EFTA01262829.pdf

AO 106 (SDNY Rev. 01/17) Application for a Search Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of An
n7F 1
(Briefly describe the property to be searched
or identify the person by name and address) ) Case
) °'
See Attached Affidavit and its Attachment A )
)
APPLICATION FOR A SEARCH AND SEIZURE WARRANT
a federal law enforcement officer or an attorney for the government, request a search warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (idewt& the person or describe the
property to be searched and give its location):
located in the Southern District of New York , there is now concealed (identify the
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
The bas„ s for the search under Fed. R. Crim. P. 41(c) is (check one or more):
L
vidence of a crime;
,:ontraband, fruits of crime, or other items illegally possessed;
O property designed for use, intended for use, or used in committing a crime;
O a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section(s) Offense Description(s)
18 U.S.C. §§ 1591 and Sex trafficking of minors; sex trafficking conspiracy
371
The application is based on these facts:
See Attached Affidavit and its Attachment A
Continued on the attached sheet.
O Delayed notice of days (give exact ending date if more than 30 days: ) is requested
under I8 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.
dpplicant1 signature
____ Spec's! Agen
.Print.
Sworn to before me and signed in my presence.
Date: 07/07/2019
Judge's signature
City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and tide
tt :2V ri keEntalL4g000072
CONFID
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1 t.t--11110 3571
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In the Matter of the Application of the United TO BE FILED UNDER SEAL
States Of America for a Search and Seizure
Warrant for Compact Discs marked with FBI Agent Affidavit in Support of
evidence numbers 15, 16, 17, 18, and 22, Seized Application for Search and Seizure
from 9 East 71" Street, New York, NY on or Warrant
about July 7, 2019, and Any Files or Media
Stored Therein
SOUTHERN DISTRICT OF NEW YORK) ss.:
being duly sworn, deposes and says:
I. Introduction
A. Affiant
1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since
2012. As such, I am a "federal law enforcement officer' within the meaning of Federal Rule of
Criminal Procedure 41(aX2XC), that is, a government agent engaged in enforcing the criminal
laws and duly authorized by the Attorney General to request a search warrant. I have been
employed by the FBI for three and a half years, and I am currently assigned to investigate violations
of criminal law relating to the sexual exploitation of children. I have gained expertise in this area
through classroom training and daily work related to these types of investigations. As part of my
responsibilities, I have been involved in the investigation of sex trafficking cases, and have been
involved in search warrants for electronic storage media.
2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal
Rules of Criminal Procedure for a warrant to search the storage media specified below (the
"Subject Devices") for the purpose of seizing the items and information described in
Attachment A. This affidavit is based upon my personal knowledge; my review of documents and
other evidence; and my conversations with other law enforcement personnel. Because this
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affidavit is being submitted for the limited purpose of establishing probable cause, it does not
include all the facts that I have learned during the course of my investigation. Where the contents
of documents and the actions, statements, and conversations of others are reported herein, they are
reported in substance and in part, except where otherwise indicated.
B. The Subject Devices
3. The Subject Devices are particularly described as compact discs stored in
containers marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence
of JEFFREY EPSTEIN located at 9 East 71st Street, New York, New York (the "Epstein
Residence"), on or about July 7, 2019.
C. The Target Subject and the Subject Offenses
4. The Target Subject of this investigation is JEFFREY EPSTEIN.
5. For the reasons detailed below, I believe that there is probable cause to believe that
the Subject Devices contain evidence, fruits, and instrumentalities of violations of Title 18, United
States Code, Section 1591 (sex trafficking of minors); Title 18, United States Code, and Section
371 (sex trafficking conspiracyXthe "Subject Offenses") by the Target Subject.
11. Probable Cause
6. On or about July 2, 2019, a grand jury in this District returned an Indictment
charging JEFFREY EPSTEIN with violations of Title 18, United States Code, Section 1591 (sex
trafficking of minors); and Title 18, United States Code, Section 371 (sex trafficking conspiracy).
A copy of the Indictment is attached hereto as Exhibit A and is incorporated by reference.
The Indictment and Victim-I
7. As set forth in Exhibit A, from at least in or about 2002, up to and including at least
in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern
District of New York and elsewhere. During that time and continuing to the present, EPSTEIN
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possessed and controlled the Epstein Residence, which is described in Exhibit A as "the New York
Residence."
