine Maxwell, to further these acts and to avoid police detection.
Defendant's systematic pattern of sexually exploitative behavior referred to in paragraph 10 and
described in paragraphs 11 through the present paragraph occurred in all of Defendant's
domestic and international residences and/or places of lodging and/or modes of transportation.
17.
Consistent with the foregoing plan and scheme, Defendant used his money,