EFTA01262900.pdf

AO 106 (SUM Rev. 01/17) Application for a Search Warrant
UNITED STATES DISTRICT COURT
for the
oo 5 1
In the Matter of the Search of
k41/41 (Briefly describe the property to be searched
A Us& it a -g -tat o r i o d e t a h * „ th V e p i e l r a son by na 3 m s e - 7 an x d aidodreescs)i sviss. ) Case No.
&Avis WM 0/8- se-N 'Jo. 0i-VaGrA3y4,nois: grab, ti< )
Wev146. tivst,ns souk eg%e t -4,4, 1„-,0 111)41; IF\ Spea,s, Abe IC 14 Oa: ,
cab k, vinitivy,c4 .1624,1, ft %Reg 6.4144: r u t cerx kint Slatted
ri,j44 5,1,447,T4RootNtraA suwict?111..S.tIZU,REhta
is is. of cki sest4 . tr acNT
1, a federal law enforcement officer or an attorney for the government, request a seared warrant and state under
penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the
property to be searched and give its location):
4
New
located in the (501.4.1-ina n District of D(L , there is now concealed (Identlfr the
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
firevidence of a crime;
O contraband, 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)
minors
is USC 15 + 3 -1I Sex l aragatail .5 oc -
C.-)C etf-ec tn3 Co n Sp r ackg
The application is based on these facts:
See Attached Affidavit and its Attachment A
cif
Continued on the attached sheet.
O Delayed notice of 30 _ days (give exact ending date if more Than 30 days: ) is requested
under 18 U.S.C. § 3103a, the basis of which is s
Sworn to before me and signed in my presence.
1 5 2019
JUL
Date:
Judge's signature
City and state: New York, NY HON. KEVIN NATHANIEL rox
tirad Otelostillokattti skaitehduto
CONFIDNITA of Nowst9fik-t-t°183
EFTA 00114267
EFTA01262900

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 (1) a black iPhone with IMEI number Agent Affidavit in Support of
357201093322785, (2) a silver iPad with serial Application for Search and Seizure
number DLXQGM3KOMW3, (3) two black Warrant
binders with CDs, (4) two black hard drives, (5)
a box of CDs, and (6) two binders with various
CDs
SOUTHERN DISTRICT OF NEW YORK) ss.:
being duly sworn, deposes and says:
I. Introduction
A. Afflant
1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since
As such, I am a "federal law enforcement office?' 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 am currently
assigned to investigate violations of criminal law relating to the sexual exploitation of children.
As part of my responsibilities, I have participated in numerous investigations and prosecutions of
crimes against children, including the sex trafficking of minors, and have participated in the
execution of search warrants involving electronic evidence.
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 certain electronic devices, compact disks and
related electronic media specified below (the "Subject Items") for the items and information
described in Attachment A. This affidavit is based upon my personal knowledge; my review of
documents and other evidence; my conversations with other law enforcement personnel; and my
1
CONFIDENTIAL SDNY_GM_00000184
2017.08.02
EFTA_00114268
EFTA01262901

training, experience and advice received concerning the use of computers in criminal activity and
the forensic analysis of electronically stored information ("ESI"). Because this 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 Items
3. The Subject Items are particularly described as follows':
a. A black iPhone with IMEI number 357201093322785, which was seized
from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-1").
b. A silver iPad with serial number DLXQGM3KGMW3, which was seized
from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-2").
c. Two black binders with CDs, which were seizeYt,,from a blue suitcase on or
pectol Avert
about July 11, 2019 ("Subject Item-3").
d. Two black hard drives, which were seizectf rom a blue suitcase on or about
Sfec41 Aynk
July 11, 2019 ("Subject Item-4").
e. A box of CDs, which was seizedsfrom a blue suitcase on or about July 11,
hlo`seccikk A3ent
2019 ("Subject Item-5").
f. Two binders with various CDs, which were seized from a black suitcase on
b3 S& cu•e,
or about July 11, 2019 ("Subject Item-6").
To the extent that the Subject Items contain any SD cards or other removable storage media, the
description of each such item encompasses those SD cards and other media.
2
CONFIDENTIAL SDNY_GM_00000185
2017.08.02
EFTA_00114269
EFTA01262902