8. As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or
about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous
minor victims at the Epstein Residence. In particular, and as alleged in the Indictment, when a
victim arrived at the Epstein Residence, she would be escorted to a room inside the Epstein
Residence with a massage table, where she would perform a massage on EPSTEIN. 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 victims' genitals. EPSTEIN typically
would also masturbate during these sexualized encounters, ask victims to touch him while he
masturbated, and touch victims' genitals with his hands or with sex toys. Following each
encounter, EPSTEIN or one of his employees or associates paid the victim in cash.
9. As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability
to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to
recruit additional minor girls to perform "massages" and similarly engage in sex acts with
EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victim-
recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were
underage, including because certain victims told him their age.
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10. One of the victims identified in paragraph 22 of Exhibit A is Victim-I. As part of
the FBI's investigation of EPSTEIN, other law enforcement officers have interviewed Victim-I.1
I know from my conversations with other law enforcement officers who have interviewed Victim-
I, that Victim-1 has provided the following information, in substance and in part:
a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on
multiple occasions in the Epstein Residence. This sexual abuse all occurred when Victim-1 was
under the age of 18.
b. During that same period, Victim-1 observed multiple floors of the Epstein
Residence and numerous individual rooms within the Epstein Residence. Victim-I has provided
detailed descriptions of certain aspects of the interior of the Epstein Residence, including Victim-
l's memory of specific details regarding the layout, furnishings, decorations, and floor pattern of
various areas within the Epstein Residence.
c. In particular, Victim-I observed that a bathroom in the residence contained what
appeared to be a bust of a human torso (the "Torso"). Victim-I believed that the Torso was
possibly a type of sex toy.
d. In addition, Victim-I recalled observing what appeared to be a taxidermied dog in
a living space in the Epstein Residence.
I In meetings with the Government, Victim-1 has disclosed that, approximately a decade ago, she
committed marriage fraud in order to obtain a green card and, subsequently, U.S. citizenship. She
has also disclosed personal substance abuse, primarily involving the abuse of prescription drugs,
during various periods between the early 2000s and 2019. Victim-1 has also disclosed having
worked for approximately a year at a "happy-ending" massage parlor, performing paid sex acts.
Victim-I is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her.
Information provided by Victim-1 has proven reliable and has been corroborated by independent
evidence, including documents and records obtained during the investigation and the accounts of
other victims whom Victim-1 has never met.
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e. Victim-1 recalled that EPSTEIN typically abused her in a room she described as a
"massage room," (the "Massage Room"), which contained a massage table, and was decorated
with artwork depicting naked women, hung on walls that appeared to be adorned with fabric.
f. Victim-I has not been in the Epstein Residence since approximately 2005.
The July 6.2019 Search Warrant of the Epstein Residence
11. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a search warrant authorizing a search of the Epstein Residence (the "First Warrant").
12. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the
"Search Team") commenced executing the search warrant at the Epstein Residence; 1 joined the
Search Team thereafter.
13. Based on the Search Team's observations during an initial search of the Epstein
Residence, at approximately 7 p.m., the Search Team stopped the search and froze the scene in
order to seek a new search warrant.
14. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a search warrant authorizing a search of the Epstein Residence (the "Second
Warrant"). The search warrant is attached as Exhibit B, and incorporated by reference herein. At
approximately 2:30 a.m., the Search Team resumed the search, and commenced searching pursuant
to the Second Warrant.
15. Based on my conversations with members of the search team, and my participation
in the search, I have learned the following:
a. Inside a safe in a closet on the third floor, the Search team discovered, among other
items, several binders containing sleeves of compact discs, most of which are labeled with
handwriting. In total, the binders contain dozens of compact discs. One disc is marked "Young-
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-and_" Another disc is marked "Nudes 00-24." Another is marked "Misc. Nudes."
