Evidence Overview and Prosecution Roadmap

The Epstein archive contains extensive evidence of systematic sex trafficking, conspiracy, obstruction of justice, and financial crimes spanning more than two decades. This article provides a comprehensive overview of the evidentiary record for potential prosecutions, organized by federal criminal statute, with particular focus on evidence against co-conspirators who have never been charged. While Jeffrey Epstein died by suicide on August 10, 2019 while awaiting trial, and only Ghislaine Maxwell has been prosecuted among his co-conspirators, the archive documents potential criminal liability for numerous other individuals under federal trafficking, conspiracy, obstruction, and financial crime statutes detailed in the Relevant Criminal Statutes page.

Summary of the Evidentiary Landscape#

The archive contains three primary categories of prosecutable evidence:

Sex Trafficking and Conspiracy Evidence: The 2019 federal indictment charged Epstein with conspiring to sexually traffic "dozens of minor girls" between 2002 and 2005, though victim complaints document abuse beginning as early as 1998. The FBI's August 2019 co-conspirator memo identified exactly 10 individuals actively tracked for potential prosecution, with detailed evidence of their roles in facilitating the operation. The 2007 Non-Prosecution Agreement documented 34 confirmed minor victims, though the actual number is likely far higher.

Obstruction of Justice Evidence: The archive contains extensive documentation of systematic obstruction, including evidence destruction, witness intimidation through private investigators, and concealment of the Non-Prosecution Agreement from victims in violation of the Crime Victims' Rights Act. An August 2019 FBI memo documents that Sarah Kellen "instructed staff to remove evidence from Epstein's residence and provide it to a private investigator" and "instructed staff to remove massage-related phone books from the USVI home and shred them" during the active 2005-2006 investigation.

Financial Crimes Evidence: While less extensively documented in the public archive, civil litigation by the U.S. Virgin Islands and shareholder derivative suits against JPMorgan Chase have revealed evidence of potential money laundering, structuring of cash payments to victims, and use of shell companies to facilitate the trafficking operation.

Evidence by Criminal Statute#

Sex Trafficking of Minors (18 U.S.C. § 1591)

The core federal sex trafficking statute makes it a crime to "recruit, entice, harbor, transport, provide, obtain, or maintain by any means a person" knowing the person is under 18 and will be caused to engage in a commercial sex act. When the victim is under 18, no proof of force, fraud, or coercion is required. The statute carries penalties of 15 years to life when the victim is under 14 or force is used, and 10 years to life when the victim is 14-17.

Evidence of Epstein's Trafficking Operation: The 2019 indictment describes a systematic operation where Epstein "enticed and recruited, and caused to be enticed and recruited, dozens of minor girls" to his Manhattan townhouse and Palm Beach estate between 2002 and 2005. The indictment alleges Epstein "paid his victims hundreds of dollars in cash for each encounter" and "actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused," creating "a vast network of underage victims."

The indictment describes the abuse pattern: when victims arrived, they "would perform a massage on JEFFREY EPSTEIN, the defendant. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the 'massage.' During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victim's genitals."

Evidence of Co-Conspirator Roles: The FBI co-conspirator memo documents the specific roles of assistants in facilitating the operation:

• Sarah Kellen (Co-Conspirator #1): Multiple victims stated she "arranged massage appointments from New York City," "served as direct supervisor to other assistants, instructing them to set up appointments, conduct background research on girls, make follow-up calls, and tell girls to recruit more girls," and "paid them directly for 'massages,' sometimes providing transportation."

• Lesley Groff (Co-Conspirator #3): Multiple victims and cooperating co-conspirators stated she "worked out of Epstein's NYC residence as his personal assistant," "was in charge of making phone calls to set up massage appointments," "would coordinate with the main NYC victim listed in the indictment to schedule appointments," and "would call victims to ask if they had any new girls for Epstein."

• Ghislaine Maxwell: The FBI memo noted "at least one employee observed her recruit a victim in the case." Maxwell was convicted in December 2021 on five counts including sex trafficking of a minor and sentenced to 20 years in federal prison in June 2022.

Interstate Commerce Element: The indictment establishes the interstate commerce element required for federal jurisdiction by documenting that "Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-2 in Florida in order to schedule an appointment" and similar interstate calls for other victims. Epstein also "frequently traveled from New York to Palm Beach by private jet."

