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Oct 03, 2025
Last updated Oct 28, 2025
Main > Our Blog > Does the Epstein ‘Client List’ Exist? What the DOJ Memo Really Says
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Rumors have circulated for decades that Jeffrey Epstein befriended powerful men — and that these friendships may have taken dark or even illegal forms. Epstein’s “friends” may have engaged in or benefited from sex trafficking and the sexual abuse of women and minors. Some may have been victimized themselves, facing blackmail for their embarrassing or illegal deeds.

However, much of this is mere speculation. Since the allegations against Epstein have come to light, no one, including his long-time associate and alleged girlfriend, Ghislaine Maxwell, has willingly admitted to taking part in his criminal activities. 

Thus, proving who may have acted as Epstein’s accomplices or clients rests on the written documents held by the U.S. Department of Justice (DOJ), the Federal Bureau of Investigation (FBI), and Epstein’s estate.

Key Takeaways

  • Most recently, the U.S. government has stating that it does not possess such a list.
  • However, if the list exists, it could help establish the narrative about which of Epstein’s associates sexually assaulted the women and underage girls trafficked by him.
  • This list might include the names of people who paid Epstein, traded favors, or just hung around him in exchange for access to the victims of Epstein’s trafficking operation.

What Is the Epstein Client List?

No one knows if a Jeffrey Epstein client list exists. Most recently, the U.S. government has responded to the question, “Where is the Jeffrey Epstein client list?” by stating that it does not possess such a list.

However, if the list exists, it could help establish the narrative about which of Epstein’s associates sexually assaulted the women and underage girls trafficked by him. Specifically, this list might include the names of people who paid Epstein, traded favors, or just hung around him in exchange for access to the victims of Epstein’s trafficking operation.

Relevance of the Epstein Client List

If it exists, the client list would be hugely embarrassing to anyone who appears in it. It might also provide leads for lawyers fighting for the survivors of Epstein and his associates’ harmful actions.

While many famous people allegedly took part in Epstein’s illegal activities and committed crimes themselves, other names and faces may not be less recognizable. A list could help survivors identify those who harmed them and, thus, hold them to account through the legal system.

Moreover, the list might point to additional evidence against Epstein and his associates. It could include contact information and dates of visits to Epstein’s island or other properties. It may even include more salacious details that bad actors could use to blackmail the people listed.

justice for Epstein Victims Compensation

Could the Epstein Client List Be Used as Evidence?

Suppose that the client list is eventually uncovered. Could law firms like Edwards Henderson use the list in court to prove a connection between Epstein and the alleged abusers on the list?

The biggest hurdle to using the list in court is a legal doctrine called hearsay. Generally, out-of-court writings cannot be used to prove the truth of the facts written. For example, the appearance of someone’s name on the client list would probably not be admissible as proof that they were a client.

Another obstacle would arise when authenticating the list. Authentication involves a lawyer establishing the origin of a document and its chain of custody. The purpose of authenticating a document is to prove that it is what it purports to be and that it has not been altered, and since Epstein died by suicide and his associate Maxwell is incarcerated, there might be no credible way to authenticate any list that may be uncovered.

Finally, the probative value of the list would need to outweigh its potential prejudicial effect. Unfortunately, inclusion on a list might imply that someone was a client, but it is not conclusive proof. Instead, a survivor’s sexual abuse attorney would likely focus on presenting witness testimony that placed the alleged client on Epstein’s property while committing a rape or other criminal act.

Using the Epstein Client List in Litigation Against Abusers

Even though a potential client list might be inadmissible in court, its usefulness goes beyond its role as evidence at trial. Investigators can use the names on the list to build stronger cases. Airplane passenger lists, emails, texts, phone records, and eyewitness testimony could help them find the truth of what happened.

Additionally, the list, as well as any notes contained in it, can help our attorneys prepare deposition questions for any abusers listed. Depositions operate under much looser rules than courtroom testimony. We may be able to get valuable information out of witnesses that constitutes or leads to admissible evidence.

Who Is on Epstein’s Client List?

If the question “Has the Epstein client list been released?” is ever answered with a “Yes,” the next question will be obvious: “Who is on Epstein’s client list?” 

While there has been no Epstein client list unsealed by the courts or the DOJ, the following names have appeared in other documents involving Epstein:

  • Elon Musk
  • Prince Andrew, Duke of York
  • Bill Gates
  • Steve Bannon
  • Peter Thiel

These names appear in flight manifests and calendars. Since the government has not released a client list, however, it cannot be confirmed who might appear on it. Moreover, it would be irresponsible to speculate about who might be on such a client list.

Contact Lists and the Role of the Client List

It may be possible to make educated guesses about what a client list may or may not include. First, as a wealthy money manager, Epstein likely had a list of financial customers for whom he managed investments. The client list sought by the public and survivors of Epstein’s acts is different from any legitimate list of customers who interacted with Epstein only in his professional capacity.

Second, Epstein’s wealth allowed him to access social circles with other wealthy or politically powerful people. He has been photographed with Donald Trump, Bill Clinton, Fidel Castro, Pope John Paul II, Mick Jagger, and Stephen Hawking. He likely maintained a Rolodex containing contact information for friends and acquaintances. 

Again, the client list pursued by claimants against the Epstein estate, investigators, and the public is different from the phone list for contacts who may have only interacted with Epstein socially. Instead, the speculated-about client list would focus on the people Epstein trusted with knowledge of his secret life as a trafficker of women and underage girls. The people appearing on the list would be suspected of exploiting the trafficked survivors by raping, assaulting, and abusing them.