Yet another is marked "Girl Pics Nude." Some discs contain the word "Zorro" or "LSJ." For
example, one disc is marked Bono Pies." Based on my conversations with law enforcement
agents who have participated in this investigation, I believe the name "Zorro" refers to Zorro
Ranch, EPSTEIN's property in New Mexico, and the name LSJ refers to Little Saint James,
EPSTEIN's property in the U.S. Virgin Islands. The majority of the discs contain titles that include
female names. Some of the discs in the binders seized by the Search Team have titles that appear
to refer to trips or vacations. However, given that these discs were contained in a safe, where based
on my training and experience I know that contraband is often stored, and given that these discs
were stored together with discs referencing girls and nudes, I submit that there is probable cause
that all of the discs in the binders seized by the Search Team contain evidence of the Subject
Offenses. 2
b. In the drawer of a dresser in a room on the Fifth floor of the Epstein residence, the
Search team discovered, among other items, a shoebox (the "Shoebox") containing numerous
compact discs. The majority of the discs are labeled, in handwriting, with female names. One
disc is marked "Thai Massage." Another disc is marked "Blonde Girl Photo Shoot." Yet another
disc is marked "Misc. Girls
Nude/Dinner--Scientists." The discs in the Shoebox were seized by
the Search Team. In another drawer of that same dresser, the Search Team discovered loose
polaroid photographs depicting young, nude females who, based on my training and experience,
appear to be teenagers. In that same drawer, the Search Team discovered a folder marked, in
2 o t h D f i s t u h a r e i p n d p g i l s i t c c h a s e t w i s o e e n a r e d rc o l h a e , b s t e h n l e e o d t S s i e n e a e r a c k h m a T u a e t n h a n o m e r r i z l t e a h f t a t io t b n d e i h t d o i n n s d o e t b a a r in c p d h p e e th r a s o r s t t h e o a c r t e o c m f o e n p r t a t a o c in t g e d i d r is l s d c s i o s , c r w s n , h u w i d c e h h s e w . r e e A t r h c e e c l o e m r f d t a a i j n o t g r t i h l t y y e ,
Epstein Residence.
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handwriting, IR' which contained photographs, including nude and sexually suggestive
photographs of a young girl who, based on my training and experience appears to be younger than
18. The folder contains other nude photographs of young girls who appear to be teenagers, based
on my training and experience. Inside the folder is a compact disc marked `11a t US 6/03" (the
Disc"), which was seized by the Search Team. Given that the labels of the compact discs in
the Shoebox reference "massage," "girls," and the name of a girl, and the fact that discs in the
Shoebox and the Disc were seized from a dresser that also contained nude and sexually
suggestive photographs of a young girl, I respectfully submit that there is probable cause to believe
that the discs seized from the Shoebox and then Disc contain evidence of the Subject Offenses.
c. In a closet on the Fifth Floor of the Epstein Residence, the Search Team discovered,
among other items, a box marked "women/old photos." The box contained, among other items,
approximately seven compact discs, which are labeled with hand-written titles. One disc is marked
"nudes 00-24." Another is labeled
"Photographer-a03" The remaining discs contain titles
that include female names. All of the foregoing discs were seized by the Search Team. Given that
one of these discs is marked "nudes" and that the discs were stored in a box marked "women/old
photos," and given the other evidence seized from the Epstein Residence, I submit that there is
probable cause that the discs contain evidence of the Subject Offenses.
d. In that same closet, the Search Team discovered numerous black binders containing
what appear to be print outs of digital photographs (with file names underneath) and compact discs.
The Search Team seized approximately ten binders (the "Seized Binders")3 which appeared to
contain, among other photographs, photographs of nude or partially nude young girls, some of
which are in sexually suggestive poses. Based on my training and experience, some of the young
3 The Search Team did not seize the remaining binders.
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girls appear to be teenagers, some of whom appear to be under the age of 18. The Seized Binders
also include photographs of what appear to be family functions, events, and travel. However,
given that the discs in the Seized Binders were stored together with photographs of nude or
partially nude young girls, I submit that there is probable cause that all of the discs in the Seized
Binders contain evidence of the Subject Offenses!
e. The compact discs seized by the Search Team and described in paragraphs 15(a)-(d)
are the Subject Devices, and are currently stored within the Southern District of New York in
containers marked with FBI evidence numbers 15, 16, 17, 18, and 22.