Sex Trafficking Conspiracy (18 U.S.C. § 1594)

This statute makes it a crime to conspire to violate § 1591, with the same penalties as the underlying offense. Conspiracy requires an agreement between two or more persons to commit the offense and an overt act in furtherance of the conspiracy.

Evidence of Conspiracy: The 2019 indictment Count One charged Epstein with conspiracy to commit sex trafficking of minors, alleging that "JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors."

The indictment lists numerous overt acts, including that "in or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-1 in order to schedule an appointment for Minor Victim-1 to engage in paid sex acts with EPSTEIN."

Unprosecuted Co-Conspirators: While Maxwell was convicted of conspiracy charges, the FBI identified 10 co-conspirators in August 2019, serving grand jury subpoenas and scheduling proffer sessions. However, aside from Maxwell, none have been prosecuted. The FBI memo explicitly categorized them as "primary" and "secondary" co-conspirators based on strength of evidence, suggesting prosecutable cases exist against multiple individuals.

Mann Act Violations (18 U.S.C. §§ 2421-2423)

The Mann Act criminalizes transporting individuals in interstate commerce for prostitution or illegal sexual activity. Section 2423(a) specifically criminalizes transporting a minor in interstate or foreign commerce for prostitution or unlawful sexual purposes, with penalties of 10 years to life.

Evidence of Interstate Transportation: Flight logs documented in the archive show extensive interstate and international travel on Epstein's private aircraft. The recruitment patterns documented in victim testimony show girls recruited in Florida were flown to New York, and vice versa. The 2019 indictment notes Epstein "frequently traveled from New York to Palm Beach by private jet, before which an employee or associate would ensure that minor victims were available for encounters upon his arrival in Florida."

Virgin Islands Jurisdiction: Epstein's Little St. James Island property in the U.S. Virgin Islands falls under federal maritime jurisdiction, making sexual abuse occurring there potentially prosecutable under 18 U.S.C. § 2243 (sexual abuse of a minor in special maritime and territorial jurisdiction). Civil litigation by the U.S. Virgin Islands Attorney General has documented extensive abuse at the island property.

Obstruction of Justice (18 U.S.C. §§ 1503, 1512, 1519)

The archive contains extensive evidence of obstruction, witness tampering, and document destruction, detailed comprehensively in the Obstruction of Justice Evidence page.

Document Destruction: The FBI co-conspirator memo documents that Sarah Kellen "instructed staff to remove massage-related phone books from the USVI home and shred them" during the 2005-2006 Palm Beach investigation. These phone books likely contained contact information for victims—precisely the type of evidence critical to building a trafficking case. This constitutes potential violations of 18 U.S.C. § 1512(c) (corruptly altering or destroying documents with intent to impair their use in an official proceeding) and § 1519 (destruction of records in federal investigations), each carrying up to 20 years imprisonment.

Witness Intimidation: Court documents from M.J. v. Epstein detail a July 2010 incident where a victim was subjected to systematic surveillance by a private investigator who followed her car, parked near her home, and "intermittently flashed his high beam lights into Jane Doe's home" and "intermittently attempted to videotape anyone inside the home." This occurred shortly before court-ordered mediation and violated a judge's explicit order against harassment. The investigator refused to identify who hired him, but court filings state "Jane Doe believed that this intimidation was being orchestrated by defendant Epstein."

During the FBI investigation, according to court documents, one victim received a message from another victim speaking on Epstein's behalf: "Those who help will be compensated and those who hurt will be dealt with." This explicit threat constitutes witness tampering under 18 U.S.C. § 1512(b), carrying up to 20 years imprisonment.

Concealment of the Non-Prosecution Agreement: The systematic concealment of the 2007 Non-Prosecution Agreement from victims, documented in internal prosecutorial emails, constitutes potential obstruction. On September 18, 2007, prosecutors assured defense counsel the NPA "would not be made public or filed with the Court." Defense counsel Jay Lefkowitz emailed September 24, 2007: "Please do whatever you can to keep this from becoming public." Prosecutors replied: "I don't anticipate it going any further... The other will be placed in the case file, which will be kept confidential."

On February 21, 2019, Judge Kenneth A. Marra ruled that prosecutors violated the Crime Victims' Rights Act: "The Government gave the Epstein defense team notice of the NPA and conferred with them throughout the process, yet purposefully withheld this information from the victims."

