Text extracted via OCR from the original document. May contain errors from the scanning process.
AO 1 16 • SDNY Rev. 01/17) Application for a Search Warrant
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. 20 MAG 6719
2 electronic devices seized on July 6, 2019 from Jeffrey Epstein))
33 electronic devices seized on July 11, 2019 from 9 East 71st )
Street, New York, NY; 27 electronic devices seized on August )
12, 2019 from Little Saint James in the Virgin Islands
I, 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 (identify the person or describe the
property to be searched and give its location):
located in the
Southern
District of
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
New York
, there is now concealed (identify the
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
Ca evidence 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)
18 U.S.C. 1591
Sex Trafficking
18 U.S.C. 2422
Enticement to Travel
18 V.S.C. 2423
Transportation of Maws
18 U.S.C. 371
Conspiracy to Commit Sex Traffickeig. Enticement to Travel, and Transportation of Mnors
The application is based on these facts:
See Attached Affidavit and its Attachment A
g Continued on the attached sheet.
O Delayed notice of
days (give exact ending date if more than 30 days:
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.
Sworn to before me and signed in my presence.
Date:
06/26/2020
City and state: New York, NY
sworn via telephone
Applicant's signature
Task Force Officer, FBI
) is requested
Printed name and title
_500
to.
likAlle" --
Judge's signature
Hon. Gabriel W. Gorenstein, U.S. Magistrate Judge
Print
Save As...
Printed name and title.
Reset
EFTA00076712
In the Matter of the Application of the United
States Of America for a Search and Seizure
Warrant for 2 electronic devices seized on July 6,
2019 from Jeffrey Epstein; 33 electronic devices
seized on July 11, 2019 from 9 East 71st Street,
New York, NY; 27 electronic devices seized on
August 12, 2019 from Little Saint James in the
Virgin Islands.
20 MAG 6719
Agent Affidavit in Support of
Application for Search and Seizure
Warrant
SOUTHERN DISTRICT OF NEW YORK) ss.:
being duly sworn, deposes and says:
I. Introduction
A. Affiant
I.
I have been a Task Force Officer with the Federal Bureau of Investigation ("FBI")
since 2017. As such, I am a "federal law enforcement officer within the meaning of Federal Rule
of Criminal Procedure 41(a)(2)(C), 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 also a detective
with the New York Police Department ("NYPD") and have been employed by the NYPD for
approximately fourteen years. I am currently assigned to investigate violations of criminal law
relating to the sexual exploitation of children as part of an FBI Task Force. 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 cases involving sex
trafficking, enticement of minors, and transportation of minors for illegal sex acts, and have
participated in the execution of search warrants for electronic devices and 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 electronic devices specified below (the
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EFTA00076713
"Subject Devices") 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 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 Devices
3.
The Subject Devices were all recovered during the course of the FBI's investigation
into JEFFREY EPSTEIN and his associates.
4.
Two of the Subject Devices were seized from JEFFREY EPSTEIN's person
during the course of his arrest by the FBI on or about July 6, 2019 (the "Arrest Subject Devices").
The Arrest Subject Devices are particularly described as follows:
a. A silver iPad with serial number DLXQGM3KGMW3 ("Subject Device-1"); and
b. A black iPhone with IMEI number 357201093322785 ("Subject Device-2").
5.
33 of the Subject Devices were seized during a search of JEFFREY EPSTEIN's
private residence located at 9 East 71st Street, New York, New York, which took place on July 11,
2019 (the "New York Subject Devices"). The New York Subject Devices are particularly
described as follows:
a. Two black hard drives, which were seized by Special Agent Kelly Maguire from a
blue suitcase on or about July 11, 2019 ("Subject Device-3");
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b. An Apple desktop computer, which was seized from in a cardboard box along the
right wall of a room on the first floor of the New York Residence, and which has
been assigned internal FBI barcode number E65 15034 ("Subject Device-4");
c. A silver iPad, which was seized from a shelf in the right corner of a room on the
third floor of the New York Residence under a television, and which has been
assigned internal FBI barcode number E65 15033 ("Subject Device-5");
d. A gray Apple iPad, which was seized from under a sink in a room on the third floor
of the New York Residence, and which has been assigned internal FBI barcode
number E65 15032 ("Subject Device-6");
e. A gray Apple iPad, which was seized from under a sink in a room on the third floor