4. Based on my training, experience, and research, I know that Subject Item-1 and
Subject Item-2 both have capabilities that allow them to serve as a wireless telephone, digital
camera, portable media player, GPS navigation device, and PDA.
5. The Subject Items are all presently located in the Southern District of New York.
C. The Target Subject and the Subject Offenses
6. The 'Paget Subject of this investigation is JEFFREY F-PSTEIN.
7. For the reasons detailed below, I respectfully submit that there is probable cause to
believe that the Subject Items contain evidence, fruits, and instrumentalities of violations of Title
18, United States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code,
Section 371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject.
El. Probable Cause
A. Probable Cause Regarding the Target Subject's Commission of the Subject Offenses
8. On or about July 2, 2019, a grand jury in this District returned an Indictment
charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached
hereto as Exhibit A and is incorporated by reference.
9. That same day, the Honorable Barbara Moses, United States Magistrate Judge,
signed an arrest warrant for JEFFREY EPSTEIN. A copy of the Arrest Warrant is attached hereto
as Exhibit B and is incorporated by reference.
B. Probable Cause Justifying Search of the Subject Items
The Indictment and Victim-1
10. 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
3
CONFIDENTIAL SDNY_GM_00000186 .
2017.08.02
EFTA_001 14270
EFTA01262903

possessed and controlled a multi-story, single-family residence located at 9 East 71st Street, New
York, New York, which is described in Exhibit A as "the New York Residence."
11. 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 New York Residence. In particular, and as alleged in the Indictment, when a
victim arrived at the New York Residence, she would be escorted to a room inside the Subject
Premises 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.
12. M 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.
13. One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of
the FBI's investigation of EPSTEIN, other law enforcement officers and I have interviewed
2017.08.02
CONFIDENTIAL SDNY_GM_00000187
EFTA_00114271
EFTA01262904

Victim-1.2 During those interviews, Victim-1 has provided the following information, in
substance and in part:
a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 im
multiple occasions in the New York Residence. This sexual abuse all occurred when Victim-1
was under the age of 18.
The July 6.2019 Seizure of Subject Item-1 and Subiect Item-2
14. I know from my personal participation in this investigation and my conversations
with other law enforcement agents that on July 6, 2019, JEFFREY EPSTEIN was aboard a private .M
jet that flew from France and landed at approximately 5:30 p.m. in Teterboro Airport in BergentrOUt
New Jersey. Upon his arrival at Teterboro Airport, and as part of his re-entry into the United
States, EPSTEIN was searched by agents of U.S. Customs and Border Protection ("CBP"), who
found both Subject Item-1 and Subject Item-2 in EPSTEIN's possession. The CBP agents then
provided Subject Item-1 and Subject Item-2 to Special Agents of the FBI who also placed
EPSTEIN under arrest. The FBI subsequently transported Subject Item-1 and Subject Item-2 to
FBI offices located in the Southern District of New York, where they are currently located.
2
I II I l ' 1 4,0 - 1 MN II I : 1 ' : 1 I 11 . 11 : : I ' :
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.
5
2017.08.02 CONFIDENTIAL SDNY_GM_00000185
EFTA_00114272
EFTA01262905

The July 6.2019 and July 7.2019 Search Warrants for the New York Residence
15. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a search warrant authorizing a search of the New York Residence. The search
warrant is attached as Exhibit C and incorporated by reference herein.
16. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the
"Search Team") commenced executing the search warrant at the New York Residence.
17. Based on the Search Team's observations during an initial search of the New York
Residence, at approximately 7 p.m., the Search Team stopped the search and froze the scene in
order to seek a new search warrant.
18. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a second search warrant authorizing a search of the New York Residence (the
"Second Warrant"). The Second Warrant is attached as Exhibit D, 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
19. Based on my conversations with members of the Search Team, I have learned the
following:
a. The Search Team observed a number of computing devices, including computers
and tablet devices, throughout the New York Residence.
b. Inside a safe in a closet on the third floor (the "Safe"), the Search Team discovered
and seized, 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
labeled "Young—I " Another disc is labeled "Nudes 00-24." Another is
labeled "Misc. Nudes." Yet another is labeled "Girl Pies Nude." Some discs contain the word
CONFIdENTIAL aDNY_GM 00000189
2017.08.02
EFTA_00114273
EFTA01262906