RICO Violations (18 U.S.C. § 1962)

The Racketeer Influenced and Corrupt Organizations Act criminalizes conducting the affairs of an enterprise through a pattern of racketeering activity. "Racketeering activity" under 18 U.S.C. § 1961 includes sex trafficking (§ 1591), witness tampering (§ 1512), and money laundering (§§ 1956-1957).

Evidence of an Enterprise: The operation described in the 2019 indictment and FBI co-conspirator memo constitutes an enterprise within the meaning of RICO: a structured organization with identified roles (recruiters, schedulers, assistants), operating across multiple states (New York, Florida, New Mexico, Virgin Islands), using systematic methods documented in recruitment patterns, and generating substantial financial proceeds through which victims were paid and co-conspirators compensated.

Pattern of Racketeering: The indictment alleges the operation ran from "at least in or about 2002, up to and including at least in or about 2005," and victim complaints document abuse from 1998, establishing a multi-year pattern. The predicate acts include multiple violations of § 1591 (sex trafficking), potential violations of § 1512 (witness tampering), and potential money laundering violations.

No RICO Charges Filed: Despite clear evidence supporting RICO charges—which would allow for asset forfeiture and increased penalties—neither the 2008 state prosecution nor the 2019 federal prosecution included RICO counts. This represents a significant missed opportunity, as RICO conspiracy (§ 1962(d)) requires no overt act and allows prosecution of anyone who agreed to participate in the enterprise's affairs through racketeering, even if they did not personally commit the predicate acts.

Money Laundering (18 U.S.C. §§ 1956, 1957)

These statutes criminalize conducting financial transactions involving proceeds of "specified unlawful activity" (which includes sex trafficking) to conceal the source or nature of the proceeds (§ 1956) or engaging in monetary transactions over $10,000 derived from specified unlawful activity (§ 1957).

Evidence of Financial Structure: The 2019 indictment documents systematic cash payments: "EPSTEIN paid his victims hundreds of dollars in cash for each encounter" and "EPSTEIN paid hundreds of dollars to victim-recruiters for each additional girl they brought." Civil complaints describe Epstein paying "$300" to victims and "$200 for bringing Plaintiff to him" to recruiters.

JPMorgan Banking Relationship: Shareholder derivative litigation against JPMorgan Chase has revealed that the bank maintained Epstein's accounts despite suspicious activity. A January 2014 Department of Justice non-prosecution agreement with JPMorgan (unrelated to Epstein) required the bank to enhance anti-money laundering controls, suggesting systemic compliance failures during the period when Epstein was a client. Civil plaintiffs have alleged JPMorgan facilitated Epstein's trafficking operation by processing payments to victims and co-conspirators.

Use of Shell Companies: The archive documents Epstein's use of numerous corporate entities including Southern Trust Company, which held substantial assets. The U.S. Virgin Islands lawsuit alleges these entities were used to conceal the source and nature of funds derived from the trafficking operation.

Witness Tampering (18 U.S.C. § 1512)

Beyond the obstruction evidence discussed above, the archive contains specific evidence of witness tampering during the federal investigation and subsequent civil litigation.

Intimidation of Co-Conspirators: Court documents state that "during the FBI investigation of his sexual abuse of young girls, Epstein intimidated and harassed other possible witnesses against him—namely Sarah Kellen, Leslie Groff and Nadia Marcinkova. Indeed, this intimidation was so serious that federal prosecutors prepared draft federal charges against him for witness tampering charges." However, "for reasons that are unclear, these charges were not filed."

Pattern of Investigator Harassment: Civil litigation documents describe a pattern where "investigators have in the past aggressively followed key witnesses to intimidate and scare them." One victim testified that in the 48 hours before the July 2010 surveillance incident, "she had received telephone calls from two ex-boyfriends that investigators were at their homes, knocking on their doors and trying to talk to them about Jane Doe—apparently because of this case."

"Accidental" Encounters: During civil depositions, court filings document that "Epstein intentionally crossed paths with the victim and stared her down as an attempt to intimidate her," occurring "despite the court's elaborate procedures to prevent these encounters and irrespective of the various court orders in place warning Epstein against this behavior."

Key Evidence Chains#

The Recruitment Pyramid Structure

The most powerful evidence of conspiracy involves the pyramid recruitment structure documented across multiple sources:

1. Initial Recruitment: Victim complaints describe girls recruited with promises of legitimate massage work and substantial pay, often by other victims who had been recruited previously.

