EPSTEIN
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felonies were committed by this criminal organization on an everyday basis. The acts were
part of Epstein's regular way of doing business (e.g., obtaining sexual gratification from
minors) during this period of time. Epstein and others acting at his direction (including
Kellen) made hundreds of telephone calls in furtherance of these illegal activities. The
sexual acts against minors may have temporarily ceased in approximately November 2005
when Epstein learned that law enforcement authorities were investigating his crimes. Given
Epstein's long history of sexually abusing minors and the frequency at which he has done so
and the fact that despite his arrest and jail sentence his criminal organization remains intact, it
is highly likely that he will continue his sexual desires for minor girls. In addition, Epstein
committed criminal acts of tampering with witnesses in violation of Florida Statutes ยง
914.22.
For example, Epstein paid the minor girls money not only with the intent to
prostitute them but also with the specific intent of causing the minor girls not to
communicate to law enforcement officers information about the sexual abuse committed
against them. Epstein made bigger payments to the minor girls depending on the degree of
force he used towards them, making larger payments when he was more concerned about the
Case 9:10-cv-81111-WPD Document 1-1 Entered on FLSD Docket 09/17/2010 Page 5 of 10
fact they might report the crimes committed against them. Without specifically detailing acts
committed against certain known minors, Epstein has paid $1000 on occasion after forcibly
holding the head of a minor down and pumping his penis inside her against her will. Epstein
has also intimidated and reprimanded his co-conspirators and associates for any cooperating
with law enforcement and has made it known that his associates must stay loyal to the
criminal enterprise above all else. These obstructions may interfere with the ability of law
enforcement to discover and prosecute all of Epstein's crimes. They may likewise interfere
with the ability of M.J. to discover all of the information supporting her claim. Epstein also
selected impoverished girls for his crimes, believing that the payments would be more
effective in obtaining their silence and that their economic circumstances might make them
less likely to report to law enforcement. If all else failed, after having unlawful sex with the
minor girls, Epstein would tell them not to tell anyone about their unlawful encounter or "bad
things" would happen. In addition, since November 2005 and through the early part of 2008
(and perhaps later), Epstein and others acting at his direction have attempted to discourage
the victims of his crimes from reporting his crimes and cooperating with law enforcement.
For example, persons acting at the direction of Epstein have aggressively attempted to
"interview" the victims or to "tail" the victims in their cars. They also harassed a victim
shortly before she was to testify at a grand jury investigating Epstein and aggressively
intimidated a victim to scare her away from proceeding to trial against him. These efforts
have been made not for legitimate investigative reasons but rather for the purpose of
discouraging the victims from cooperating with law enforcement (and, in at least one case,
the investigating grand jury) and from filing civil lawsuits to vindicate their rights.
7. The enterprise is also described in the complaint, which allegations M.J. expressly
incorporates into this statement as part of the description of the enterprise. The enterprise
included, at a minimum, a group of individuals associated in fact to assist Epstein in
recruiting and procuring minor girls and obtaining criminal gratification of his illegal sexual
interest in minor girls and at least two individuals (Ghislaine Maxwell and Jean Luc Brunel)
who were free to act independently and advance their own interests, including their own
sexual interests.
a.
The persons constituting the enterprise included a group of individuals associated
in fact.
These individuals include Epstein, Sarah Kellen, Nadia Marcinkova,
Ghislaine Maxwell, and Jean Luc Brunel, as well as other yet unnamed persons
whose names M.J. intends to identify during the discovery phase of this case.
b. The criminal enterprise had a definite hierarchal structure, although all the details
of that structure are not completely know to M.J..
Through discovery, M.J.
intends to ascertain the precise structure of the enterprise that enabled Epstein to
commit sexual crimes against here. While M.J. does not currently know all of the
details of the structure, she does know that the enterprise operated together on a
continuing basis, in an extremely efficient and organized manner, with largely the
same personnel for a common purpose. The shared purpose of the enterprise was
to satisfy Epstein's, as well as certain other individual's, illegal interest in having