PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS

PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) MEMORANDUM TO: Geoffrey S. Berman. U.S. Attorn FROM: AUSAs DATE: December 19, 2019 RE: Investigation into Potential Co-Conspirators of Jeffrey Epstein This memorandum details the investigative steps taken since the indictment of Jeffrey Epstein in this District on July 2, 2019 and analyzes the extent to which certain of Epstein's associates and employees may or may not be criminally liable for their conduct during their employment with Epstein. I. Background On July 2, 2019, a federal grand jury in the Southern District of New York returned a sealed indictment (the "Indictment") charging Jeffrey Epstein with one count of sex trafficking of minors, in violation of 18 U.S.C. § 1591, and one count of conspiracy to commit sex trafficking of minors, in violation of 18 U.S.C. § 371. The prosecution memorandum in support of that indictment detailed the evidence gathered regarding Epstein and his associates during our Office's pre-indictment investigation. That evidence revealed that beginning in at least 2002, Epstein enticed and recruited dozens of minor girls to engage in sex acts with him, for which he paid the victims hundreds of dollars in cash. He undertook this activity in at least two different locations, including his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence"). In both New York and Florida. Epstein perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to Epstein, which would be performed nude or partially nude, would become increasingly sexual in nature, and would typically include one or more sex acts, including groping and direct or indirect contact with victims' genitals. Epstein paid his victims hundreds of dollars in cash for each separate encounter. Moreover, Epstein actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. He incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each additional girl they brought to him. In this fashion. Epstein created a vast network of underage victims — as young as 14 — in locations including New York and Palm Beach. In creating and maintaining a network of minor victims whom he 1 EFTA 00022461 EFTA02731082 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) abused, Epstein worked with others, including employees and associates who facilitated his exploitation of minors by, among other things, contacting victims and scheduling their sexual encounters with Epstein, both in New Yorlc and in Florida. Epstein was arrested on July 6, 2019, and the Indictment against him was unsealed on July 8, 2019. That same day, our Office held a press conference asking anyone with information, including any victims, to come forward and meet with investigators. In the wake of the press conference, numerous victims and witnesses came forward and were interviewed by the FBI and ow Office. On or about August 10, 2019, Epstein committed suicide while in custody at the Metropolitan Correctional Center. Since his death, we have continued the investigation that remained ongoing following the return of the Indictment against Epstein into tential co- conspirators. In particular, that investigation focused on Ghislaine Maxwell, and Leslie Groff. This memo details the steps taken in this investigation since July 2019, summarizes the potential charges for the conduct at issue, and analyzes the evidence against certain of Epstein's associates and employees: Leslie Groff, and Ghislaine Maxwell. The potential charges against Maxwell will be further analyzed in a separate prosecution memorandum, which is expected to seek authorization to charge Maxwell with federal offenses for her role in facilitating the transport of minors for illegal sex acts. II. Investigative Steps Taken Since the Indictment was unsealed on July 5, 2019, our Office and the FBI have been contacted by numerous potential witnesses —both directly and through their attorneys. Every unrepresented person who contacted the investigative team—either through the FBI tip line or by calling our Office—was contacted in the first instance by an FBI agent for an initial screening interview. The FBI then provided our Office with the names and contact information of individuals who appeared to have information pertinent to our investigation. The AUSAs and case agents then conducted follow up interviews of those identified individuals. In addition, the investigative team initiated contact with numerous witnesses about whom we learned both through our investigation and through press reporting. Although some individuals declined to be interviewed, we ultimately conducted dozens of witness interviews and proffers. At the same time, following the unsealing of the Indictment, ow Office and the FBI took numerous additional investigative steps, including the execution of search warrants, the review of financial records and other documents, and meetings with attorneys for numerous subjects of the investigation. This section walks through the information gathered during our continuing investigation since Epstein's arrest in July 2019. First, we summarize interviews conducted with victims who were abused as minors. Second, we summarize interviews conducted with victims who were abused as adults. Third, we summarize interviews conducted with victims who were not abused. Fourth, we summarize interviews with individuals who are subjects of the investigation. Fifth, we summarize ow interview with one victim, 2 EFTA_ 00022462 EFTA02731083 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Finally, we walk through other investigative steps, such as attorney proffers, search warrants, and document review. A. Interviews of Victims Who Were Abused As Minors 1. Since the unsealing of the Indictment, we have been in regular contact with attorneys who represent Over the course of multiple proffers, all conducted between March 2019 and July 2019, has described how she was recruited to engage in sexual contact with Epstein in approximately , at the