16. The Second Wan-ant expressly authorized the search and seizure for "any other
documents of communications with or regarding victims of potential victims of the Subject
Offenses." Accordingly, the Second Warrant authorizes the search of the Subject Devices because,
based on their markings, there was probable cause to believe they included discs that appear to
contain documents regarding underage girls who may be victims of the Subject
Offenses. However, law enforcement has not yet reviewed the Subject Devices. In an abundance
of caution, therefore, I respectfully request that the Court issue a warrant to seize and search the
items and information specified in Attachment A to this affidavit and to the Search and Seizure
Warrant.
17. Based on the foregoing, I respectfully submit that there is probable cause to believe
that the Subject Devices contain evidence of the Subject Offenses.
• o th D f i s t u h a r e i p n d p g i l s i t c c h a s e t w i s o e e n a r e d rc o l h a e , b s t e h n l e e o d t S s i e n e a e r a c k h m a T u a e t n h a n o m e r r i z l t e a h f t a i t o t b n d e i t h d o i n n s d o e t a b a r in c p h d p e t e h r a s o r s t t h e o a c r t e o c m f o e n p r t a t a o c in t g e d i d i r s l s c d s i o s , c r w s n , h u w i d c e h h s e w . r e e A t r h c e e c l o e m r f d t a i a j n o t g r t i h l t y y e ,
Epstein Residence.
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III. Procedures for Searching ESI
A. Review of ESI
18. Law enforcement personnel (including, in addition to law enforcement officers and
agents, and depending on the nature of the ESI and the status of the investigation and related
proceedings, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) will
create a forensic image of the Subject Devices (if practicable) and review the ESI contained therein
for information responsive to the warrant.
19. In conducting this review, law enforcement personnel may use various techniques
to determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
• surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
• conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigations; and
• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
5 k s n u e o K b y t e j w s e y t c o o w t r r d o e to r d s d e a s a e t s a r i e z c a a u h s r r e c s e s h e e b w a s r u o c t a r h t k l a h o b a o n l t n e e l i y t s a e r n x f e o o t . r t t M y t c e p a o x i p c r t t e a u d o l r a l v e y t d e a r , i , b n y e y a e v d t a e e m n q k a u a e n s y a y t w t e o t o y t t r o e p d x e d s t s e e d o a t a e f r t c c a f h t i , l t e a b h s l e e l , r c s e r a u e u m c l s e h a e v y a a t h s n b e t e i m d i i n n a a f f g t o o a e r r . s m m F a a a o n t t r d i i o o o n v n n i d d p e o e r o o t e h p s s i , e n n d r g o l o y , t
contain the keywords being searched.
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20. Law enforcement personnel will make reasonable efforts to restrict their search to
data falling within the categories of evidence specified in the warrant. Depending on the
circumstances, however, law enforcement personnel may need to conduct a complete review of all
the ESI from seized devices or storage media to evaluate its contents and to locate all data
responsive to the warrant.
B. Return of ESI
21. If the Government determines that the electronic devices are no longer necessary
to retrieve and preserve the data, and the devices themselves are not subject to seizure pursuant to
Federal Rule of Criminal Procedure 41(c), the Government will return these items, upon request.
Computer data that is encrypted or unreadable will not be returned unless law enforcement
personnel have determined that the data is not (i) an instrumentality of the offense, (ii) a fruit of
the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, or (v) evidence of the
Subject Offenses.
IV. Conclusion and Ancillary Provisions
22. Based on the foregoing, I respectfully submit there is probable cause to believe that
evidence of the Subject Offenses, and in particular the items described in Attachment A, will be
located within the Subject Devices and therefore request the court to issue a warrant to seize the
items and information specified in Attachment A to this affidavit and to the Search and Seizure
Warrant.
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23. The investigation is ongoing, and the investigative team anticipates beginning a
search of the Subject Devices this evening, possibly after 10 p.m. In view of the circumstances, I
submit that good cause exists to begin the search after 10 p.m.
4
special Agent
Federal Bureau of Investigation
Sworn to before me on
July 7, 2019
VA
THE HONORABLE BA SARA MOSES
UNITED STATES MAGIS-IRATE JUDGE
m
to
CC-cock-Lino)
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ATTACHMENT A
L The Subject Devices to Be Searched
The Subject Devices are particularly described as compact discs stored in containers
marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence located at 9
East 71st Street, New York, New York, on or about July 7, 2019.
