UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08-80736-CIV-MARRA
JANE DOE #1 and JANE DOE #2,
Petitioners,
vs.
UNITED STATES OF AMERICA,
Respondent.
_______________________________/
scribd.com/doc/267173868/…
1. My name is Virginia Roberts and I was born in August, 1983.
2. I am currently 31 years old.
3. I grew up in Palm Beach, Florida. When I was little, I loved animals and wanted
to be a veterinarian. But my life took a very different turn when
4. In approximately 1999, when I was 15 years old, I met Ghislaine Maxwell. She is the daughter of Robert Maxwell, who had been a wealthy publisher in Britain. Maxwell asked that I come with her to Jeffrey Epstein’s mansion
5. From the first time I was taken to Epstein’s mansion that day, his motivations and actions were
6. I came back for several days following and did the same sorts of sexual things for Epstein.
7. After I did those things for Epstein, he and Maxwell said they were going to have me travel and were going
8. So I started “working”
luxurious room. The mansion was huge. I got scared because it was so big. Epstein brought me to a room with a massage parlor.
9. You can see how young I looked in the photograph below.(bottom photo captioned age 15-16)
10. Epstein took me on a ferry boat on one of the trips to NYC
telegraph.co.uk/news/uknews/th…
11. Over the next few weeks, Jeffrey Epstein and Ghislaine Maxwell trained me to do what they wanted, including sexual activities and the use of sexual toys. The training was in New York
12. I was trained to be “everything a man wanted me to be.” It wasn’t just sexual training - they wanted me to be able to cater to all
13. Epstein and Maxwell also told me that they wanted me to produce things for them in addition to performing sex on the men. They told
14. From very early on I was fearful of Epstein. Epstein told me he was a billionaire. I told my mother that I was working for this rich guy, and she said “go, go far away.”
15. I visited and traveled
like mansions) in locations including New York City, New York; the area of Santa Fe, New Mexico; Palm Beach, Florida; an
with. Epstein paid me for many of these sexual encounters. In fact, my only purpose for Epstein, Maxwell and their friends
16. To illustrate my connection to these places, I include four photographs taken of me in New Mexico (shown below). The first one is a museum in Santa Fe, New Mexico. We had gone sightseeing for the day. Epstein took this picture of me. I was
17. When I was with him
18. Epstein’s code word for sexual encounters was that it was a “massage”. At times the interaction between Epstein and the girls would start in a massage room setting, it was always a sexual encounter and never just a massage.
19. In addition to constantly
someone was in his pocket, they owed him favors. I also understood that Epstein thought he could get leniency if he was ever caught doing anything illegal, or more so that he could escape trouble altogether.
20. Ghislaine Maxwell was heavily involved in the illegal sex. I understood her to be a very powerful person. She used Epstein’s money and he used her name and connections to gain power and prestige.
21. One way to describe Maxwell’s role was as the “madame.” She assumed a
22. I first had sexual
various residences plus other exotic locations.I had sex with Maxwell in the Virgin Islands, New Mexico, New York, as well
23. Maxwell took pictures of many of the underage girls. These pictures were
sexually explicit. Maxwell kept the pictures on the computers in the various houses. She also made
24. Harvard law
25. I had sexual intercourse with Dershowitz at least six times.
27. The second time that I had sex with Dershowitz was at Epstein’s house in Palm Beach. During this encounter, Dershowitz instructed me to both perform oral sex and have sexual intercourse.
28. I also had sex with
29. We also had sex at Little Saint James Island in the U.S. Virgin Islands. I was
asked to give Dershowitz a massage on the beach. Dershowitz
30. Another sexual encounter between me and Dershowitz happened on Epstein’s airplane. Another girl was present on the plane with us.
31. I have recently seen a former Harvard law
32. Epstein made me have sex with Prince Andrew several times. Prince Andrew, Maxwell,
33. One day when I was in London (specifically in a townhouse that is under
Maxwell’s name), I got news
Epstein told me I was meeting a “major prince.” Epstein told me “to exceed” everything I had been taught. He emphasized that whatever Prince Andrew wanted, I was to make sure he got.