age of approximately 14. While at a New York City club, met another teenager who described having worked for a rich man, giving topless massages — and recruiting other girls to do the same—and invited to make money this way. At the time, was living by herself and supporting herself financially, having moved away from a difficult home life. ultimately visited Epstein's New York residence to engage in sexual massages and other sex acts at least dozens of times between approximately , all while she was a minor.' During these visits, performed erotic massages on Epstein, including being partially or fully nude while she massaged him. Most or all of the massages performed by would end with Epstein masturbating and ejaculating; during some of the massages, Epstein touched the genitals o with his hand or with a vibrator or sex toy. also reported a hazy memory of participating in an incident in which was nude with Epstein in his bed. could not recall the details of any sex acts that occurred during that interaction with Epstein ordinarily paid $300 in cash after a massage was completed. During an earlier visit, recalls Epstein asking her how old she was and her truthfully telling Epstein that she was 14 years old. After initial meetings with Epstein, he asked her, in sum and substance, to recruit other girls for the same activity. Over approximately the next two years, estimates that she brought dozens of girls to Epstein to provide massages at his New York residence, starting with girls she knew from her community and eventually strangers whom met at bars, clubs, or other locations. would describe to the girls what was expected, i.e., that they would provide erotic massages to Epstein, while nude, and that Epstein might touch them or ask them to touch him. would schedule appointments for the provided a detailed description of Epstein's New York residence, which was corroborated by photographs taken by the FBI during the execution of a search warrant there in July 2019. 3 EFTA_00022463 EFTA02731084 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) girls by phone with Leslie Groff.2 Although recalls meeting Groff on at least one occasion at her office to pick up some money, she did not have extensive interactions with Groff and did not tell Groff her age. Each time brought a girl to Epstein, was paid $300. and the other girl would also receive $300, alwa in cash. After brought a girl to Epstein, he would sometimes either tell to bring the girl again, if he liked her, or tell not to bring the girl again. noticed that the girls Epstein liked were generally younger and more petite. Epstein would tell "you know what I like." which she took to mean underage, petite girls. Epstein would occasionally indicate his displeasure with for bringing a particular irl, including expressing to that he did not like dark-skinned girls. Later on, as grew older and knew fewer oung girls to bring, she brought older girls, which Epstein expressed displeasure about. recalls at least one occasion when she saw a girl show Epstein an ID to prove she was under 18. 2. During interviews conducted between March and July 2019, described how she was recruited to provide Epstein with sexualized massages at his Palm Beach residence when she was approximately 14 years old. estimates that she herself performed more than ten sexualized massages and that she also recruited approximately 20 to 30 additional girls who were similarly abused by Epstein in Florida. When first encountered Epstein, she was a high school dropout, living away from home and supporting herself financial) . She recalls being recruited b a young girl named at a party who told and her friend that they could make agreed to go to Epstein's Palm Beach $200 by giving a massage to an older man. residence, and she ultimately participated in at least ten massages, which became increasingly sexual over time. She recalled that Epstein would instruct her to pinch his nipples while he masturbated, and that she was often instructed to take her clothes off and perform the massage while nude. During the massages, Epstein would touch her genitals with a vibrator or his hand. She recounted that Epstein would frequently push thin further to see how far he could go. On at least one occasion, Epstein brought another woman, into a sexualized massage with During this encounter, who was an adult at the time, engaged in sex acts with at Epstein's direction. 2 A message slip recovered from a trash pull from E tein's Palm Beach residence during the first Florida investigation included a message from' The phone number associated with that message appears on toll records for one o friends from the same period. I 4 EFTA_00022464 EFTA02731085 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) Epstein asked to bring other girls for massages, which she did. Initially, Epstein simply asked her to "bring a friend" and told her he would pay her to bring other girls. Later, after a few experiences of bringing victims who balked at the sexual nature of the massages, Epstein told her not to bring girls unless they knew what to expect. understood this to mean she should warn girls to expect they would need to take off their clothes, and that Epstein would touch them and masturbate. She then conveyed as much in recruiting new victims. estimates that over the course of several years, she recruited approximately 20 to 30 girls for Epstein, all of whom were approximately 15 to 20 years old.4 believes that most of the girls she recruited were minors. Epstein would occasionally indicate to which girls he liked and which girls he disliked, and she noticed he preferred the younger minors she brought, and that he referred petite blonde girls. usually coordinated these appointments with or specifically recalls that would occasionally call and say that she was in New York, that Epstein would be arriving in Florida soon, and that she wanted to know it could "work" when he arrived.. also recalled- personally taking her to the massage room