EPSTEIN
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satisfy his sexual desires. Epstein had a particular interest in minor girls, including
girls as young as 12. On occasion, he would tum away girls who were 18 or over
because of his perverse and unlawful sexual interest in young girls. Epstein recruited
and paid the girls for the sexual activities. In doing so, he procured for prostitution,
and caused to be prostituted, many young girls under the age of 18, in violation of
(among other statutes) Florida Statute§ 796.03. The pattern of criminal and unlawful
sexual activity extended from at least 1998 through November 2005 and upon
information and belief actually existed and operated in a criminal organizational
structure for many years prior to 1998. Epstein committed unlawful sexual abuse
against M.J. at least 20 times between Summer of 2002 to Spring 2004 while she was
a minor. Other criminal activities involving tampering with and harassing witnesses
occurred from June 2002 through early 2008 (and perhaps later).
c. On many of the occasions, the exact dates of which are not as yet determined by the
M.J., Epstein would represent that he was interested in a "massage" or legitimate
"work" when in fact he was interested in unlawful sexual activity with the minor
girls, including fondling the girls, masturbating in their presence, and vaginally
penetrating them or causing them to be penetrated. Epstein and others acting under
his direction falsely represented to the minor girls that he was interested in a
"massage" or "work" when in fact he was interested in procuring the girls for
unlawful sexual activity and acts of prostitution. Epstein and others acting under his
direction used means of interstate communications to
make these false
representations, including cellular telephones. Similar to all known crime families or
criminal organizations that operate to commit crimes, this criminal enterprise made
use of seemingly innocuous code words such as "message" and "work" to describe
the continuous criminal activity of procuring underage girls to sexually molest, abuse
and exploit.
d. Epstein has pied guilty to two Florida felony criminal offenses against minor girls, as
alleged in the complaint and Epstein is a Registered Sexual Offender for life.
Case 9:10-cv-81111-WPD Document 1-1 Entered on FLSD Docket 09/17/2010 Page 4 of 10
e. The relationship of the criminal activity to the enterprise is also described in the
complaint. The Florida offenses to which Epstein pied guilty are but a few of the
many instances of his plan succeeding. The acts are all related to each other, are
arranged, and are part of common plan for these reasons: they have the same intent
(to gratify Epstein's unlawful sexual interest in minor girls as well as to gratify the
unlawful sexual interests in minor girls of others at times); the same results (the
unlawful sexual abuse and prostitution of minor girls); the same accomplices
(including Kellen and frequently Marcinkova, Maxwell, and Brunel); the same
victims (M.J. was herself victimized more than 20 times, and many other girls were
also victimized repeatedly); the same means (there was a standard payment of several
hundred dollars for going to the mansion, and standard escalation feature depending
on the nature of the sexual acts that Epstein performed); the same methods of
commission (Epstein obtained young, skinny, and attractive girls to satisfy his sexual
desires while they were economically disadvantaged and lacked a stable family life
and therefore, he perceived, would be interested in obtaining money and unlikely to
report his crimes to law enforcement); and the same frequency (remarkably Epstein's
criminal enterprise operated constantly to procure underage minor females to be
sexually abused by Epstein every single day, oftentimes 2 or 3 different underage
females in a single day). The acts were also interrelated by common characteristics,
namely the identity of the perpetrator (Epstein and often Marcinkova or sometimes
Maxwell) and the common results of his crimes (sexual abuse and acts of prostitution
with minor girls). The acts also constituted a clear pattern of criminal activity,
including giving the impression to the girls who were being recruited that they would
have legitimate modeling opportunities.
6. The criminal acts of Epstein occurred repeatedly over a substantial period of time and were
not isolated events. In particular, Epstein committed repeated (more than 20) criminal acts of
sexual abuse against M.J. from approximately Summer 2002 to Spring 2004. He committed
similar criminal acts of unlawful sexual activity and prostitution against other minor girls for
a period of time from at least 1998 to November 2005. The acts occurred frequently during
this time, so frequently that it is impossible to calculate how many different illegal sexual
acts were committed by Epstein and his criminal enterprise, but it is fair to say that serious
felonies were committed by this criminal organization on an everyday basis. The acts were