EFTA02731039

Connected People (13)

Referenced in Findings (3)

Extracted Text

U.S. Department of Justice
United States Attorney
Southern District of New York
Prosecution Memorandum
Privileged and Confidential — Attorney Work Product
Do Not Disseminate Outside ofthe SDNY USAO
USAO #:                       United States v. Epstein, 19 Cr.      ( )      June 11, 2019
This memorandum seeks authorization to charge JEFFREY EPSTEIN with one count
of sex trafficking of children and one count of conspiracy to commit sex trafficking of children.
These charges arise from a years-long scheme to recruit and entice minor girls into engaging in
commercial sex acts, specifically sexualized massages and related sexual activity in exchange for
money, in locations including Manhattan and Palm Beach, Florida. The proposed indictment is
attached hereto, and this memorandum is submitted to provide additional factual background and
relevant legal analysis.
1.      Overview
The Scheme
For a period of years, from at least 2002 through approximately 2005, Epstein engaged
in a pattern of enticing minor girls to engage in paid sex acts.' This conduct was in part revealed
through a previous federal investigation into Epstein by the U.S. Attorney's Office and FBI in the
Southern District of Florida ("SDFL"), which resulted in a 2007 non-prosecution agreement,2 and
was further investigated and revealed thorough our investigation, which began in late 2018.
As detailed below, the SDNY is not bound by the SDFL non-prosecution agreement; moreover,
while our investigation and charges cover some conduct and victims initially identified by the
SDFL investigation, our charges also include conduct and victims who were not interviewed
during that prior investigation, including individuals who were victimized solely in New York.
Based on our review of interview reports from the historical case file and from victim interviews
in media, we have reason to believe that Epstein's conduct traces back at least to the 1990s.
However, because the victims we have interviewed were not abused during that time
we have not focused on that pen
2 Epstein's conduct became the subject of an investigation by the Palm Beach Police Department,
and then the FBI, in approximately 2005, after the parents of a victim reported to law enforcement
that Epstein had abused their daughter. Those investigations spanned approximately two years
and included, among other things, interviews with approximately 35 victims; a search warrant
executed on Epstein's Florida residence; and detailed analysis of various phone and flight records.
As detailed below, the terms of the 2007 non-prosecution agreement required Epstein to plead
guilty in Florida state court to soliciting prostitution, which he did in 2008. He was sentenced to
18 months in jail, was permitted to serve his sentence in a facility where he was released during
the day to work, and was released from his sentence after serving approximately 13 months.
EFTA_00022556
EFTA02731039
Page 2
In both Florida and New York, the scheme operated in a nearly identical fashion:
Epstein essentially operated a pyramid scheme of sexual exploitation, victimizing minor girls who
were brought to his homes to give Epstein erotic "massages," in exchange for hundreds of dollars,
and then paying those individuals to recruit additional minor victims. Once the victims were alone
with Epstein, the "massages" became increasingly sexual. The identified victims ranged from
approximately 14 to 17 years old when their abuse began, with the majority having been
approximately 15 or 16 when they were recruited to perform sex acts with Epstein. Epstein's
conduct included masturbating in front of victims; fondling their breasts; placing a vibrator on
their genitals; and/or directly touching their genitals. Some victims also continued to engage in
such acts with Epstein after they were no longer minors. Victims and recruiters in New York and
Florida generally were paid $300 and $200 per visit, respectively. The victims were typically paid
by Epstein or his employees in cash, in hundred dollar bills.
After their first visit to Epstein's residences, victims in New York and Florida usually
were contacted via telephone by individuals who worked for Epstein to arrange additional
massages. In New York, one of those individuals was Leslie Groff, one ofEpstein's assistants; in
Florida, the primary contact for the girls was                  who was Epstein's employee and often
accompanied him on travel, including to ew or                 everal victims reported that when they
arrived at the Florida residence for massage appointments,               was present at the house and
escorted them to the massage room to meet Epstein.
In order to maintain a steady stream of underage girls to perform sexual acts, Epstein
also directed others, including some of his victims, to recruit other minor girls to engage in
sexualized massages. Some victims brought just one or two friends, while others become prolific
recruiters, bringing Epstein dozens of other girl

[... truncated, 39,207 characters total]