"Zorro" or "LSJ." For example, one disc is marked "Dana Zorro 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.
c. During the search, the Search Team did not seize at that time certain binders of
discs located in the Safe, where the majority of the discs in the binder were labeled in a manner
that did not appear to refer to girls or nudes. The Search Team also did not seize at that time
several unlabeled hard drives, which were also located in the Safe. As detailed below, those
additional binders of discs are among the subjects of this application.
d. In addition to the Safe, in the drawer of a dresser in a room on the Fifth floor of the
New York Residence, the Search team discovered and seized, among other items, a shoebox (the
"Shoebox") which contained numerous compact discs. The majority of the discs are labeled, in
handwriting, with female names. One disc is labeled "Thai Massage." Another disc is labeled
"Blonde Girl Photo Shoot." Yet another disc is labeled "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 the training and experience of law enforcement officers who observed them, appear to be
teenagers. In that same drawer, the Search Team discovered a folder marked, in handwriting,
which contained photographs, including nude and sexually suggestive photographs of a
young girl who, based on the training and experience of law enforcement officers who observed
them, appears to be younger than 18. The folder also contained other nude photographs of young
CONFIDlENTIAL SONY_GM_00000190
2017.08.02
EFTA_00114274
EFTA01262907

girls who appear to be teenagers, based on my training and experience. Inside the folder is a
compact disc marked which was seized by the SeatCh Team.
e. In a closet on the Fifth Floor of the New York 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 labeled "nudes 00-24." Another is labeled "Photographer—Mackla `03" The remaining
discs contain titles that include female names. All of the foregoing discs were seized by the Search
Team.
f. 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 the training and experience of law enforcement
officers who observed them, at least some of the young girls depicted in the photographs appear
to be teenagers, including some who appear to be under the age of 18. The Seized Binders also
include photographs of what appear to be personal functions, events, and travel.
g. The compact discs seized by the Search Team and described in paragraphs li(a)-(d)
are currently stored within the Southern District of New York in containers marked for
identification with FBI evidence numbers 15, 16, 17, 18, and 22 (the "Seized Discs").
The July 7. 2019 Search Warrant for th&Seized Discs
20. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a third search warrant to search and seize electronic media stored on the Seized Discs
3 The Search Team did not seize the remaining binders.
CONFIDENTIAL SDNY_GM_00000191
2017.08.02
EFTA_00114275
EFTA01262908

(the "Third Search Warrant"). The Third Warrant is attached as Exhibit E, and incorporated by
reference herein.
21. Based on my conversations with law enforcement agents who have reviewed the
Seized Discs pursuant to the Third Search Warrant (the "Reviewing Agents"), I have learned the
following:
a. The discs contain approximately thousands of nude or partially nude photographs
of girls or young women, many of which are in sexually suggestive poses. Based on my
conversations with the Reviewing Agents, who have particular training and experience relating to
child erotica and visual depictions of children in child exploitation cases, I have learned that the
Reviewing Agents believe that many of the nude or partially nude images they have reviewed
appear to depict girls under the age of 18. Moreover, many of the photographs appear to be labeled
with file names that suggest the photographs depict these girls at properties associated with
JEFFREY EPSTEIN. For example, some file names are labeled "Zorro" or "LSJ."
b. Among the photographs on the Seized Discs, the Reviewing Agents identified
partially-nude photographs of a young girl, labeled with an associated name that matched a
particular individual ("Individual-1"). After identifying those photographs, the Government was
advised by Individual-1's counsel that Individual-1 recalls the month and year during which she
believes those partially-nude photographs were taken, and also the location where they were taken,
and that she was 17 years old at the time.
The July 11, 2019 Search Warrant for All Electronic Devices and Storage Media in the
New York Residence
22. Following the initiation of the FBI's review of the Seized Discs, on or about July
11, 2019, the Honorable Henry B. Pitman, United States Magistrate Judge, signed another search
warrant authorizing another search of the New York Residence and specifically authorizing the
CONFID9ENTIAL aDNY_GM_00000192
2017.08.02
EFTA_00114276
EFTA01262909

