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1.74 MB
Extraction Summary
6
People
2
Organizations
1
Locations
2
Events
3
Relationships
4
Quotes
Document Information
Type:
Legal memorandum / court filing (page 3)
File Size:
1.74 MB
Summary
This legal memorandum page details evidence supporting attorney Edwards' conclusion that Epstein operated a 'pyramid abuse scheme' to access underage girls. It cites specific testimony from victims Jane Doe #4 and E.W., as well as a Palm Beach Police Incident Report concerning a 14-year-old victim, S.G. The document describes the recruitment payment structure ($200-$300 per recruit) and graphic details of sexual abuse.
People (6)
| Name | Role | Context |
|---|---|---|
| Epstein | Perpetrator |
Accused of running a pyramid abuse scheme, molesting underage females, and instructing victims to disrobe.
|
| Edwards | Attorney |
Likely Bradley Edwards; the document asserts his 'good faith basis' for conclusions regarding Epstein's scheme.
|
| E.W. | Victim / Recruiter |
Underage female paid by Epstein to bring him other victims.
|
| Jane Doe #4 | Victim / Deponent |
Described being abused by Epstein starting at age 15.
|
| S.G. | Victim |
14-year-old minor brought to Epstein's home; instructed to undress by Epstein.
|
| Epstein's assistant | Facilitator |
Unnamed woman who prepared the massage room and told S.G. that Epstein would be up shortly.
|
Organizations (2)
| Name | Type | Context |
|---|---|---|
| Palm Beach Police |
Produced the Incident Report cited in the document.
|
|
| House Oversight Committee |
Source of the document production (implied by footer stamp).
|
Timeline (2 events)
Locations (1)
| Location | Context |
|---|---|
|
Location where S.G. was taken and where abuse occurred.
|
Key Quotes (4)
"Epstein was able to access a large number of underage girls through a pyramid abuse scheme"Source
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Quote #1
"paid underage victims $200-$300 cash for each other underage victim that she brought to him"Source
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Quote #2
"Being fingered by him, having him use a vibrator on [me], grabbing my nipples, smelling my butt, jerking off in front of me, licking my clit, several times."Source
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Quote #3
"Epstein, then in a towel told her to take off everything."Source
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Quote #4
Full Extracted Text
Complete text extracted from the document (2,238 characters)
using a vibrator and he also paid her $200 for each other underage female E.W. brought him to
molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date
(hereinafter "Jane Doe #4 Depo") (Deposition Attachment #5) at 32-34, and 136 (she describes
first being taken to Epstein at 15 years old, "Being fingered by him, having him use a vibrator on
[me], grabbing my nipples, smelling my butt, jerking off in front of me, licking my clit, several
times.").
molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date
(hereinafter "Jane Doe #4 Depo") (Deposition Attachment #5) at 32-34, and 136 (she describes
first being taken to Epstein at 15 years old, "Being fingered by him, having him use a vibrator on
[me], grabbing my nipples, smelling my butt, jerking off in front of me, licking my clit, several
times.").
3. At all relevant times Edwards has had a good faith basis to conclude and did
conclude² that Epstein was able to access a large number of underage girls through a pyramid
abuse scheme in which he paid underage victims $200-$300 cash for each other underage victim
that she brought to him. See Palm Beach Police Incident Report at 87 (hereinafter "Incident
Report") (Exhibit "A").³ The Palm Beach Police Incident Report details Epstein’s scheme for
molesting underage females. Among other things, the Incident Report outlines some of the
experiences of other Epstein victims. When S.G, a 14 year old minor at the time, was brought to
Epstein’s home, she was taken upstairs by a woman she believed to be Epstein’s assistant. The
woman started to fix up the room, putting covers on the massage table and bringing lotions out.
The "assistant" then left the room and told S.G. that Epstein would be up in a second. Epstein
walked over to S.G. and told her to take her clothes off in a stern voice. S.G. states in the report
she did not know what to do, as she was the only one there. S.G. took off her shirt, leaving her
bra on. Epstein, then in a towel told her to take off everything. S.G. removed her pants leaving
conclude² that Epstein was able to access a large number of underage girls through a pyramid
abuse scheme in which he paid underage victims $200-$300 cash for each other underage victim
that she brought to him. See Palm Beach Police Incident Report at 87 (hereinafter "Incident
Report") (Exhibit "A").³ The Palm Beach Police Incident Report details Epstein’s scheme for
molesting underage females. Among other things, the Incident Report outlines some of the
experiences of other Epstein victims. When S.G, a 14 year old minor at the time, was brought to
Epstein’s home, she was taken upstairs by a woman she believed to be Epstein’s assistant. The
woman started to fix up the room, putting covers on the massage table and bringing lotions out.
The "assistant" then left the room and told S.G. that Epstein would be up in a second. Epstein
walked over to S.G. and told her to take her clothes off in a stern voice. S.G. states in the report
she did not know what to do, as she was the only one there. S.G. took off her shirt, leaving her
bra on. Epstein, then in a towel told her to take off everything. S.G. removed her pants leaving
² In support of all assertions concerning the actions Edwards took, what Edwards learned in the course of his
representation of his clients, Edwards’s good faith beliefs and the foundation for those beliefs, see Edwards
Affidavit and specifically paragraphs 25 and 25 of that Affidavit.
³ For clarity, depositions attached to this memorandum will be identified numerically as attachments #1, #2, #3, etc.,
while exhibits attached to this memorandum will be identified alphabetically as exhibits A, B, C, etc.
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representation of his clients, Edwards’s good faith beliefs and the foundation for those beliefs, see Edwards
Affidavit and specifically paragraphs 25 and 25 of that Affidavit.
³ For clarity, depositions attached to this memorandum will be identified numerically as attachments #1, #2, #3, etc.,
while exhibits attached to this memorandum will be identified alphabetically as exhibits A, B, C, etc.
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