DOJ-OGR-00000478.jpg

Case 1:19-cr-00490-RMB Document 32 Filed 07/18/19 Page 7 of 33

C. Indictment

A grand jury voted to indict Mr. Epstein on or about July 2, 2019. The Indictment
charges Mr. Epstein with two felonies involving minor girls some as young as 14. Count I
includes conspiracy to commit sex trafficking of minor girls, in violation of 18 U.S.C. § 371, and
Count II includes sex trafficking of minor girls, in violation of 18 U.S.C. § 1591. It states:
“[F]rom at least in or about 2002, up to and including at least in or about 2005, Jeffrey Epstein, .
. . enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion
in Manhattan, New York . . . and his estate in Palm Beach, Florida, . . . to engage in sex acts with
him, after which he would give the victims hundreds of dollars in cash.” Indictment, dated July
2, 2019 (“Indictment”), ¶ 2. “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 this way, Epstein created a vast network of underage victims for him to sexually
exploit in locations including New York and Palm Beach.” Id.

The Indictment also charges that “the victims . . . were as young as 14 years old at the
time they were abused by [Mr. Epstein] . . . and were, for various reasons, often particularly
vulnerable to exploitation.” Id. ¶ 3. “Mr. Epstein intentionally sought out minors and knew that
many of his victims were in fact under the age of 18, [] because, in some instances, minor
victims expressly told him their age.” Id.

Following his arrest, on Monday, July 8, 2019, Mr. Epstein was arraigned and presented
with the Indictment by Magistrate Judge Henry Pittman.

D. Legal Principles Governing Release Versus Remand

Under the Bail Reform Act, 18 U.S.C. § 3142, a Court can order a defendant’s detention
if it determines that the defendant is either (1) a danger to the community or (2) a risk of flight.

7

DOJ-OGR-00000478