of the New York Residence, and which has been assigned internal FBI barcode
number E6515031 ("Subject Device-7");
f. A Sony Vaio laptop, which was seized from inside a desk drawer in the drawing
room on the second floor of the New York Residence, and which has been assigned
internal FBI barcode number E65 15026 ("Subject Device-8");
g. A Dell Precision Tower 5810, which was seized from a storage area in the basement
of the New York Residence, and which has been assigned internal FBI barcode
number E65 15025 ("Subject Device-9");
h. A Seagate Barracuda 7200 hard drive, which was seized from a storage area in the
basement of the New York Residence, and which has been assigned internal FBI
barcode number E65 15024 ("Subject Device-10");
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i. A MSI PC Computer, which was seized from a storage area in the basement of the
New York Residence, and which has been assigned internal FBI barcode number
E65 15023 ("Subject Device-11");
j. A Sony Camera with a black case, which was seized from in a drawer inside a room
on the sixth floor of the New York Residence, and which has been assigned internal
FBI barcode number E65 15022 ("Subject Device-12");
k. A gray Apple desktop computer, which was seized from a desk inside a room on
the sixth floor of the New York Residence, and which has been assigned internal
FBI barcode number E6515021 ("Subject Device-13");
I. A Seagate Backup Plus portable drive, which was seized from a shoebox on top of
a desk in a room on the fifth floor of the New York Residence, and which has been
assigned internal FBI barcode number E65 15020 ("Subject Device-14");
m. A white Apple iPhone 5, which was seized from the lower left shelf of a white
wooden cabinet in a room on the fifth floor of the New York Residence, and which
has been assigned internal FBI barcode number E6515019 ("Subject Device-15");
n. An Apple desktop computer, which was seized from on top of a desk inside the
drawing room on the second floor of the New York residence, and which has been
assigned internal FBI barcode number E6515018 ("Subject Device-16");
o. An Apple desktop computer, which was seized from on top of a desk in a mom on
the fifth floor of the New York Residence, and which has been assigned internal
FBI barcode number E6515017 ("Subject Device-17");
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p. A SPIEF 2014 silver USB, which was seized from a cabinet on the back wall of a
storage closet on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E65 15016 ("Subject Device-18");
q. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515015 ("Subject Device-19");
r. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E65 15014 ("Subject Device-20");
s. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515013 ("Subject Device-21");
t. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515012 ("Subject Device-22");
u. A blue EMTEC USB, which was seized from a small tray on the floor of the dining
room on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E651501 I ("Subject Device-23");
v. An EMTEC USB, which was seized from a small tray on the floor of the dining
room on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515010 ("Subject Device-24");
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w. A silicone power micro SD adaptor, which was seized from a drawer inside a table
in the dining room on the First Floor of the New York Residence, and which has
been assigned internal FBI barcode number E65 15008 ("Subject Device-25");
x. A DELL Machine, which was seized from a desk in a room on the first floor of the
New York Residence, and which has been assigned internal FBI barcode number
E6515007 ("Subject Device-26");
y. A Cube 9000 Siteserver, which was seized from a desk in a room on the first floor
of the New York Residence, and which has been assigned internal FBI barcode
number E65 15006 ("Subject Device-27");
z. An HP Compaq Machine, which was seized from a desk in a room on the first floor
of the New York Residence, and which has been assigned internal FBI barcode
number E65 15005 ("Subject Device-28");
aa. A Mentor Media USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E65 15004 ("Subject Device-29");
bb. A Data Traveler USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E65 15003 ("Subject Device-30");
cc. A Data Traveler USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E6515002 ("Subject Device-31");
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EFTA00076718
dd. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E65 15001 ("Subject Device-32");
ee. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E65 15000 ("Subject Device-33");
ff. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433827 ("Subject Device-34"); and
gg. A silver Apple desktop computer, which was seized from a desk in an oval study
on the first floor of the New York Residence, and which has been assigned internal
FBI barcode number E6433828 ("Subject Device-35").
6.
27 of the Subject Devices were seized during a search of a private island in the U.S.