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex
trafficking conspiracy) (the "Subject Offenses") described as follows:
I. Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
2. Any photographs of victims or potential victims of the Subject Offenses;
3. Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger;
4. Motion pictures, films, videos, and other recordings of visual or written depictions
of minors engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2);
5. Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usemames and passwords, user profiles, e-mail contacts, and photographs;
6. Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
B. Review of ESI
Law enforcement personnel (including, in addition to law enforcement officers and agents,
and depending on the nature of the ESI and the status of the investigation and related proceedings,
attorneys for the government, attorney support staff, agency personnel assisting the government in
this investigation, and outside technical experts under government control) will create a forensic
image of the Subject Devices (if practicable) and review the ESI contained therein for information
responsive to the warrant.
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
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• surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
• conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation6; and
• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section
II.A of this Attachment. However, law enforcement personnel arc authorized to conduct a
complete review of all the ESI from seized devices or storage media if necessary to evaluate its
contents and to locate all data responsive to the warrant.
6 Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
keyword searches work only for text data, yet many types of files, such as images and videos, do
not store data as searchable text. Moreover, even as to text data, there may be information properly
subject to seizure but that is not captured by a keyword search because the information does not
contain the keywords being searched.
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EXHIBIT A
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
SEALED
UNITED• STATES OF AMERICA INDICTMENT
19 Cr.
19 CRIM 490
JEFFREY EPSTEIN,
Defendant.
X
COUNT ONE
(Sex Trafficking Conspiracy)
The Grand Jury charges:
OVERVIEW
1. As set forth herein, over the course of many
years, JEFFREY EPSTEIN, the defendant, sexually exploited and
abused dozens of minor girls at his homes in Manhattan, New
York, and Palm Beach, Florida, among other locations.
2. In particular, from at least in or about 2002, up
to and including at least in or about 2005, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, minor girls to visit his mansion in Manhattan, New
York (the "New York Residence") and his estate in Palm Beach,
Florida (the "Palm Beach Residence") to engage in sex acts with
him, after which he would give the victims hundreds of dollars •
in cash. 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
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this way, EPSTEIN created a vast network of underage victims for
him to sexually exploit in. locations including New York and
Palm Beach.
3. The victims described herein were as young as 14
years old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for various reasons, often particularly
vulnerable to exploitation. EPSTEIN intentionally sought out
minors and knew that many of his victims were in fact under the
age of 18, including because, in some instances, minor victims
expressly told him their age.
4. In creating and maintaining this network of minor
victims in multiple states to sexually abuse and exploit,
JEFFREY EPSTEIN, the defendant, worked and conspired with
others, including employees and associates who facilitated his
conduct by, among other things, contacting victims and
scheduling their sexual encounters with EPSTEIN at the New York
Residence and at the Palm Beach Residence.
FACTUAL BACKGROUND
5. During all time periods charged in this
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with
multiple residences in the continental United States, including
the New York Residence and the Palm Beach Residence.
6. Beginning in at least 2002, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and •
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recruited, dozens of minor girls to engage in sex acts with him,
after which EPSTEIN paid the victims hundreds of dollars in
cash, at the New York Residence and the Palm Beach Residence.
7. In both New York and Florida, JEFFREY EPSTEIN,
the defendant, perpetuated this abuse in similar ways. Victims
were initially recruited to provide "massages" to EPSTEIN, which
would be performed nude or partially nude, would become
increasingly sexual in nature, and would typically include one
or more sex acts. EPSTEIN paid his victims hundreds of dollars
in cash for each encounter. Moreover, 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. In so
doing, EPSTEIN maintained a steady supply of new victims to
exploit.
The New York Residence
8. At all times relevant to this Indictment, JEFFREY
EPSTEIN, the defendant, possessed and controlled a multi-story
private residence on the Upper East Side of Manhattan, New York,
i.e., the New York Residence. Between at least in or about 2002
and in or about 2005, EPSTEIN abused numerous minor victims at
the New York Residence by causing these victims to be recruited
to engage in paid sex acts with him.
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9. When a victim arrived at the New York Residence,
she typically would be escorted to a room with a massage table,
where she 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. EPSTEIN typically would also masturbate during these
sexualized encounters, ask victims to touch him while he
masturbated, and touch victims' genitals with his hands or with
sex toys.
10. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars in cash for each encounter.