seizure and search of electronic devices and storage media inside the New York Residence (the
"Fourth Warrant"). The Fourth Warrant is attached as Exhibit F and incorporated by refe, ce
herein.
23. Later on July 11, 2019, the Search Team executed the Fourth Warrant at the New
York Residence.
24. Based on my conversations with members of the Search Team, I have learned the
following, among other things, regarding the execution of the Fourth Warrant:
a. During the July 11, 2019 execution of the Fourth Warrant inside the New
York Residence, the Search Team found that the Safe described above was empty and, in
particular, that the collection of discs and hard drives described in paragraph 19b, above, that the
Search Team had not seized during its prior search of the New York Residence on July 7, 2019,
had been removed.
b. After discovering that the Safe was empty, the Search Team spoke with an
employee who worked at the New York Residence (the "Employee"). During that conversation,
the Employee told the Search Team that after the completion of the prior search on July 7, 2019,
the Employee had been instructed by a third party ("the Third Party") to take the contents of the
Safe out of the New York Residence and deliver those items to the Third Party. The Employee
further told the Search Team that after receiving that instruction, the Employee packed the contents
of the Safe into two suitcases and delivered those suitcases to the Third Party. The Employee
provided the Search Team with the Third Party's contact information.
c. The Search Team then contacted the Third Party. During the ensuing
conversation, the Third Party confirmed receipt of two suitcases from the Employee but also told
CONFII5ENTIAL SDNY_GM_00000193
2017.08.02
EFTA_00114277
EFTA01262910

the Search Team that the Third Party had not opened the suitcases or touched or tampered with
their contents. The Third Party also agreed to deliver the two suitcases to the Search Team.
d. Later on July 11, 2019, and consistent with the conversation described
above, the Third Party met the Search Team outside of the New York Residence and provided
446.
Sc
RS\ O.\ SPimmt with the two suitcases described above, one of which was blue and one of which was black.
Consistent with standard law enforcement protocol, the Search. Team conducted an inventory of
both suitcases before taking custody of them. While taking an inventory of the blue suitcase, the
Search Team discovered, among other items, Subject Item-3, Subject Item-4, and Subject Item-5.
While taking an inventory of the black suitcase, the Search Team discovered, among other items,
Subject Item-6. These items, i.e., Subject Items -3, -4, -5, and -6, appeared to be the same items
observed in the Safe by the Search Team during the July 7, 2019 search of the New York
Residence.
The 2018 Payments
25. Based on my participation in this investigation, my review of open source materials,
and my review of financial records, I have further learned the following:
a. On or about November 28, 2018, the Miami Herald began publishing a
series of articles related to JEFFREY EPSTEIN, his sex trafficking of minor girls, and the
circumstances of a non-prosecution agreement ("NPA") he previously negotiated with the
Southern District of Florida. Among other things, the NPA identified several individuals as
EPSTEIN's co-conspirators in the sex trafficking of minor girls.
b. Records obtained by the Government from a financial institution
(Institution-1") appear to show that just two days after the Miami Herald began publishing its
series,. on or about November 30, 2018, the defendant wired $100,000 from a trust account he
CONFIDENTIAL SONY_GM_00000194
2017.08.02
EFTA_00114278
EFTA01262911

controlled to an individual named as a possible co-conspirator in the NM. The same records from
Institution-1 appear to show that just three days after that, on or about December 3, 2018, the
defendant wired $250,000 from the same trust account to another individual named as a possible
co-conspirator in the NPA and also identified as one of the defendant's employees in the
Indictment. Neither of these payments appears to be recurring or repeating during the
approximately five years of bank records presently available.
c. This course of action, and in particular its timing, suggests the defendant
was still in communication with and attempting to further influence co-conspirators who might
provide information against him in light of the recently re-emerging allegations.
Request to Search the Subiect Items
26. Based on my training and experience and participation in this investigation, I
respectfully submit that there is probable cause to believe that the Subject Items will contain and/or
constitute additional fruits, evidence and instrumentalities of the Subject Offenses. As an initial
matter, all of the Subject Items were initially found in the same Safe in which EPSTEIN was
storing discs and other media already reviewed and which contain hundreds of not thousands of
nude and suggestive images of young females, some of whom appear to be under 18. Given as
much, and because there is probable cause to believe that Epstein engaged in sex trafficking of
underage girls, there is probable cause to believe that the additional storage media in EPSTEIN's
possession and control—Le., the Subject Items—will contain evidence of the Subject Offenses.
Moreover, that efforts were made to remove Subject Items -3, -4, -5, and -6 from the New York
Residence after the initial search only further reinforces the probable cause to believe that those
Subject Items contain and constitute fruits, evidence and instrumentalities of the Subject Offenses.
CONFIDENTIAL SDNY_GM_00000195 '
2017.08.02
EFTA_00114279
EFTA01262912