34. Eventually Prince Andrew
inside alone with Andy. I was introduced to the Prince, and we kissed formally, cheek to cheek. There was a lot of legal
turned to me.Maxwell said “guess how old she is.” Prince Andrew guessed 17.
35. Then we all went to a Chinese restaurant for dinner & then to Club Tramp, a fancy “members only” night club in central London.
that night. Andy traveled in a separate car with
36. We all arrived back at the townhome and went upstairs. Epstein took a picture of me and Andy with my own camera. The picture above is that picture, which has been widely circulated on the internet. Andy has his left arm around my waist and is smiling.
37. I wanted a picture with the prince because I was keeping in contact with my
family. I had told my mom and my grandma that I was meeting
38. After the picture, Epstein and Maxwell kissed me and said to “have fun.” They left Andy and me alone upstairs. We went to the bathroom and bedroom, which were just steps away from where the
39. I chatted with Epstein about this the next day. I told him, “it went great.” Epstein said something to the effect of, “You did well. The Prince had fun.” I felt
40. When I got back from my trip, Epstein paid me more than he had paid me to be with anyone else – approximately $15,000. That money was for what I had done and to keep my mouth shut about “working” with the Prince.
41. The second time I had sex with Prince Andrew was in
42. I had the impression that Andy had come there to see Epstein and to have sex me with. There was no other apparent purpose for Andy to be there.
43. I was told to go upstairs with Andy and to go to the room I thought of as the “dungeon” (the massage room, but it is
44. The third time I had sex with Andy was in an orgy on Epstein’s private island in the US Virgin Islands. I was around 18 at the time. Epstein, Andy,
communicate, saying that they are the “easiest” girls to get
45. Afterwards we all had dinner by the cabanas. The other girls were chatting away
46. I have seen Buckingham Palace’s
hoping that he would simply voluntarily tell the
47. I also had sexual intercourse with Jean Luc Brunel many times when I was 16 through 19 years old. He was another of Epstein’s powerful
(& Maxwell’s) strong appetite for sex with minors.
48. Brunel ran some kind of modeling agency and appeared to have an arrangement with the U.S. Government where he could get passports or other travel documents for young girls. He would then bring these young girls (girls ranging in age from 12 to 24) to the United States
49. Brunel would offer the girls “modeling” jobs. A lot of the girls came from poor countries or poor backgrounds, and he lured them in with a promise of making good money.
50. I had to have sex with
51. Jeffrey Epstein has told me that he has slept with over 1,000 of Brunel’s girls, and everything that I have
52. In addition to Ghislaine Maxwell, Sarah Kellen, and NAME REDACTED were also involved in the orgies. At this stage I am hopeful that these other women will come forward and tell the truth about
53. I have seen reports saying or implying that I had sex with former President Bill Clinton on Little Saint James Island. Former President Bill Clinton was present on the Island at a time when I was also
54. I now understand that Epstein reached a non-prosecution agreement with the federal
55. On September 3, 2008, the FBI sent a victim notification letter to me. This was the first written communication I had received from the FBI. The letter is attached as Exhibit I. The letter describes an agreement in which compensation would be made victims of Epstein’s
56. In 2011, two FBI agents, called me in Australia and then came to meet me. They met me at the U.S.
57. The agents were mainly focused on Epstein but while there I provided them some information
58. Epstein also
59. I will continue to cooperate fully in the investigation and prosecution of Epstein, Maxwell, or any of their friends who participated in the sexual abuse of minors. I also hope that this information is treated in a way that will keep me safe from
60. In
61. I have directed my attorneys, Bradley J. Edwards and Paul G. Cassell, to pursue all reasonable and legitimate means to
62. Since I filed my motion in this case, my credibility has been attacked. I am telling the truth and
63. I declare under penalty of perjury that the foregoing is true and correct.
Executed this 19th day of January, 2015.
SIGNATURE REDACTED