on some occasions, where she would set up the massage table. also recalls paying her after some of these encounters. When'. first met Epstein, she told him she was 18 because her friend had told her to lie about her age. In truth, she was approximately 14 or 15 at the time, and was wearing braces, and recalls that it would have been obvious that she was very young. Initially, similarly told other girls she brought to Epstein to say they were older because her friend had given her that instruction. Over time, however, based on her observations of the girls that Epstein seemed to prefer—and the sheer number of minors she brought to the house without issue—M came to believe that Epstein wanted younger girls and did not care if the girls told him their true ages. For this reason, stopped telling the girls she recruited to lie about their ages. She stated that the girls she recruited looked very young, and she believes it would have been obvious to anyone that they were underage. When the Florida investigations became public, after had stopped visiting Epstein, she recalls having a phone conversation with in which stated, in sum and substance, that would be taken care of if she didn't say anything. 4 Message pads recovered from Epstein's Palm Beach residence during the first Florida I. investigation include messages with full name and phone number. The messages appear to refer to scheduling appointments an recruiting other girls, e.g.: "She has a female friend for you, please call back as soon as possible." Additionally, the message pads include messages with names of individuals- identified as other victims. 5 Contemporaneous phone records reflect numerous calls between- and 5 EFTA_00022465 EFTA02731086 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) On August 27, 2019, we met with in New York. 3. During During prior interviews conducted between April and July 2019 • described how between approximately-, she went to Epstein's Florida residence approximately 20 times to participate in sexualized massages. receiving ayments of $200 for each visit. recalled that she told Epstein her true age, which was 17. Specifically, explained that she would typically deposit cash from Epstein in her bank account right away. provided a notebook in which she noted sits she made: based on her dates of deposits. it appears the abuse began in approximately , weeks past her sixteenth birthday. The records also appear to show that cash payments from Epstein continued through- several months before her eighteenth birthday. Similar to other victims.. was recruited by a high school friend, who told her she could make money by giving a massage. She recalls Epstein telling her that they could travel together after she turned 18, and that once she turned 18 he would be able to help her with a modeling career. She ultimately stopped going to Epstein's residence because she felt disgusted by her interactions with him. . generally scheduled the massages through . recalled that would sometimes call from New York to schedule massages in advance of Epstein's arrival in Florida. and ifically rec mentioning on calls that was in New York at the time. also recalled pe rsonally taking her to the massage room on some occasions. . specifically recalled telling that she was in high school and could not provide massages at certain times due to school conflicts. She also reported that Epstein asked her to bring girls who looked like her, which she took to mean blonde girls her age.. brought two seventeen -year-old girls to Epstein's house for massages, for which. was also paid.. has reported that the massages became increasingly sexual over time, and included Epstein 6 Contemporaneous phone records reflect numerous contacts between and A comparison of call records against logs of Epstein's flights on his private Jet reflects several sets of calls during times when example, on afternoon: later t t West Palm Beach. appears to have been in New York City with Epstein. For and recc.reflect at had three calls spread throughout the and Epstein flew from - 6 to EFTA_00022466 EFTA02731087 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) touching her genitals and using a vibrator on her genital area, including under her underwear. also recalled that Epstein asked her for intercourse, but she refused. On Au t 27, 2019, we met with in New York. 4. We have interviewed on three occasions. First, on S tember 19, 2019, was interviewed in During this interview, described how she met Epstein and Ghislaine Maxwell and described in general terms how her relationship with them evolved. She did not want to discuss specific incidents of abuse in detail during this interview. In When was about 13 years old Maxwell and Epstehaoached her while she was sitting outside at apicnic table with her friends.' ifiin told asked about back ound. When told Epstein that she live that he gives scholarships and Epstein asked for her phone number so that they could connect. About six weeks later, after had returned home and had turned 14, someone called from Epstein's office askin to have tea with Epstein. They accepted the invitation, and both had tea with Epstein at his Palm Beach residence, during which he explained that he likes to mentor and give scholarships.