2. Deceptive Pretenses: The 2019 indictment describes victims initially recruited to provide "massages" that "would become increasingly sexual in nature."

3. Transformation into Recruiters: The indictment states Epstein "actively encouraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEIN incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought to EPSTEIN."

4. Network Growth: The indictment alleges "certain recruiters brought dozens of additional minor girls to the New York Residence" and through this system "EPSTEIN gained access to and was able to abuse dozens of additional minor girls."

This pyramid structure establishes conspiracy liability not only for Epstein but for any co-conspirators who facilitated the recruitment system. The FBI co-conspirator memo identifies specific individuals whose roles in coordinating this system are documented through victim testimony.

The Scheduling and Coordination Evidence

Phone records and testimony documented in the FBI memo establish a systematic scheduling operation:

1. Advance Coordination: The 2019 indictment states "EPSTEIN, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN'S travel to Florida to ensure appointments were scheduled for when he arrived."

2. Interstate Calls: The indictment establishes federal jurisdiction through interstate phone calls: "Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-2 in Florida in order to schedule an appointment."

3. Employee Roles: The FBI memo documents that Lesley Groff "would coordinate with the main NYC victim listed in the indictment to schedule appointments and relay information to Epstein" and Sarah Kellen "served as direct supervisor to other assistants, instructing them to set up appointments."

This scheduling evidence establishes that assistants were not merely employees performing legitimate work but active participants in the trafficking conspiracy who knowingly facilitated the sexual abuse of minors.

The Cash Payment Trail

While the archive contains limited direct financial records (many likely destroyed during obstruction efforts), the pattern of cash payments is established through:

1. Victim Testimony: The 2019 indictment repeatedly states victims "typically were paid hundreds of dollars in cash for each encounter."

2. Structured Payment System: Civil complaints document specific amounts: "$300" to victims and "$200" to recruiters, suggesting a standardized payment structure.

3. Assistant Involvement: The FBI memo states Sarah Kellen and Lesley Groff "sometimes paid the victims directly," establishing co-conspirator participation in the financial aspects of the operation.

The systematic use of cash rather than checks or wire transfers suggests consciousness of criminality and efforts to avoid creating traceable financial records—evidence relevant to money laundering charges.

The Interstate Transportation Network

Flight logs and property records establish Epstein's ability to transport victims across state and international lines:

1. Multiple Properties: Epstein maintained residences in Manhattan, Palm Beach, New Mexico, Paris, and the U.S. Virgin Islands.

2. Private Aircraft: Flight logs document extensive use of private jets to travel between properties, often with passengers whose ages and identities raise questions.

3. Victim Transportation: The 2019 indictment documents that Epstein "frequently traveled from New York to Palm Beach by private jet" and arranged for victims to be available upon arrival. Victim testimony describes being flown to various properties.

This transportation network establishes jurisdiction under the Mann Act and demonstrates the interstate nature of the conspiracy.

Strongest Cases for Prosecution#

Based on the archive evidence, the strongest potential prosecutions involve:

Sarah Kellen (Co-Conspirator #1)

Strength of Evidence: The FBI memo documents Kellen's role through "multiple victims and cooperating co-conspirators," including that she:

• Arranged massage appointments and supervised other assistants
• Instructed them to "set up appointments, conduct background research on girls, make follow-up calls, and tell girls to recruit more girls"
• Paid victims directly
• Instructed staff to remove evidence and shred documents during the investigation

Applicable Charges:

• Conspiracy to commit sex trafficking (18 U.S.C. § 1594)
• Obstruction of justice (18 U.S.C. § 1512(c)) for evidence destruction
• Witness tampering (18 U.S.C. § 1512(b))

Obstacles to Prosecution: The 2007 Non-Prosecution Agreement explicitly granted immunity to "Sarah Kellen" among others. However, the U.S. Attorney's Office for the Southern District of New York took the position it was not bound by the Florida NPA, as demonstrated by Maxwell's prosecution. Additionally, obstruction charges for acts committed during or after the NPA was signed would not be covered by its immunity provisions.

Current Status: Kellen, who married NASCAR driver Brian Vickers and changed her name to Sarah Kensington, has not been charged. A federal judge ruled in 2022 that she was "criminally responsible" for Epstein's sex trafficking but no prosecution has followed.

