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Case 1:19-cv-07625-AJN-DCF Document 1-2 Filed 08/14/19 Page 1 of 15
EXHIBIT B
Case 1:19-cv-07625-AJN-DCF Document 1-2 Filed 08/14/19 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.
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-07625-AJN-DCF Document 1-2 Filed 08/14/19 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 old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for va
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