° After that meetin be an spending more time with Epstein and Maxwell. , Maxwell or an assistant would regularly call house phone to invite to visit with Epstein. recalls Epstein having a number of different assistants, including Leslie Groff and When she was still 14 years old, travelled to New York to visit with Epstein and Maxwell. During that trip, Epstein and Maxwell took shopping and picked out clothing for her, including white underwear. does not recall any sexual contact occurring until after that trip to New York. After that tri frequently went to Epstein's Palm Beach residence. While there. Epstein would Between approximatel I I 9 worked as Maxwell's assistant in 7 EFTA 00022467 EFTA02731088 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) have rub his feet, and he often gave her cash, which he claimed was for her to use for voice lessons. Epstein first sexually abused when she was 14 years old at his Palm Beach residence. The two were discussing desire to be , and Epstein told that she needed to be comfortable in her underwear. Epstein then pulled his pants down, pulledi into his lap and began masturbating. Epstein told a photographer might do this to her, so she needed to be prepared. After that first incident, Epstein increasingly sexually abused After a few months of abusing on his own, Epstein began abusing with Maxwell present. Eventually, Epstein also had other young girls or women participate in sex acts with-could not recall the names of all of these other females, but she vaguely remembers meeting once. She also recalled Epstein's assistant, being involved in sexual contact. Many of these instances occurred in the context of massages, during which would be present when other girls would provide sexualized massages to Epstein. For the next approximately two years, Epstein continued sexually abusing by, among other things, fondling her genitals and using vibrators to touch her genitals. During that period, Epstein also photographed while wearing only underwear.' recalled travelling to New York and New Mexico with both Epstein and Maxwell during this period. She indicated that both Epstein and Maxwell participated in sexual encounters with her during this period, but she was not at that point prepared to go into more details regarding the specifics of the contact. recalled that either Groff or Maxwell would arrange her travel. When was a senior in high school, Epstein paid for her to move to continued abusing there, and eventually raped her in his New York residence. recalled meeting famous friends of Epstein's, including Prince Andrew, but she never had any sexual encounters with any of Epstein's friends. remained in contact with Epstein until , when she was 21 years old. e Second, on November 14, 2019, was re-interviewed in During this interview, clarified her memory of the timing of her interactions with Epstein and Maxwell. She recalled when she was 13 years old, shortly before she turned 14 . She recalled first travelling on Epstein's private jet when she was 14 years old, when she travelled to New York. Epstein first engaged in sexual contact with when she was 14 years old. began her senior year in New York in., so she moved to New York in when she was about 17 years old, then began attending school in New York in the fall after turning 18 years old. Given that timing, she believes she may have been 18 when Epstein raped her in New York. 10 Multiple photographs of were recovered from Epstein's Palm Beach residence during the first Florida investigation. 8 EFTA_00022468 EFTA02731089 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) recalled travelling to New Mexico with Epstein approximately three times. Maxwell was present for each of those trips. She went more frequently to New York, but Maxwell was not around as often during the New York trips because Epstein and Maxwell did not live in the same residence in New York. could not recall whether Maxwell would call her to make appointments to see Epstein while in New York. She generally recalled assistants calling to invite her to see Epstein. recalled that Maxwell was much more present when she first met Epstein and that Maxwell made travel arrangements for during her earlier trips with Epstein. also recalled at least one incident of sexual abuse in New York when she was a minor during which Maxwell was present, but she explained that Maxwell was present for more instances of abuse in Florida. did not wish to discuss the details of incidents of abuse during this meeting. Third, on December 17, 2019, was interviewed for a third time in She recalled that when she was still living in (before she moved to when she was 17 years old), she would speak with Maxwell on the phone about plans to travel with Epstein. She also recalled flying on Epstein's private et with Maxwell. When asked to describe specific instances of abuse before she moved to described sexual assaults ranging from Epstein masturbating in her presence to Epstein touching her genitals with a vibrator to Epstein engaging in oral sex with her to raping her. When asked which specific acts Maxwell was physically present for, indicated that she was not entirely sure. She could only specifically recall instances in which Maxwell was in the room while Epstein masturbated and directed to touch hisinis. She could not recall specifically whether Maxwell was resent when Epstein touched genitals or engaged in other sexual contact with her. did not recall Maxwell ever touching her during an instance of sexual abuse with Epstein. 5. We have interviewed on three occasions. First. on August 27, 2019, met with us in New York. During that interview. described meeting Ghislaine Maxwell lived at the time, when and how much he was oin to like was about 17 ears old. Maxwell talked about her bo end. Jeffrey, One day when Epstein was Maxwell invited to come to Maxwell's residence, where she was introduced to 9 EFTA_00022469 EFTA02731090 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) Epstein. During that fust meeting, Maxwell told that Epstein needed a massage every day and asked to give Epstein a massage. Maxwell then brought- up to a bedroom where Epstein was in a robe. While Maxwell waited outside the room, Epstein removed the robe and got onto the bed. massage. Epstein rolled over, touched then massaged Epstein. During the and put her hand on his penis. After that first sexual assault. Maxwell repeatedl called who was still 17, and invited her to see Epstein at Maxwell's residence During these visits, Epstein engaged in sexual contact with At the time, was not in school but still lived with .11 is confident Maxwell knew her age because Maxwell got her an expensive gift for her 18 birthday. Eventually, Maxwell and Epstein invited