Lesley Groff (Co-Conspirator #3)

Strength of Evidence: The FBI memo documents through "multiple victims and cooperating co-conspirators" that Groff:

• Worked as Epstein's executive assistant coordinating schedules
• "Was in charge of making phone calls to set up massage appointments"
• "Would coordinate with the main NYC victim listed in the indictment to schedule appointments"
• "Would call victims to ask if they had any new girls for Epstein"
• Sometimes paid victims directly

Applicable Charges:

• Conspiracy to commit sex trafficking (18 U.S.C. § 1594)
• Aiding and abetting sex trafficking (18 U.S.C. § 2)

Obstacles to Prosecution: The NPA granted immunity to "Lesley Groff" by name. However, the same jurisdictional argument that allowed Maxwell's prosecution could apply.

Current Status: Groff has denied knowledge of Epstein's criminal activities and has not been charged. Her attorney stated she voluntarily spoke with prosecutors and was told she was not being prosecuted.

Jean-Luc Brunel (Deceased)

Strength of Evidence: The FBI memo identified Brunel as owner of MC2 Model Management, which Epstein financed with at least $1 million in 2005. Multiple victims testified Brunel helped recruit girls through the modeling industry.

Status: Brunel was arrested in Paris in December 2020 on charges of rape of minors and trafficking. He was found dead in his Paris prison cell on February 19, 2022, in what French authorities determined was suicide.

Leslie Wexner (Co-Conspirator #8)

Strength of Evidence: The less-redacted FBI memo identifies Wexner, billionaire founder of L Brands, as residing in Ohio. The memo states "there is limited evidence regarding his involvement," suggesting the FBI assessed but did not develop a strong case.

However, circumstantial evidence includes:

• Wexner was Epstein's primary client and financial manager from 1987-2007
• Epstein acquired the Manhattan townhouse central to the trafficking operation through a murky transaction with Wexner
• Victim Virginia Giuffre named Wexner as one of the men she was trafficked to
• An undated draft message from Epstein to Wexner discusses their involvement in "gang stuff" for over 15 years

Obstacles to Prosecution: Wexner's legal representative stated prosecutors informed him he was "neither a co-conspirator nor target." Wexner has claimed Epstein "stole or misappropriated several hundred million dollars" from him, positioning himself as a victim rather than co-conspirator.

Current Status: No charges have been filed. In 2025, the House Oversight Committee issued subpoenas to Wexner and Epstein's estate executors for documents related to the trafficking operation.

Evidence Gaps and Areas Needing Further Investigation#

Destroyed or Concealed Financial Records

The obstruction evidence documenting destruction of "massage-related phone books" and removal of evidence suggests substantial financial records were destroyed. Further investigation should focus on:

1. Bank Records: Subpoenas to all financial institutions that held Epstein accounts, including offshore banks and the entities documented in JPMorgan litigation.

2. Shell Company Documents: Full corporate records for all entities associated with Epstein, including Southern Trust Company and others identified in the U.S. Virgin Islands lawsuit.

3. Cash Withdrawal Records: Analysis of patterns of large cash withdrawals that would correspond to the hundreds of dollars paid to victims.

Unidentified Victims and Witnesses

The 2007 NPA documented 34 confirmed minor victims, but the 2019 indictment alleges "dozens" and civil complaints reference "countless" victims. Many victims have never been identified or interviewed. The Victim References page documents known victim accounts, but substantial gaps remain.

Needed Investigation:

• Systematic outreach to potential victims through public appeals and victim advocates
• Analysis of phone records and flight logs to identify additional potential victims
• Interviews with former employees who may have witnessed abuse but were not involved

International Trafficking Evidence

The archive contains limited evidence about Epstein's international properties and activities, particularly:

1. Paris Apartment: The Paris apartment property is documented but evidence of trafficking occurring there is limited in the public archive.

2. Other International Travel: Flight logs show extensive international travel, but victim testimony about abuse occurring in foreign countries is limited in the public record.

3. Foreign Co-Conspirators: Jean-Luc Brunel was the only non-U.S. co-conspirator identified, but the international nature of the operation suggests others may exist.