11. JEFFREY EPSTEIN, the defendant, knew that many of
his New York victims were underage, including because certain
victims told him their age. Further, once these minor victims
were recruited, many were abused by EPSTEIN on multiple
subsequent occasions' at the New York Residence. EPSTEIN
sometimes personally contacted victims to schedule appointments
at the New York Residence. In other instances, EPSTEIN directed
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employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter. In
addition, certain victim-recruiters routinely scheduled these
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encounters through Employee-1, who sometimes asked the
recruiters to bring a specific minor girl fox EPSTEIN.
The Palm Beach Residence
14. In addition to recruiting and abusing minor girls
in New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence. 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.
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants ("Employee-2" and'
"Employee-3") who, as described herein, Were also responsible
for scheduling sexual encounters with minor victims. Once
inside, the victim would provide a nude or semi-nude massage for
EPSTEIN, who would himself typically be naked. During these
encounters, EPSTEIN would escalate the nature and scope of the
physical contact to include sex acts such as groping and direct
and indirect contact with the victim's genitals. EPSTEIN would
also typically masturbate during these encounters, ask victims
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to touch him while he masturbated, and touch victims' genitals
with his hands or with sex toys.
16. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
. 17. JEFFREY EPSTEIN, the defendant, knew that certain
of his victims were underage, including because certain victims
told him their age. In addition, as with New York-based
victims, many Florida victims, once recruited, were abused by
JEFFREY EPSTEIN, the defendant, on multiple additional
occasions.
18. JEFFREY EPSTEIN, the defendant, 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. In particular, in certain
instances, Employee-2 placed phone calls to minor victims in
Florida to schedule encounters at the Palm Beach Residence. At
the time of certain of those phone calls, EPSTEIN and Employee-2
were in New York, New York. Additionally, certain of the
individuals victimized at the Palm Beach Residence were
contacted by phone by Employee-3 to schedule these encounters.
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19. Moreover, as in New York, to ensure a steady
stream of minor victims, JEFFREY EPSTEIN, the defendant, asked
and enticed certain victims in Florida to recruit other girls to
engage in sex acts. EPSTEIN paid hundreds of dollars to victim-
recruiters for each additional girl they brought to the Palm
Beach Residence.
STATUTORY AtLrGATIONS
20. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New York
and elsewhere, 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, in violation of Title 18, United States Code, Section.
1591(a) and (b).
21. It was a part and object of the conspiracy that
JEFFREY EPSTEIN, the defendant, and others known and unknown,
would and did, in and affecting interstate and foreign commerce,
recruit, entice, harbor, transport, provide, and obtain, by any
means a person, and to benefit, financially and by receiving
anything of value, from participation in a venture which has
engaged in any such act, knowing that the person had not
attained the age of 18 years and would be caused to engage in a
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commercial sex act, in violation of Title 18, United States
Code, Sections 1591(a) and (b)(2).
Overt Acts
22. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were committed in the Southern District of New York and
elsewhere:
a. In or about 2004, JEFFREY EPSTEIN, the
defendant, enticed and recruited multiple minor victims,
including minor victims identified herein as Minor Victim-1,
Minor Victim-2, and Minor Victim-3, to engage in sex acts with
EPSTEIN at his residences in Manhattan, New York, and Palm
Beach, Florida, after which he provided them with hundreds of
dollars in cash for each encounter.
b. In or about 2002, Minor Victim-1 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the New York Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-1
to recruit other girls to engage,in paid sex acts, which she
did. EPSTEIN asked Minor Victim-1 how old she was, and Minor
Victim-1 answered truthfully.
c. In or about 2004, Employee-1, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
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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.
d. In or about 2004, Minor Victim-2 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars after each
encounter. EPSTEIN also encouraged and enticed Minor Victim-2
to recruit other girls to engage in paid sex acts, which she
did.
e. In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-2 in order to schedule an
appointment for Minor Victim-2 to engage in paid sex acts with
EPSTEIN.
f. In or about 2005, Minor Victim-3 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-3
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim-3 how old she was, and Minor
Victim-3 answered truthfully.