Credible Evidence from Survivors’ Testimony

The credible testimony of survivors offers ample evidence that these people exist. In other words, survivors have expressly stated that Epstein was not the only abuser and that others were involved.

It is uncertain whether these people were true “clients” in the sense that they paid Epstein with money, favors, or information. The existence of any quid pro quo agreements between the alleged clients and Epstein is only speculation. It is possible that Epstein and these people simply shared an interest in sexually exploiting women and girls.

Alternatively, some believe that business relationships existed between these men and Epstein. He may have benefited from supplying women and girls to these men. Some speculate that Epstein supplied women and girls to gain evidence of wrongdoing that he could use for extortion; however, the DOJ states that there is no evidence that Epstein was paid with money or information by any blackmail victims.

What the DOJ Memo Says About the Epstein “Client List”

In July of 2025, the DOJ released a memorandum that makes several factual assertions.

Exhaustive Review

The DOJ and FBI claim to have conducted an “exhaustive review” of the evidence gathered while investigating Epstein’s crimes. This review includes digital searches of all electronically stored evidence, such as databases, hard drives, and network servers. 

The agencies also claim to have reviewed all areas where physical evidence is stored, such as desks, closets, file cabinets, and squad areas. Based on these searches, the agencies purport to uncover the following:

  • 300 gigabytes of data
  • Images of Epstein
  • Images of victims who were or appeared to be minors
  • Child pornography and child sex abuse material that was allegedly downloaded rather than produced by Epstein

These materials were reviewed by agents, analysts, and other experts to determine what they had and whether it could be released publicly.

Much of the Evidence Against Epstein Would Not Have Been Made Public

After discussing the enormous volume of material in the DOJ’s hands, the memo then asserts that much of the material is sealed by courts. Specifically, the courts have sealed all records that might expose the identities of victims. Thus, the DOJ concludes that much of the evidence against Epstein could not be made public in a trial.

The memo then makes a confusing leap of logic. It asserts that the material that could have been released to the public would not have exposed any third parties, i.e., the clients, to “allegations of illegal wrongdoing.”

This is where the DOJ’s memorandum starts to split hairs. According to the DOJ’s assertion, it cannot release any evidence that exposes victims, and any evidence that it can release does not implicate any third parties. 

In theory, there is another category left unaddressed by the memorandum, namely, victim evidence that implicates clients. In other words, the DOJ does not address whether the victims’ evidence that was sealed by the courts implicates any third parties. Thus, damaging information about clients could remain solely in the DOJ’s hands because it also contains information about victims.

The Review Revealed No Incriminating Client List

The DOJ asserts that it did not find an “incriminating client list.” Again, the DOJ’s memorandum splits hairs. It does not state that no client list exists. Instead, this statement means that any client list the DOJ may have found was not incriminating. 

Thus, in theory, the DOJ could have found a client list and, on the basis of its investigative discretion, determined that the list did not incriminate anyone. It’s possible that the DOJ found a client list that did not have a clear purpose; it could have been a Rolodex of social contacts or investment customers. 

The DOJ might have determined that the list may have served a noncriminal purpose and, thus, was not an “incriminating client list.” However, it is also possible that the DOJ uses the word “incriminating” to conceal the fact that it has a client list but that it does not have enough evidence to use it as the basis for criminal charges.

No Credible Evidence of Blackmail

The memorandum states that the agencies found no “credible evidence” that Epstein blackmailed prominent individuals. Once again, the memo does not state that there was no evidence at all. Instead, it says that there was no “credible” evidence of blackmail.

Credibility is often in the eye of the beholder. It is possible to interpret the DOJ’s memorandum to mean that no evidence of blackmail existed. However, another plausible interpretation is that DOJ found evidence of blackmail that lacked corroboration.

For example, suppose that the DOJ uncovered financial records showing that someone who was not an investment customer paid Epstein a large sum of money. However, Epstein’s financial records for that payment did not state “For Blackmail.” The DOJ could reasonably argue that there was no credible evidence that the payment was the result of blackmail because it could have served some other legitimate purpose.

No Evidence to Support an Investigation Against Uncharged Clients

The memo states that the review did not uncover evidence that could “predicate an investigation” against uncharged third parties. To begin an investigation, the DOJ needs a reasonable suspicion that a crime occurred. In other words, mere rumors do not provide a strong enough basis to investigate.

However, “reasonable suspicion” is open to interpretation. It means that an objective, reasonable investigator in the same position would suspect that a crime took place. Investigators who are predisposed to forgo an investigation might interpret the evidence differently.

Epstein Committed Suicide

In the memorandum, the FBI concludes that Epstein died by suicide while being held at the Metropolitan Correctional Center in New York City on August 10, 2019. It bases this conclusion on an autopsy and an internal investigation of the officers responsible for guarding Epstein. It also relies on security videos from the detention facility. 

However, after allegations that the publicly released security videos had been doctored, the DOJ released a “missing minute” that raised questions about the agency’s transparency.

What Epstein Survivors Are Saying About the Release of Names

Many members of the public, including Epstein survivors, have called for the release of all files that do not disclose private victim information. The names that would appear in these files could help survivors hold Epstein’s co-conspirators and accomplices accountable.

Contact Us to Discuss Your Sex Assault or Trafficking Case

The experienced attorneys at Edwards Henderson have a record of success fighting for survivors of sexual abuse and trafficking. Contact us for a free and confidential consultation.

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