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Case 1:20-cr-00330-PAE Document 670 Filed 06/22/22 Page 9 of 55

This culture of silence provided space for the defendant and Epstein to operate a playbook
through which they sexually abused young girls. At trial, Dr. Lisa Rocchio, an expert in
psychology with a specialized expertise in traumatic stress and interpersonal violence, explained
that children are most frequently sexually abused through grooming and coercion in the context of
a relationship. (Tr. 713). Dr. Rocchio explained that abusers use a series of deceptive tactics to
engage a child in sexual abuse. (Tr. 715-20). The defendant and Epstein used such tactics
throughout the life of the conspiracy. In the early phase of the conspiracy, from at least
approximately 1994 through approximately 2001, the defendant identified vulnerable girls,
typically from single-mother households and difficult financial circumstances. (PSR ¶ 26). The
defendant and Epstein then isolated the girls, spending time with them away from their family and
friends. (Id.). During that time, they groomed the girls through techniques such as giving them
gifts, pretending to be friends, and building trust. (Id.). The defendant and Epstein then
normalized sexual situations and sexual touching. (Id.). Finally, they transitioned to sexual abuse,
often through the pretext of giving Epstein a massage. (Id.). This earlier phase required the
defendant and Epstein to identify one girl at a time to target for grooming and abuse.

In the later phase, from approximately 2001 until at least approximately 2004, the
defendant and Epstein developed a scheme that created a constant stream of girls who recruited
each other to visit Epstein at his Palm Beach residence. (PSR ¶ 27). This new approach replaced
some of the early grooming and trust-building steps with money provided to girls from struggling
families. (Id.). Specifically, the defendant and Epstein paid young girls hundreds of dollars in
cash in exchange for meeting Epstein to be sexually abused—again, often under the pretext of
giving Epstein a massage. (Id.). Once a girl was introduced to these sexualized massages, she
was offered more money if she brought other teenage girls to engage in sexualized massages with

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