to travel with them to Palm Beach, Paris, the Virgin Islands, and New York. Every time travelled with Epstein, he engaged in sexual contact with her. This included sexualized massages during which Epstein used a vibrator to touch her genitals. recalled times that she resisted Epstein's advances, and Maxwell encouraged her to do what Epstein wanted, sayin_•thiike "don't be silly" to minimize the conduct. On one occasion, Maxwell encouraged to wear a schoolgirl uniform for Epstein. When resisted. Maxwell responded. "don't be so frigid." On one occasion, Maxwell asked if she knew someone who could give Epstein "a blow job" because Maxwell did not feel like doing so that day. Maxwell also made comments about Epstein's sexual preferences, notin that he preferred younger looking females and wanted to constantly have sex. understood that Maxwell was Epstein's girlfriend, but she came to understand that Maxwell allowed Epstein to engage in sexual contact with other ple, as long as it did not include intercourse. Nevertheless, Epstein raped on multiple occasions, and he told not to tell Maxwell about the rapes because it violated their understanding. Maxwell also asked to bring other girls to engage in sex with Epstein and repeatedly asked to engage in sex acts with Epstein. Maxwell continued to ask to enga e in sexualized massages with Epstein into her 20s. Over the years, Leslie Groff would contact to invite her to meet Epstein and would make her travel arrangements. Second. on September 19, 2019. met with us in New York. During this interview, she a ' described meeting Maxwell when she was 17 years old. Maxwell then introduced to Epstein, and during that first meeting, Maxwell encouraged. ■to give Epstein a full body massage. Maxwell then waited outside the room while. gave Epstein a massage, during which Epstein put her hand on his penis. After the massage was over. Maxwell asked how it went, whether had nu'. and whether Epstein liked it. Maxwell then paid for the massage. 10 EFTA_00022470 EFTA02731091 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) When turned 18, Maxwell gave her a gift with a card signed by both Epstein and Maxwell. also recalled Maxwell telling someone else at a later date that Maxwell met when she was 17 years old. was not certain whether she began travelling with Epstein and Maxwell before or after her 18 birthday. After she was 18 or 19 years old, recalls Maxwell saying she was getting too old to have a child with Epstein. Maxwell also told that Epstein needed sex three to four times per day. Third, on December 15, 2019, we met with still could not recall whether she first traveled with Epstein and Maxwell when she was 17 or when she was 18. She was certain, however, that she was 17 years old during at least the first two instances when Epstein sexually assaulted her . Both instances occurred at Maxwell's residence had previously described the first instance, which involved Maxwell encouraging her to provide Epstein a massage and waiting outside the bedroom while massaged Epstein, and Epstein first sexually abused- Sometime after leaving Maxwell's residence following that first incident of abuse,. received a call from Maxwell. On the call, Maxwell said was a "clever girl" and that "Jeffrey was very impressed," so Maxwell wanted to schedule a return visit. agreed and sometime later, she returned to Maxwell's London residence. When arrived, Maxwell told her, in substance, that Maxwell was relieved was there because otherwise "it falls to me," which understood to mean that Maxwell had to provide Epstein with sexualized massages if no one else was available. After this conversation, Maxwell walked to a bedroom and opened the door. Inside the room, Epstein was fully nude and standing facing Maxwell and Maxwell said "I'll leave you to it," and left. did not wish to discuss the details of the sexual abuse that occurred during this second massage at this time. After the massage, Maxwell asked if. had a nice time, and then changed the subject to chat about upcoming plans. 6. On September 28, 2019, was interviewed in New York. explained at the outset of the interview that her recollection had been refreshed by reviewing the journal she kept while in high school which we are in the process of obtaining. met Epstein in. and worked in some capacity for Epstein. Between , when was 16 years old and a junior in high school , she took two trips to meet with Epstein. 11 EFTA_00022471 EFTA02731092 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. GRIM. P. 6(e) First. told that Epstein was interested in meeting her and hel • in her with college. Epstein then paid for to fly out to New York . While in New York, stayed saw Epstein twice during this New York trip. During the first meeting, Epstein bought tickets to see the Phantom of the Opera and met with them before the show at his New York residence. During that meeting. Epstein asked about her life and offered to help her with her education. During the second meet' Epstein took , to see the movie 12 Monkeys. Epstein sat between during the movie and touched inappropriately throughout the movie. In particular, Epstein touched leg, stroked her arm, and held her hand. Second, with Epstein and Ghislaine Maxwell. phone about this trip. which made them feel more comfortable about to fly to New Mexico and arranged for a driver to take her to Epstein's New Mexico ranch. background and lifil especifically remembers telling Maxwell that she was a junior in high Once at the ranch, nt time with Maxwell, who expressed interest in school because they discussed her homework, her plans for the upcoming senior year, and her desire to attend college. flew alone to New Mexico, where she spent a weekend recalls that spoke with Epstein on the all knew that Maxwell would be on the trip, traveling alone.' Epstein paid for During this trip to New Mexico, recalls several instances of conduct that made her feel uncomfortable. First, Maxwell encouraged to masse ipstein's feet with her and