27. With respect to Subject Item-1 and Subject Item-2, both are electronic devices
capable of sending, receiving, and containing thousands of messages and images. Based on my
training and experience, I am aware that individuals who store nude and/or sexually suggestive
photographs of minors on compact discs or other external storage devices typically access those
images from computers and other electronic devices in order to view those images, and individuals
who store such materials on compact discs typically store similar files on other computing devices
and storage devices like Subject Item-1 and Subject Item-2. Further, in light of the payments to
potential co-conspirators described in paragraph 25, above, I respectfully submit there is probable
cause to believe that EPSTEIN still communicates with at least some of his co-conspirators about
the Subject Offenses and that such communications may occur using Subject Item-1 and Subject
Item-2.
28. I further know from my training and experience that computer files or remnants of
such files can be recovered months or even years after they have been created or saved on an
electronic device such as the Subject Items. Even when such files have been deleted, they can
often be recovered, depending on how the device has subsequently been used, months or years
later with forensics tools. Thus, the ability to retrieve from information from the Subject Items
depends less on when the information was first created or saved than on a particular user's device
configuration, storage capacity, and computer habits.
29. Based on the foregoing, I respectfully submit there is probable cause to believe that
evidence of JEFFREY EPSTEIN's commission of the Subject Offences is likely to be found on
the Subject Reins..
CONFIDENTIAL SONY_GM_00000196
2017.08.02
•
EFTA_00114280
EFTA01262913

III. Procedures for Searching ESI
A. Review of ESI
30. Law enforcement personnel (who may include, in addition to law enforcement
officers and agents, attorneys for the government, attorney support staff, agency personnel
assisting the government in this investigation, and outside technical experts under government
control) will review the ESI contained on the Subject Items for information responsive to the
warrant
31. In conducting this review, law enforcement 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 investigation4; and
• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
4
Keyword cenrches 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.
14
CONFIDENTIAL SONY_GMj00000197
2017.08.02
EFTA_00114281
EFTA01262914

32. 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 may need to conduct a complete review of all the ESI
from the Subject Items to evaluate its contents and to locate all data responsive to the warrant.
B. Return of the Subject Items
33. If the Government determines that. the Subject Items are no longer necessary to
retrieve and preserve the data on the Subject Items, and that the Subject Items are not subject to
seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return the
Subject Items. Computer data that is encrypted or unreadable will not be returned
unless law enforcement personnel have determined that the data is not (i) an instrtnnentality of the
offense, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed,
or (v) evidence of the Subject Offenses.
CONFIdENTIAL SDNY_GM_00000198
2017.08.02
EFTA_00114282
EFTA01262915

IV. Conclusion and Ancillary Provisions
34. Based on the foregoing, I respectfully 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.
35. In light of the confidential nature of the continuing investigation, I respectfully
request that this affidavit and all papers submitted herewith be maintained under seal until the
Court orders otherwise.
Special Agent
Federal Bureau of Investigation
Swom to before me on ,L 1 5 2019'
July /5- 2019
/C-e-tri, -FataL-eq÷
HON. KEVIN NATHANIEL FOX
UNITED STATES MAGISTRATE JUDGE
CONFIDENTIAL SDNY_GM_00000i99
2017.08.02
EFTA_00114283
EFTA01262916

Attachment A
I. Items Subject to Search and Seizure
The Subject Items are particularly described as follows':
• A black iPhone with IMEI number 357201093322785, which was seized from
JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-1").
• A silver iPad with serial number DLXQGM3KOMW3, which was seized from
JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-2").
• Two black binders with CDs, which were seizedkom a blueA suit4ca1se (o4n o r about 444
aseeL'ce
July 11, 2019 ("Subject Item-3").
23M
• Two black hard drives, which were seizes from a b ue suitrn on or ut y ,
/VA+
2019 ("Subject Item-4").
l)t:\ Creit0.1
• A box of CDs, which was seizediem a Blue suitcase on or about Y ,
("Subject Item-5"). SrecaA
b.) i\lAt-
L.
• Two binders with various CDs, which were seizeckfrom a black suitcase on or about A
July 11, 2019 ("Subject Item-6"). 5fee,0,1 Aajni-
II. Review of ESI on the Subject Items
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Items for 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:
1. 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. Records, data, or other items that evidence ownership, control, or use of, or access
to the Subject Items, including, but not limited to access history data, historical location data,
To the extent that the Subject Items contain any SD cards or other removable storage media, the
description of each such item encompasses those SD cards and other media.
2017.08.02 CONFIDENTIAL SDNY_GM_00000200
EFTA_00114284
EFTA01262917