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g• In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-3 in Florida in order to
schedule an appointment for Minor Victim-3 to engage in paid sex
acts with EPSTEIN.
h. In or about 2004, Employee-3 placed a
telephone call to Minor Victim-3 in order to schedule an
appointment for Minor Victim-3 to engage in paid sex acts with'
EPSTEIN.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
23. The allegations contained in paragraphs'l
through 19 and 22 of this Indictment are repeated and realleged
as if fully set forth within.
24. From at least in or about 2002, up to. and
including in or about 2005, in the Southern District of New
York, JEFFREY EPSTEIN, the'defendant, willfully and knowingly,
in and affecting interstate and foreign commerce, did recruit,
entice, harbor, transport, provide, and obtain by any means a
person, knowing that the person had not attained the age of 18
years and would be caused to engage in a commercial sex act, and
did aid and abet the same, to wit, EPSTEIN recruited, enticed,
harbored, transported, provided, and obtained numerous
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individuals who were less than 18 years old, including but not
limited to Minor Victim-1, as described above, and who were then
caused to engage in at least one commercial sex act in
Manhattan, New York.
(Title 18, United. States Code, Sections 1591(a),
(b)( 2), and 2.)
FORFEITURE ALLEGATIONS
25. As a result of committing the offense alleged in
Count Two of this Indictment, JEFFREY EPSTEIN, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594(c)(1), any property, real and
personal, that was used or intended to be used to commit or to
facilitate the commission of the offense alleged in Count Two,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Two, or any property traceable to
such property, and the following specific property:
a. The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 9 East 71st Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
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Substitute Asset Provision
26. If any of the above-described forfeitable
property, as a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d), has been substantially diminished in value; or
(e) has been commingled with other property which cannot
be subdivided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C.
853(p) and 28 U.S.C. § 2461(c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853(p); and
Title 28, United States Code, Section 2461.)
t
GEOFiFYR . BERMAN
United States Attorney
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Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
JEFFREY EPSTEIN,
Defendant.
'INDICTMENT
(18 U.S.C. §§ 371, 1591(a), (b)(2),
and 2)
GEOFFREY S. BERMAN
United Statei Attorney
14
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EXHIBIT B
13
2017.0.2
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AD 03 ISDNY key tuI 7I Search oral Sonire tVairanI
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(fiddly describe the proper°. to be searched
or identify the person by nom and( farm) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
ridengfr tire person or describe the property to be searched and give us location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the properly
to be swizedn
See Attachment A
The search and seizure are related to violation(s) of (Insert monstorycitentonc):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s). or any recorded testimony, establish probable cause to search and seize the person or
ProPer131.
YOU ARE COMMANDED to execute this warrant on or before July 7, 2019
(not to exceed 14 days)
O in the daytime 6:00 a.m. to 10 p.m. at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
O Upon its return, this warrant and inventory should be filed under seal by the Clerk of Court,
£4S'ALt initials
O 1 find that immediate notification may have an adverse result listed in IS U.S.C.. § 2705 (except for delay
(retrial), and authorize the officer executing this warrant to delay notice to the person wbo, or whose property, will be
searched or seized (check the toppropriate box) Ofor days (not to exceed 30). •
Ountil. the facts justifyipg Wuclater speCific date o
9A-
' 1
Date and time issued: - k•Ot42,41 •
Judge's• sinew,
City and state: New York. NY Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and tide
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AO93 (SONY Ray Oil)?) Search and SelAlft Watrani (Page 2)
Return
Case No.: Date and lime warrant executed: Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
&earring officer's stratum
Nitwit name and title
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ATTACHMENT A
I. Premises to be Searched—Subject Premises
1. The premises to be searched (the "Subject Premises") are described as a multi-story
single-family residence located at 9 East 71st Street, New York, New York, and include all locked
and closed containers found therein. A photograph of the front entrance to the Subject Premises
is included below:
Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371.
(sex trafficking conspiracy) (the "Subject Offenses") described as follows:
i. Any and all taxidermied dogs.
ii. Any and all massage tables and massage paraphernalia.
iii. Any and all busts or three-dimensional representations of female human
torsos.
iv. Any and all photos or representations depicting nude or partially nude
women located in the Massage Room, as defined herein.
v. Any and all sex toys and sex paraphernalia located in the Massage
Room, as defined herein.
2017.08.02
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vi. A binder labeled "PB Girls" and any other documents or
communications with or regarding victims or potential victims of the
Subject Offenses.
2
2017.08.02
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