showed how he liked to have his feet rubbed. Second, i went to the movies with Epstein and Maxwell to see Primal Fear, and outside the theater, Maxwell aiudown Epstein's sweatpants a bit in a joking manner. During the movie. Epstein again held hand and stroked her arm, but he did not to be trying to hide this contact from Maxwell. Third, Maxwell insisted on giving a massage during which was either partially or fully nude. The massage took place in a room with an open door leading to the next room where Epstein was located, such that E stein may have been able to observe- " During the massage. Maxwell rubbed chest, touching the sides of her breasts. Finally, one morning. Epstein came into room, got into bed with her, and said he wanted to cuddle. said she needed to go to the bathroom, and left the room. does not recall having any other contact with Epstein or Maxwell after the New Mexico trip. 12 EFI'A_00022472 EFTA02731093 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) 7. was interviewed on July 31, 2019, August 27, 2019 and November 21, 2019. all in New York. Epstein sexuall assaulted her in New Mexico, Florida, and Paris." said that when she was 17 ears old, first First, during the July 31. 2019 interview, met Epstein through who worked as a masseuse for Epstein and introduced Epstein as someone who could help was on the verge of homelessness and had nowhere else to go. first introduced to Epstein at a hotel-. During that first meeting, Epstein expressed interest in background and offered to pay for her to travel and attend school. After that first meetin , Epstein invited to his home in New Mexico. During that first trip. Epstein asked to 'ye him a massage. was present in the massage room, and both and were in swimsuits. At first, Epstein asked to remove her top and began fondling froze as Epstein turned to her and began to fondle her genitals. During this first interview, was too distressed to describe any other details regarding this assault. She explained, however, that after that first incident, when she was still 17, she travelled with Epstein to other residences where he sexually assaulted her. In particular, recalled during this interview that Epstein assaulted her in New Mexico, Florida, and Paris on four occasions when she was 17 years old. Two of the assaults involved Epstein sneaking into her room at night and raping her. asked not to discuss the details of those assaults during this first interview. E stein aid for to travel to for school. In turned 18 . After turning 18, continued to spend time with E stein for approximately two more years. During that two-year period, Epstein paid for to attend school for three months-long periods." When she was not in school, either travelled with Epstein or resided at an apartment he provided for her in New York. During that same period, Epstein continued to engage in sexual Eventually the stress of continued abuse led to develop an eating 10 As indicated below, during a subsequent interview, clarified that she was in fact assaulted in New Mexico, New York, Florida, and the Virgin Islands when she was 17 years old. Although Epstein engaged in sexual contact with her in other locations, including Paris, she was 18 years old when those incidents took place. 15 We have identified message pads recovered during the first Florida investigation referencing instances in which = called for Epstein during this period. 13 EFTA_00022473 EFTA02731094 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) disorder. When confided in Epstein about her eating disorder for her to fly to Arizona and then essentially disowned her, cutting off contact. he paid While travelling with Epstein, became familiar with the people in his world, including Leslie Groff Ghislaine Maxwell. and Jean Luc Brunel. provided us with copies of photoirahe still had from her time with Epstein, including photographs featuring Epstein. Maxwell. and Brunel. recalled that was Epstein's assistant. In that capacity, arranged the scheduling for Epstein's flights on his roximately five years older than and acted as private jet and coordinated with his pilots and house staff to arrange for E stein's travel. As described above, was present when Epstein sexually assaulted in a massage room at Epstein's New Mexico residence. could not recall, however, whether she ever expressly discussed her age with During this first interview, was too distressed to discuss instances of sexual assault in detail, but she indicated that was present for and participated in two assaults before turned 18, and believed that during these assaults. touched 16 also recalled that took photographs of= while at Epstein's Virgin Islands residence. Although could not be completely sure, she believed that those photographs were taken when she was 17 years old. did not recall whether she was clothed in the photos or if anyone else was in the photos.17 As travelled with Epstein . she noticed a lot of ' is coining and going to and from Epstein's residences in New York and Palm Beach. recalled that these girls would stay for about an hour or so. They appear.oung, but but did not know whether any were under the age of 18. recalled saying generally that the girls were there to see Epstein. recalled that became E stein's girlfriend after returning from her first trip knows that was 18 years old when they met. For about two years, was roommate when the travelled with Epstein, and they shared an apartment in New York. As a result, the two became friends. referred to herself as Epstein's girlfriend, but in general, she and did not discuss the details of their sexual activity with Epstein. 16 As descried below, during a subsequent interview, clarified that she onl recalled one instance of sexual abuse when she was a minor for w lc was present. also clarified that she does not have a memory of= touching er during any instances of abuse. 17 When execut search warrant at Epstein's New York residence, the FBI recovered multiple photographs o in which she is nude or partially nude and appears to be in a tropical location. 