Co-Conspirator Communications

The archive contains limited email or text message communications between Epstein and his co-conspirators about the trafficking operation. The obstruction evidence suggests such communications existed but were destroyed. Further investigation should include:

1. Forensic Recovery: Examination of seized electronic devices for deleted communications
2. Third-Party Records: Subpoenas to communications providers for message records
3. Co-Conspirator Devices: Seizure and examination of devices belonging to identified co-conspirators

The NPA Negotiation Process

While the obstruction evidence and Non-Prosecution Agreement pages document some of the concealment of the NPA from victims, substantial questions remain about:

1. Who Made the Decision: The DOJ OPR report examined prosecutors' conduct but questions remain about involvement of senior DOJ officials
2. Defense Team Communications: The full scope of coordination between prosecutors and Epstein's defense team
3. Pressure on Prosecutors: Whether external pressure influenced prosecutorial decision-making

Post-2008 Trafficking Activity

The 2019 indictment charged offenses through 2005, and Epstein was incarcerated from June 2008 to July 2009. However:

1. Post-Release Activity: Evidence of whether trafficking resumed after Epstein's 2009 release from jail
2. Zorro Ranch: The New Mexico property is documented in the archive but evidence of when and how it was used for trafficking is limited
3. 2010s Activity: Whether the operation continued in the 2010s, potentially with different methods to avoid detection

Status of Current Investigations#

Federal Criminal Investigation (Ongoing)

Following Epstein's death in August 2019, the federal criminal investigation continued, resulting in:

1. Maxwell Prosecution: Ghislaine Maxwell was indicted in July 2020, convicted in December 2021, and sentenced to 20 years in June 2022. Her appeal was denied by the Second Circuit in September 2024, and she petitioned the Supreme Court for review.

2. Co-Conspirator Investigation: The FBI's August 2019 memo documented 10 identified co-conspirators with active grand jury subpoenas and scheduled proffer sessions. However, no additional indictments have been announced as of this writing.

3. Prison Guards: Two guards on duty the night Epstein died, Tova Noel and Michael Thomas, were charged with falsifying records but entered into a deferred prosecution agreement in 2022.

Civil Litigation

Numerous civil cases remain ongoing or have been settled:

1. Victim Compensation Fund: After Epstein's death, a Victim Compensation Program was established, ultimately paying more than $121 million to over 135 claimants.

2. JPMorgan Chase Settlement: The bank paid $290 million to settle the U.S. Virgin Islands lawsuit alleging it facilitated Epstein's trafficking.

3. Deutsche Bank Settlement: Deutsche Bank paid $75 million to settle similar allegations.

4. Ongoing Litigation: Multiple victim lawsuits against Epstein's estate and alleged co-conspirators remain active in federal and territorial courts.

Congressional Oversight

The House Oversight Committee has conducted ongoing investigation, including:

1. 2025 Subpoenas: In July 2025, subpoenas were issued to Leslie Wexner, Darren Indyke, and Richard Kahn for documents related to the trafficking operation.

2. Document Releases: The Committee has facilitated public release of thousands of pages from the Epstein archive.

3. Ongoing Hearings: Committee members have indicated additional hearings and document releases are planned.

Grand Jury Proceedings

In July 2025, the Department of Justice filed motions to unseal grand jury transcripts from both the 2006-2008 Florida federal investigation and the 2019 New York federal investigation. These filings indicate continued DOJ interest in transparency regarding the investigations, though they do not necessarily indicate ongoing criminal investigations.

Recommendations for Investigators#

Based on the evidence documented in the archive, investigators and prosecutors should prioritize:

1. Prosecute Documented Obstruction Offenses

The obstruction evidence is strong and well-documented. Sarah Kellen's instruction to staff to "remove evidence" and "shred" documents during an active investigation constitutes clear obstruction under 18 U.S.C. § 1512(c) and § 1519. These charges:

• Carry 20-year maximum sentences
• Are not covered by the NPA's immunity provisions (obstruction during the investigation postdates any immunity agreement)
• Could provide leverage to obtain cooperation against other co-conspirators
• Would send a clear message that evidence destruction will be prosecuted

2. Reassess NPA Immunity Arguments

While the 2007 NPA granted immunity to named co-conspirators, the successful prosecution of Maxwell demonstrates this immunity is not absolute. The Southern District of New York took the position it was not bound by a Florida district agreement. Moreover:

• Post-NPA obstruction is not covered by immunity
• Testimony obtained from immunized co-conspirators during the 2006-2008 investigation could be used against them for subsequent crimes
• Civil litigation has established that "named" co-conspirators can be found "criminally responsible" even if not prosecuted