configuration files, saved usernames and passwords, user profiles, e-mail contacts, and
photographs;
5. 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).
As to Subject Item-1 and Subject Item-2, Law enforcement personnel (who may include,
in addition to law enforcement officers and agents, attorneys for the government, attorney support
staff, agency personnel assisting the government in this investigation, and outside technical experts
under government control) are further authorized to review the ESI contained on Subject Item-1
and Subject Item-2 for 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:
1. Any documents or communications with or regarding co-conspirators in the Subject
Offenses.
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 ffie-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 investigation; 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 U
of this Attachment. However, law enforcement personnel are 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.
CONFIDENTIAL SDNY_GM_00000201
2017.08.02
EFTA_00114285
EFTA01262918

EXHIBIT A
2017.08.02 CONFIDENTIAL -- ---
EFTA,I14.286
EFTA01262919

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
SEALED
UNITED STATES OF AMERICA INDICTMENT
19 Cr.
19 CREW 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
S0NY_GM_00000203
CONFIDENTIAL
EFTA 00114287
EFTA01262920

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
CONFIDENTIAL SONY_GM_00000204
EFTA_00114288
EFTA01262921

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 Now 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
0. 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.
CONFIDENTIAL SDNYLGM_00000205
EFTA _00114289
EFTA01262922

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
CONFIDENTIAL SONY_GM_00000206 •
EFTA 00114290
EFTA01262923

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 additionil
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
CONFIDENTIAL SONY_GM_00000207
EFTA_00114291
EFTA01262924

encounters through Employee-1, who sometimes asked the
recruiters to bring a specific minor girl for 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
CONFIbENTIAL SONY_GM_00000208
EFTA_OOI14292
EFTA01262925

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 victi • m in cash. Victims typically were paid hundreds
of dollars for each encounter.
17. JEFFREY EPSTEIN, the defendint, 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.
CONFIDENTIAL SDNY_GM_00000209
EFTA_00114293
EFTA01262926

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 ALLEGATIONS
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
CONFIDENTIAL SDNY_GM_00000210
EFTA_001 14294
EFTA01262927

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 iin 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
CONFIDENTIAL SDNY_GM_00000211
EFTA _(X/114295
EFTA01262928

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.
CONFIDENTIAL SDNY_GM_00000212
EFTA 001142%
EFTA01262929

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 2.2 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
CONFIDENTIAL
SDNY_GM_00000213
EFTA_00114297
EFTA01262930

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 list Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
CONFIDENTIAL SDNY_GM_00000214
EFTA_OOI14298
EFTA01262931

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.)
@tt
GEOFFR Y . BERMAN
United States Attorney
CONFIDENTIAL SDNY_GM_00000215
EFTA_0011,1299
EFTA01262932

Form No. USA-335-274 (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. S§ 371, 1591(a), (b)( 2),
and 2)
GEOFFREY S. BERMAN
United States Attorney
CONFIDENTIAL SDNY_GM_00000216
EFTA_00114300
EFTA01262933

EXHIBIT B
2017.08.02
CONFIDENTIAL
SDNY-GM 17
EFTA_00114301
EFTA01262934

Mal AO 442 (09/13) ArtestWerant AUSA Namo & Wino: Alison Moe, 212-637-2225
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
v.
19CRIM 490 '
Jeffrey Epstein
Ebirendant
ARREST WARRANT
To: Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name ofp rison to be arrested) Jeffrey Epstein
who is accused of an offense or violation based on the following document filed with the court
RC Indictment O Superseding Indictment O Infomration. O Superseding Information O Complaint
O Probation Violation Petition ID SuperVised Release Violation Petition O Violation Notice O Order of the Court
This offense is briefly described as follows:
Title 18, United States Code, Section 371 (sex trafficking conspiracy) 'ram), a
Title 18, United States Code, Sections 1591(a), (bX2), and (2) (sex trafficking of minors) soc r , • . ,st i rt i j 1
t \• • . • , .•
Date: 07/02/2019
City and state: New York, NY The Honorable Barbara Mosek. MagiStrate Judge
Printedname andM k
Return
This warrant was received on (dare) , and the person was arrested on (date)
at MOt ands tate)
Date:
Arresting officer s stgrernms
Printedm ine andM k
CONFIDENTIAL SDNY_GM00000218
EPTA_00114302
EFTA01262935