14 EFTA 00022474 EFTA02731095 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) understood Ghislaine Maxwell to be Epstein's "partner," who also handled scheduling along with Her impression was that Maxwell's relationship with Epstein was more focused on business than personal matters. explained that Leslie Groff arranged payments for schooling and also coordinated her commercial flights. did not see Groff as often as she saw and Maxwell because Groff did not travel with Epstein. Second, during the August 27, 2019 interview, provided additional details regarding her interactions with other people in Epstein's circle during her time travelling with Epstein. First, explained that she understood to be Epstein's assistant. responsibilities included shopping, travel arrangements, and coordinating with Epstein's pilots. During the time was travelling with Epstein went wherever Epstein did. During this same period, when Epstein was in New York, , resided in the same building as did, though in a different apartment. When in New York, would sometimes call and instruct her to come to Epstein's New York residence. again indicated that was present for the first time Epstein assaulted her and was somehow involved in the second time Epstein assaulted her, but she was not emotionally prepared to describe the details of the assaults during this interview. does not recall speaking explicitly with about her age, but she does recall that was present with Epstein and others for 19ih and 20th birthdays. When asked who else attended those birthdays, recalled that Epstein and were present as well. When asked who else she recalled being associated with Epstein mentioned that a female named whose last name could not recall, was present during an instance when Epstein sexually assaulted in Virgin Islands. recalled that was older than Again, though, was not emotionally prepared to describe the details of that assault. recalled that Leslie Groff booked travel for school. also recalled that Ghislaine Maxwell often travelled with Epstein and would sleep in Epstein's room when they travelled. More generally, explained that she did not discuss Epstein's sexual abuse with anyone, including Maxwell, Groff, and because she felt that it was taboo and not something she should mention. recalled two instances when Epstein asked her to provide massages to other men, both of which took place after turned 18. First, massaged Jean Luc Brunel, but the massage did not involve any sexual contact. Second, when was at Epstein's Paris residence, Epstein instructed her to massage Harvey Weinstein there. When went into the massage room, Weinstein directed to remove her shirt. refused, and in response, Weinstein became angry and told to tell or Weinstein's assistant Bonnie 15 EFTA_00022475 EFTA02731096 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) to come instead. left and told Epstein what happened. Epstein apologized to for putting her in that position. Third, during the November 21, 2019 interview, provided additional details regarding certain instances of abuse and clarified her memories of her interactions with Epstein before turning 18. recalled that when she was about 17 years old introduced her to a man named Joseph Alvarez, a/k/a "Gypsy," , who taught both sisters how to give massages. Alvarez then introduced to Epstein, and she began travelling with him. Later introduced to Epstein. That first meeting took place at a hotel , where met both Maxwell and Epstein. During the meeting, massaged Epstein's feet while he asked about her life and background. told him she wanted to go back to school, and Epstein offered to pay for her to attend school . Following that meeting, Epstein called on multiple occasions, sometimes with Leslie Groff connecting the calls. Eventually, Epstein committed to paying for to attend school . In response, gave up the room in the apartment where she was living, gave notice to her job, and prepared to travelME. A few weeks before left she accepted the invitation. then travelled to Epstein's New Mexico residence in when she was still 17 years old. She recalls Epstein, Maxwell, and other females whose names she does not remember being at the residence when she arrived. remained at the New Mexico residence for a couple of days before returning . Early on in the visit, Maxwell took horseback riding, and told Maxwell about her life and background. Although does not specifically recall saying her age, she believes Maxwell would have had strong indications of her age based on that conversation. Later during that same trip, went swimming in the pool with As they got out of the pool in their swimsuits, Epstein called them over to give him a massage in a nearby massage room. Once inside the massage room, Epstein removed top, began masturbating, and touched breasts and genitals. Epstein then touched genitals. froze and began crying, but Epstein continued to touch her genitals and masturbate until he ejaculated. recalled that- seemed at ease, as though this was a normal occurrence. never spoke about the incident with Epstein invited to New Mexico, and After returned , Epstein called her multiple times, both to discuss her plans to attend school and to invite her on another trip. agreed to go on another trip with Epstein , when she was still 17. In or arounc , she flew o New York, where she visited Epstein at his New York residence. Once there, Epstein brought alone into the dining room where he reached down her pants and fondled her. From New York, flew with Epstein, Maxwell, and another female to Palm Beach, where the group stayed at Epstein's Palm Beach residence for a few days. One of the nights in Palm Beach, Epstein came into the room where was sleeping and raped her. The same group then flew from Palm Beach to the Virgin Islands, where they stayed on at Epstein's Virgin Islands residence. One of the nights on the island, Epstein again came into the 16 EFTA_00022476 EFTA02731097 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) room where was sleeping and raped her. The same group then flew back to Palm Beach.' From there. believes she flew back to After that trip. Epstein paid for to travel to Spain in approximately and attend school there. While in Spain, turned 18 in . At the end of the semester in the spring ofM, Epstein paid for her to fly back to the Virgin Islands and rejoin him at his Virgin Islands residence." Over the next approximately two years. Epstein periodically paid for to travel to attend school for months at a time. When- was not attending school, she travelled with Epstein to his various residences. During the periods she was with Epstein, her understanding was that either or Maxwell scheduled Epstein's massages. She recalled thinking that the masseuses she saw were about her age (18 or 19 years old). 