EPSTEIN
page 3 / 67 . OCR, unverified
At
the time of certain of those phone calls, EPSTEIN and Employee-2
were in New York, New York.
Additionally, certain of the
individuals victimized at the Palm Beach Residence were
contacted by phone by Employee-3 to schedule these encounters.
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 9 of 15
19.
Moreover, as in New York, to ensure a steady
stream of minor victims, JEFFREY EPSTEIN, the defendant, asked
and enticed certain victims in Florida to recruit other girls to
engage in sex acts.
EPSTEIN paid hundreds of dollars to victim-
recruiters for each additional girl they brought to the Palm
Beach Residence.
STATUTORY ALLEGATIONS
20.
From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New York
and elsewhere, JEFFREY EPSTEIN, the defendant, and others known
and unknown, willfully and knowingly did combine, conspire,
confederate, and agree together and with each other to commit an
offense against the United States, to wit, sex trafficking of
minors, in violation of Title ·18, United States Code, Section
159l(a) and (b).
21.
It was a part and object of the conspiracy that
JEFFREY EPSTEIN, the defendant, and others known and unknown,
would and did, in and affecting interstate and foreign commerce,
recruit, entice, harbor, transport, provide, and obtain, by any
means a person, and to benefit, financially and by receiving
anything of value, from participation in a venture which has
engaged in any such act, knowing that the person had not
attained the age of 18 years and would be caused to engage in a
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 10 of 15
commercial sex act, in violation of Title 18, United States
Code, Sections 1591 (a) and (b) (2).
Overt Acts
22.
In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a.
In or about 2004, JEFFREY EPSTEIN, the
defendant, enticed and recruited multiple minor victims,
including minor victims identified herein as Minor Victim-1,
Minor Victim-2, and Minor Victim-3, to engage in sex acts with
EPSTEIN at his residences in Manhattan, New York, and Palm
Beach, Florida, after which he provided them with hundreds of
dollars in cash for each encounter.
b.
In or about 2002, Minor Victim-1 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the New York Residence over a
period of years and was paid hundreds of dollars for each
encounter.
EPSTEIN also encouraged and enticed Minor Victim-1
to recruit other girls to engage in paid sex acts, which she
I
did.
EPSTEIN asked Minor Victim-1 how old she was, and Minor
Victim-1 answered truthfully.
c.
In or about 2004, Employee-1, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 11 of 15
a telephone call to Minor Victim-1. in order to schedule an
appointment for Minor Victim-1 to engage in paid sex acts with
EPSTEIN.
d.
In or about 2004, Minor Victim-2 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars after each
encounter.
EPSTEIN also encouraged and enticed Minor Victim-2
to recruit other girls to engage in paid sex acts, which she
did.
e.
In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-2 in order to schedule an
appointment for Minor Victim-2 to engage in paid sex acts with
EPSTEIN.
f.
In or about 2005, Minor Victim-3 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars for each
encounter.
EPSTEIN also enco~raged and enticed Minor Victim-3
to recruit other girls to engage in paid sex acts, which she
did.
EPSTEIN asked Minor Victim-3 how old she was, and Minor
Victim-3 answered truthfully.
Case 1:19-cv-11869-MKV-DCF Document 1-1 Filed 12/27/19 Page 12 of 15
g.
In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-3 in Florida in order to
schedule an appointment for Minor Victim-3 to engage in paid sex
acts with EPSTEIN.
h.
In or about 2004, Employee-3 placed a
telephone call to Minor Victim-3 in order to schedule an
appoint~ent for Minor Victim-3 to engage in paid sex acts with·
EPSTEIN.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
23.
The allegations contained in paragraphs·l
through 19 and 22 of this Indictment are repeated and realleged
as if fully set forth within.