EXHIBIT
2017.08.02
CONFIDENTIAL
SONY-GM'''''
EFTA_00114303
EFTA01262936

AO93 (SDNY Rev. 0U17) Scorch end Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of Now York
In the Matter of the Search of
(Briefly describe the property to be searched
or :den* the person by name and address) 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 Soighom District of Now York
(Wen* the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal Wen* the person or describe the property
to be seixec9: .
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
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 persion or
PropertY.
YOU ARE COMMANDED to execute this warrant on or before I- • to - lei
(not to meal 14 days)
in the daytime 6:00 am. to 10 p.m. O at any time in the day or night as I fmd 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 the Court
MAO Initials
O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) Ofor days (not to exceed 30).
Ountil, the facts justifying,~ho.latsr specific date of
1-- 6. l`k 1O1A c14/ • iA •
Date and time issued:
Judge's signature
City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge
ONFIDENTIA
t ame and we SDNY_GM_00000220
C
EFTA_00114304
EFTA01262937

AO 93 (SDNY Rev. 01117) Search sod Seizure Warrant (Page 2)
Return
Case No.: Date and time 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:
Faseuthtg cificer's signature
Printed name and title
CONFIDENTIAL SDNY_GM_00000221
EFTA_OOI14305
EFTA01262938

ATTACHiVBENT A
L Premises to be Searched—Subject Premises
1. The premises to be searched (the "Subject Premise?) are described as a nearly
19,000 square foot 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:
IL Items to Be Seized
1. This warrant authorizes executing agents to photograph, video record and otherwise
document the full interior of the Subject Premises, including any items, furnishings, or possessions
therein.
• 2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sox trafficking of
minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy or ownership of the Subject Premises,
including utility and telephone bills, mail envelopes, addressed correspondence,
diaries, statements, identification documents, address books, telephone
directories, and photographs of its occupant(s).
b. Evidence concerting the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2017.08.02
CONFIDENTIAL SDNY_GM_00000222
EFTA_00114306
EFTA01262939

EXHIBIT D
201708 D1 CONFIDENTIAL ----
EFTA 00116307
EFTA01262940

AO 93 (SDNY Rev. 01/17)Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
or ideal°, the person by name and address) 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
(identify the person or describe the property to be searched and give lit location):
See Attachment A
The person or property to be searched, described above, is believed to conceal memo the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations).
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
property.
July 7, 2019
YOU ARE COMMANDED to execute this warrant on or before
(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 the Court.
USALI Initials
O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) Ofor days (not to exceed 301
Ountil, the facts justifyi later specific date o
a 1 - ‘ct 2_p?aa.µ .
Date and time issued:
Judge's signature
City and state: New York. NY Hon. Barbara Moses, U.S. Malitrate Judge
Printed name and title
SONY_GM_00000224
CONFIDENTIAL
EFTA_00 I 14308
EFTA01262941

AO 93 (SDNY Rev. 0111 7) Search and Seizure Warrani (Page 2)
Return
Case No.: Date and time 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
1 declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date: ___ _ _..._
Erectility officer's signatum
Printed name and dile
CONFIDENTIAL SDNY_GM_00000225
EFTA_00114309
EFTA01262942

ATTACHMENT A
I. Premises to be Searched—Subject Premises
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:
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 and all taxidennied 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
CONFIDENTIAL SONY_GM_00000226
EFTA_00114310
EFTA01262943

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
CONFIDENTIAL SDNY_GM_00000227
EFTA_001 14311
EFTA01262944

EXHIBIT E
CONFIDENTIAL -----
EFTA,I1012
EFTA01262945

AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address) 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 _ftectiOdt
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal hdentifir the person or describe the property
to be seized):
See Attachment A
The search and seizure arc related to violation(s) of (insert statutorycitations):
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
property.
YOU ARE COMMANDED to execute this warrant on or before July 21, 2019
(not to exceed /4 days)
lit
O in the daytime 6:00 a.m. to 10 p.m. at any time in the day or night as 1 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 the Court.
USMJ initials
O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate bar) Ofor __ days (not to exceed 301.
Ountil, the facts justifying, the later specific date of
1:1- tk. '%‘").04
Date and time issued:
Ju signature
aAr, u.sS. EStRite
City and state: New York, NY FIDE HRM CiNtS0229
nante and fide
CON
EFTA_00114313
EFTA01262946