8. On Se tember 10. 2019. we met with when On November 4, 2019, we interviewed in Mlin or around , was approximately 16 years old, a friend of hers named asked if 1° We have identified flight records for E stein'sprivate 'et corroborating account of this trip. In particular, flight records 19 The metadata for some of the nude photogra hs o recovered from Epstein's New York residence suggest that the photos were created , w ch would be consistent with 1I second trip to the Virgin Islands. 17 EFTA_00022477 EFTA02731098 PRIVILEGED - ATTORNEY WORK' PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) she wanted to make money by giving a massage to a billionaire. said yes, and connected her with a your man named 21 who gave a ride to Epstein's Palm Beach residence. told to lie and say she was 18 years old. Once at the residence, met then brought to the massage room while waited downstairs. then gave Epstein a massage, during which Epstein masturbated and o ed genitals and buttocks. At the end of the massage, Epstein offered to a if she brought other girls to engage in similar acts. During that initial meeting, lied and said she was 18 years old and in college. then went her phone number. downstairs and gave After that first encounter, be an bringing other girls to massage E stein. To coordinate the massage appointments, spoke on the phone with continued bringing girls to Epstein's Palm Beach residence for approximately two more years until she was 18 years old and the police began investigating Epstein. In total, estimates she went to Epstein's Palm Beach residence once or twice a month. She recalled that Epstein often went weeks without coming to Florida. When brought a new girl. Epstein always paid 5200 himself. Sometimes would bring girls up to the massage room, and down, then would go up to talk with Epstein and get paid by him. d not recall would wait downstairs for about an hour until the came back di sometimes did. any of the is she brought being upset after a massage, as she always warned them what to expect. only recalls dealing with and never met or spoke with Maxwell, or Groff. In total, brought about six different girls to give sexualized massages to E stein. All except one were minors. At one time, brought someone in her 20s, and told not to bring her again, though he did not say why. All the other girls brought were oun er looking, thinner girls. told everyone she brought to say they were 18 years old. did not recall having any personal conversations with and does not know whether knew how old she or any of the girls she recruited were. recalled that occasionally asked to bring a specific girl. recalls referring to the girls she recruited as her "friends" to Eventually, some of the girls brought began recruiting other girls themselves. recalled walking into the massage room with a recruit at some point and seeing and Epstein leaving the shower/steam room together, which led her to believe they had a sexual relationship. The police approached in 2006, after which she never spoke with Epstein or again. 9. was interviewed on July 14, 2019 in 18 When she was EFTA_00022478 EFTA02731099 PRIVILEGED - ATTORNEY WORK PRODUCT/DELIBERATIVE PROCESS CONFIDENTIAL - SUBJECT TO FED. R. CRIM. P. 6(e) approximately 13 or 14, a friend of hers named recruited to give massages to Epstein at his Palm Beach residence. Over a period of approximately two years, frequently went to his residence and engaged in massage sessions with Epstein, during which he touched her breasts and genitals, used a vibrator on her genital area, and masturbated in front of her. also became a prolific recruiter and estimates that she may have brought as many as one hundred underage girls to Epstein's Palm Beach residence for massages massa became pregnant at the age of 15, after which Epstein no longer wanted to see her, but he allowed to continue recruiting other girls for massages. received $200 for each massage she performed and for each massage performed by a girl she brought to Epstein's Palm Beach residence. recalled that the first time a new girl gave Epstein a massage, Epstein would often ask to stay in the massage room with the new girl. remembered that would sometimes bring girls up to the massage room, but would then leave before the massage began. would sometimes pay following massages. also provided with gifts from Epstein, including a bikini, and baby shower gifts when became pregnant. recalled that she primarily scheduled massages through over the phone. When scheduling an appointment for a new girl, would call, say she had "someone" for Epstein and would describe what the girl looked like. Occasionally would pick up and drive her to Epstein's Palm Beach residence. recalled saying things like, "you know what Jeffrey likes." also believed that knew was in high school, but she could not recall a specific conversation in which told her age or that she was in high school. recalled lying and telling Epstein that she was 16 years old when they met. She also told Epstein that the girls she recruited were all 16 or older. recalled one incident, however, when Epstein was angry with her for bringing an old