EPSTEIN
page 2 / 212 . OCR, unverified
Brunel used his modeling agency to locate
underage girls for Epstein and others to sexually abuse.
Maxwell personally brought
underage girls to Epstein for him to sexually abuse, she also presented him with underage
girls for him to maintain as sex slaves and to travel the globe with him and others,
prostituting underage sex slaves to others.
Maxwell was also a participant in sexually
abusing minor females.
Maxwell served many additional purposes for the criminal
organization and was highly ranked within the organization, thus she was able to act on her
own accord, without needing orders from Epstein. Maxwell's roles and actions on behalf of
the criminal enterprise have included but not been limited to: procuring minor females for her
and Epstein and others to sexually abuse, hiring personnel to work for Epstein and for the
various positions in the criminal organization, developing relationships with politically
connected individuals to protect the organization, managing and organizing the records of the
enterprise, maintaining computer records and images of underage minor females with their
names and phone numbers, threatening witnesses who have information that could hurt the
enterprise, and assisting Epstein and other members of the criminal enterprise to continue the
criminal activity of the organization and avoid law enforcement detection or prosecution.
4. The names of all of the victims are unknown to the plaintiff at this time. However, they
include M.J. herself as well as the victims in the multitude of other civil cases, both filed and
unfiled, against Epstein. A list of more than 30 such minor female victims was previously
provided by the U.S. Attorney's Office for the Southern District of Florida to Epstein (but
not to M.J.).
The injuries to those victims resulted from criminal sexual activity and
prostitution with Epstein and Marcinkova and at times Maxwell. The injuries they suffered
are like those suffered by M.J. in this action, as described in her complaint. For example,
M.J. and the other victims suffered grave emotional distress and financial injury from being
forced to engage in unlawful sexual activities with him to which, as minors, they could not
lawfully consent, and from being introduced into a deviant sexual lifestyle.
They also
suffered distress and financial injury from being prostituted by him.
5. The pattern of racketeering and/or criminal activity is also described in the complaint, which
M.J. incorporates by reference into this statement here and at all other points in the statement.
The criminal activity included Epstein using paid employees and underlings (including
Kellen and Marcinkova) to repeatedly find, procure, and bring to him minor girls in order for
Epstein to solicit, induce, coerce, entice, compel or force these minor girls to engage in
unlawful sexual activity and acts of prostitution and Epstein using Ghislaine Maxwell and
Jean Luc Brunel and others yet unnamed to create the impression that he was involved in
legitimate modeling and other activities.
a. The criminal activity and specific statutes violated are listed in the complaint and
include, but are not necessarily limited to: (i) procuring for prostitution, or causing to
be prostituted, minors, in violation of Florida Statutes Chapter 796; (ii) acts of battery
in violation of Florida Statutes Chapter 784; (iii) commercial sexual exploitation of a
Case 9:10-cv-81111-WPD Document 1-1 Entered on FLSD Docket 09/17/2010 Page 3 of 10
child in violation of Florida Statues § 827.071; and (iv) tampering with a witness in
violation of Florida Statutes § 914.22. The criminal activities also include violations
of federal criminal statutes, including sexual trafficking of children by fraud, in
violation of 18 U.S.C. § 1591, use of a means of interstate commerce to entice a
minor to commit prostitution, in violation of 18 U.S.C. § 2422, as well as wire fraud,
in violation of 18 U.S.C. § 1343.
b. The dates of the events are not fully known to M.J. at this time. However, at a
minimum, Epstein obtained minor girls (including M.J.) for sexual purposes of the
period of approximately 1998 through November 2005.
Epstein could better
determine than M.J. the precise dates of his abuse of her by reviewing his schedule or
computer records for this period of time and looking for notations of days on which
she performed "work" for him. Epstein has pled guilty to two such criminal offenses
against minor girls, although the total number of indictable or chargeable offenses
would easily number more than 1000. On each of these occasions, as described in the
complaint, Epstein would have his underlings, co-conspirators or associates
(including Kellen) procure a minor girl to satisfy his sexual desires and then would
satisfy his sexual desires through criminal sexual contact with the minor girls.
Epstein would also watch Marcinkova or Maxwell sexually abuse the minor girls to