A093 (SONY Rev. 01/17)Search Dad Scinre Warrant (Page 2)
Return
Case No.: Date and time 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: _____ ___
Executing officer 's signature
printed name and title
SONY_GM_00000230
CONFIDENTIAL
EFTA_00 I 14314
EFTA01262947

ATTACHMENT A
I. 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.
11. 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:
1. 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
usernames 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:
2017.08.02
CONFIDENTIAL SDNY_GM_00000231
EFTA_00114315
EFTA01262948

• 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 investigation's; 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
ILA of this Attachment. However, law enforcement personnel are 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.
2
2017.08.02
CONFIDENTIAL SDNY_GM_00000232
EFTA_00114316
EFTA01262949

EXHIBIT F
CONFIDENTIAL -- --
EFT.9,11017
EFTA01262950

AO 93 (SDNY Roc 01117)Search sieSerovoVirenue
UNITED STATES DISTRICT COURT
for the
Southern District of New Irk 9 MAG 6 4 3 9
In the Matter of the Search of )
(Briefly describe the property to be searched )
or identify the person by name and address) ) Case No. 19 Cr. 490 (RMB)
)
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
(dentifr the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal °den* the person or describe the property
to be seine,:
See Attachment A
The search and seizure are related to violation(s) of (Insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I fed that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
proper tY-
July 12, 2019
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
$1 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
k 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 the Court
USWI nitials
0 I fed that immediate notification may have an adverse result listed in 18.1,1,Sas § pos (except for delay
of trial), and authorize the officer executing this warrant to delay notice to theptuolaNitho,,oy ki.hose property, will be
searched or seized (Check the appropriate boa) Ofor days (not to exceetti0),:, • • . • . • . .
Ountil, the facts justifying, the'lite0Pecific dale of
iy;$4.10ATY?1
Date and time issued: —7 /till el
Fiat,
City and state: New York, NY tin an U:S'M Istraktfhtipdatcoonnrm
EFTA_00 I 14318
EFTA01262951

AO 93 (SDNY Rev. °Urn Sara and Seizure warms (Page 2)
Return
Case No.: Date and time warrant executed: Copy'of wanint 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:
&twang officer's *nature
Printed name and title
CONFIDENTIAL SON Y_G M_00000235
EFTA_00 I 14319
EFTA01262952

ATTACHMENT A
X. 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:
U. 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:
The items to be seized from the Subject Premises are any computer devices and storage
media that may contain any electronically stored information falling within the categories set forth
in Section B of this Attachment, inoluding, but not limited to, desktop and laptop computers, disk
drives, modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners,
routers, modems, and network equipment used to connect to the Internet. In lieu of seizing any
such computer devices or storage media, this warrant also authorizes, in the alternative, the
copying of such devices or media for later review.
The items to be seized from the Subject Premises also include:
CONFIDENTIAL SDNY_GM:00000236
2017.08.02
EFTA_00114320
EFTA01262953

1. Any items or records needed to access the data storedon any seized or copied
computer devices or storage media, including but not limited to any physical keys, encryption
devices, or records of login credentials, passwords, private encryption keys, or similar information.
2. Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or software manuals or other information
concerning the configuration of the seized or copied computer devices or storage media.
3. Any evidence concerning the identities or locations of those persons with access to,
control over, or ownership of the seized or copied computer devices or storage media.
B. Scarab and Seizure of Electronically Stored Information
As set forth in Section A to this attachment, this warrant authorizes the search of the Subject
Premises for any computer devices and storage media that may contain any electronically stored
information falling within the categories set forth below:
4. Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
5. Any photographs of victims or potential victims of the Subject Offenses;
6. Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger;
7. 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
usernames and passwords, user profiles,-e-mail contacts, and photographs;
8. 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).
C. Review of ESI
Law enforcement personnel (including, in addition to law enforcement officers and agents,
and depending on the nature of the HSI 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, that is, for the materials specified in Section B of this Attachment.
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other BSI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
CONFIDENTIAL . SDNY_GM_00000237
2017.0&02
EFTA_00114321
EFTA01262954

• 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
ILA of this Attachment. However, law enforcement personnel are authorized to conduct a
complete review of all the BSI 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.
CONFIDENTIAL SONY_GM_00000238
2017.08.02
EFTA_00 I 14322
EFTA01262955