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Case 1:19-cv-10474 Document 1-1 Filed 11/12/19 Page 1 of 15




             EXHIBIT A
            Case 1:19-cv-10474 Document 1-1 Filed 11/12/19 Page 2 of 15




 UNITED STATES DISTRICT COURT
 SOUTHERN DISTRICT OF NEW YORK
                                         X
                                                SEALED
  UNITED STATES OF AMERICA                      INDICTMENT

                   - v. -                       19 Cr.

  JEFFREY EPSTEIN,

                   Defendant.
                                             19                            0
                                         X


                                     COUNT ONE
                            (Sex Trafficking Conspiracy)

              The Grand Jury charges:

                                     OVERVIEW

              1.      As set forth herein, over the course of many

years, JEFFREY EPSTEIN, the defendant, sexually exploited and ·

abused dozens of minor girls at his homes in Manhattan, New

York, and Palm Beach, Florida, among other locations.

              2.      In particular, from at least in or about 2002, up

to and including at least in or about 2005, JEFFREY EPSTEIN, the

defendant, enticed and recruited, and caused to be enticed and

recruited, minor girls to visit his mansion in Manhattan, New

York (the "New York Residence") and his estate in Palm Beach,

Florida (the "Palm Beach Residence") to engage in sex acts with

him, after which he would give the victims hundreds of dollars

.in cash.    Moreover, and in order to maintain and increase his

supply of victims, EPSTEIN also paid certain of his victims to

recruit additional girls to be similarly abused by EPSTEIN.               In
        Case 1:19-cv-10474 Document 1-1 Filed 11/12/19 Page 3 of 15




this way, EPSTEIN created a vast network of underage victims for

him to sexually exploit in locations including New York and

Palm Beach.

           3.   The victims described herein were as young as 14

years

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