3. Focus on Financial Crimes

Money laundering and structuring charges (18 U.S.C. §§ 1956, 1957, 31 U.S.C. § 5324) may be easier to prove than trafficking conspiracy for certain co-conspirators who were primarily involved in the financial aspects of the operation. These charges:

• Require proof only that the defendant conducted financial transactions involving proceeds of "specified unlawful activity"
• Can be established through bank records even without victim testimony
• Carry significant penalties (up to 20 years for money laundering)
• Allow for asset forfeiture

4. Develop RICO Case

The evidence clearly establishes an "enterprise" within the meaning of RICO (18 U.S.C. § 1962), with:

• A defined structure (Epstein, assistants, recruiters, victims)
• Continuity over many years (at least 1998-2019)
• Multiple predicate acts (sex trafficking, witness tampering, money laundering)
• Interstate and international operations

A RICO prosecution would allow:

• Charging defendants who agreed to participate in the enterprise even if they didn't personally commit all predicate acts
• Civil forfeiture of assets
• Enhanced penalties (up to 20 years, or life if predicate acts carry life)
• Prosecution of the ongoing criminal enterprise rather than isolated incidents

5. Pursue Co-Conspirator Cooperation

The FBI memo documents that several identified co-conspirators "cooperated" or had "proffer" sessions scheduled in 2019. These individuals should be re-engaged with offers of:

• Limited immunity for testimony against higher-level participants
• Reduced sentences in exchange for cooperation
• Protection from the extensive witness intimidation documented in the obstruction evidence

6. Investigate Financial Institutions

The JPMorgan civil settlements suggest the bank had knowledge of suspicious activity. Criminal investigation should examine:

• Whether bank employees violated anti-money laundering statutes (31 U.S.C. § 5322)
• Whether bank officers made false statements in suspicious activity reports
• Whether the bank failed to file required currency transaction reports
• Whether individual bankers received personal benefits for maintaining the accounts

7. International Cooperation

Jean-Luc Brunel's arrest in France demonstrates international willingness to prosecute Epstein-related crimes. U.S. authorities should:

• Issue Red Notices through Interpol for any co-conspirators believed to be abroad
• Provide mutual legal assistance to foreign jurisdictions investigating Epstein-related crimes
• Seek extradition where appropriate under existing treaties
• Share evidence with foreign prosecutors who have jurisdiction over abuse in their countries

8. Grand Jury Subpoenas for Co-Conspirators

The FBI memo documents that grand jury subpoenas were issued to identified co-conspirators in July-August 2019. If those grand jury proceedings remain active, additional subpoenas should be issued for:

• Complete financial records of all identified co-conspirators
• Communications records (emails, texts, phone records)
• Travel records coordinating with victim travel
• Employee records from Epstein's various entities

9. Systematic Victim Outreach

The identification of only 34 confirmed victims when the indictment alleges "dozens" suggests many victims remain unidentified. A systematic outreach program should include:

• Public service announcements in areas where recruitment occurred (Palm Beach County, Manhattan)
• Victim advocate assistance in identifying and supporting potential victims
• Immunity from minor charges (prostitution) that might deter victims from coming forward
• Compensation through the existing victim fund even if victims do not wish to testify

10. Document Forensic Analysis

The obstruction evidence documents systematic destruction of "phone books" and other records. However, modern forensic techniques may recover:

• Deleted electronic communications from seized devices
• Reconstructed financial records from fragments
• Metadata showing when documents were deleted (establishing obstruction timeline)
• Third-party copies of destroyed documents (emails sent to co-conspirators, cloud backups)

See Also#

• Epstein's Co-Conspirators - Detailed profiles of the 10 FBI-identified co-conspirators
• Obstruction of Justice Evidence - Comprehensive documentation of obstruction activities
• Relevant Criminal Statutes - Full text and analysis of applicable federal criminal laws
• 2007 Non-Prosecution Agreement - The controversial immunity deal and its aftermath
• Victim References in the Archive - Documentation of victim accounts and testimony
• Recruitment and Trafficking Patterns - Systematic analysis of how the operation functioned
• JPMorgan Chase Banking Relationship - Financial institution facilitation of the operation
• Flight Logs and Travel Evidence - Interstate and international transportation documentation