EPSTEIN
page 4 / 149 . OCR, unverified
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-07625-AJN-DCF Document 1-2 Filed 08/14/19 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-07625-AJN-DCF Document 1-2 Filed 08/14/19 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.
24.
From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New
York, JEFFREY EPSTEIN, the defendant, willfully and knowingly,
in and affecting interstate and foreign commerce, did recruit,
entice, harbor, transport, provide, and obtain by any means a
person, knowing that the person had not attained the age of 18
years and would be caused to engage in a commercial sex act, and
did aid and abet the same, to wit, EPSTEIN recruited, enticed,
harbored, transported, provided, and obtained numerous
Case 1:19-cv-07625-AJN-DCF Document 1-2 Filed 08/14/19 Page 13 of 15
individuals•who were less than 18 years old, including but not
limited to Minor Victim-1, as described above, and who were then
caused to engage in at least one commercial sex act in
Manhattan, New York.
(Title 18, United States Code, Sections 159l(a),
( b) ( 2 ) , and 2 . )
FORFEITURE ALLEGATIONS
25.
As a result of committing the offense alleged in
Count Two of this Indictment, JEFFREY EPSTEIN, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594(c) (1), any property, real and
personal, that was used or intended to be used to commit or to
facilitate the commission of the offense alleged in Count Two,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Two, or any property traceable to
such property, and the following specific property:
a.
The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 9 East 71st Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
Case 1:19-cv-07625-AJN-DCF Document 1-2 Filed 08/14/19 Page 14 of 15
Substitute Asset Provision
26.
If any of the above-described forfeitable
property, as a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d), has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;