Virgin Islands, known as Little Saint James, which is an approximately 75 acre island located
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands
Residence") on or about August 12, 2019 (the "Virgin Islands Subject Devices"). The Virgin
Islands Residence consists of multiple structures, including a main residence as well as several
other smaller structures on the island, including a pool house, sheds, a beach house, an office, and
multiple cabanas. However, as detailed below, JEFFREY EPSTEIN, who was a Target Subject
of this Investigation until his death in August 2019, is the only known occupant of the Virgin
Islands Residence. The Virgin Island Subject Devices are particularly described as follows:
a. A gray Mac desktop computer labeled "kitchen mac", which was recovered from
a desk in the main residence on the island ("Subject Device-36");
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EFTA00076719
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89111772QT,
which was recovered from a desk in the main residence on the island ("Subject
Device-37");
c. A silver MacBook Pro bearing serial number c02qmOgugwdp, which was
recovered from a desk in the main residence on the island ("Subject Device-38");
d. A silver iPad model A1567 bearing serial number dmpq125ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-39");
e. A silver iPad model A1567 bearing serial number dmpqL1rmg5y, which was
recovered from a desk in the main residence ("Subject Device-40");
f. A silver Mac desktop computer bearing serial number cO2nm I mOfy14, which was
recovered from a desk in the pool house on the island ("Subject Device-41");
g. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-42");
h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a
shed on the island ("Subject Device-43");
i. An HP laptop bearing serial number cnd8 I 368v5, which was recovered from a desk
in a shed on the island ("Subject Device-44");
j. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-45");
k. A silver Macbook desktop computer, which was recovered from a desk in a cabana
on the island ("Subject Device-46");
I. A Dell Inspiron Tower computer model D19M QCNFA335, which was recovered
from a desk in the beach house on the island ("Subject Device-47");
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m. A silver Mac desktop computer model A1311 bearing serial number
W804736DDAS, which was recovered from a desk in the beach house on the island
("Subject Device-48");
n. A Unfi video bearing mac ID 1829f b4fbe426ea90, which was recovered from a
server rack inside a shed on the island ("Subject Device-49");
o. A Unifi Server bearing mac ID 1735K 788A20463234-8uuu9f, which was
recovered from a server rack inside a shed in on the island ("Subject Device-50");
p. An HP server with four 500 GB drives, bearing serial number MXQ3220187, which
was recovered from a shed on the island ("Subject Device-51");
q. A Panasonic KX TDE100 computer bearing serial number 1OC-TDa0104
9LCCD005398, which was found on a server rack in a shed on the island ("Subject
Device-52");
r. A 6 bay with 146 GB drives bearing serial number MXQ824A1R, which was found
on a server rack in a shed on the island ("Subject Device-53");
s. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-54");
t. An HP desktop tower model 260-A010, bearing serial number cnv7160050, which
was recovered from the maintenance office on the island ("Subject Device-55");
u. An HP tower model 260-A010, bearing serial number cnv716004y, which was
recovered from the maintenance office on the island ("Subject Device-56");
v. A Mac desktop computer model A1312, bearing serial number w89524czspj, which
was recovered from the maintenance office on the island ("Subject Device-57");
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w. A Lenovo tower machine type 90J0, bearing serial number mj07yg6u, which was
recovered the maintenance office on the island ("Subject Device-58");
x. A Lenovo tower bearing serial number 153306g2umjxekgx, which was recovered
the maintenance office on the island ("Subject Device-59");
y. An HP Tower bearing serial number CNV74213M3 570-P056, which was
recovered the maintenance office on the island ("Subject Device-60");
z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID
1843kb4fbe4d30c69-dcrgm9, which was found on a server rack in a shed on the
island ("Subject Device-61"); and
aa. A red Nikon digital camera, which was recovered on a file cabinet next to a desk in
a cabana on the island ("Subject Device-62").
7.
Subject Device-1 through Subject Device-11 and Subject Device-13 through
Subject Device-60 are all computers and/or storage devices capable of storing electronic picture
and message files.
8.
Subject Device-61 is a device that identifies a user to a service over the Internet. It
acts as a key that allows users to access other data on other devices, such as Subject Device-1
through Subject Device-11 and Subject Device-13 through Subject Device-60.
9.
Subject Device-12 and Subject Device-62 are both digital cameras capable of
taking and storing electronic picture files.
10.
The Subject Devices have all been transported by the FBI to FBI offices in the
Southern District of New York. At this time, all of the Subject Devices are presently located in
the Southern District of New York.
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EFTA00076722
C. The Subject Offenses
11.
As detailed herein, all of the Subject Devices have been the subject of prior search
warrant applications, each of which has been granted and has authorized their search of evidence,
fruits and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex
trafficking of minors) and 371 (conspiracy to commit sex trafficking) (the "Original Subject
Offenses.")
12.
For the reasons detailed below, I believe that there is also probable cause to
believe that the Subject Devices contain evidence, fruits, and instrumentalities of additional
violations of criminal law, including violations of Title 18, United States Code, Sections 2422
(transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to commit
transportation of minors and enticement to travel) (the "Additional Subject Offenses"). The
Target Subjects of this investigation are known and unknown co-conspirators of JEFFREY
EPSTEIN, including but not limited to
II. Probable Cause and the Initial Search Warrants
and GHISLAINE MAXWELL.
A. Probable Cause Regarding the Target Subjects' Commission of the Original
and Additional Subject Offenses
13.
On or about July 2, 2019, a grand jury in the Southern District of New York 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. 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.
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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
jet that flew from France and landed at approximately 5:30 p.m. in Teterboro Airport in Bergen,
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 Device-1 and Subject Device-2 in EPSTEIN's possession. The CBP agents
then provided Subject Device-1 and Subject Device-2 to Special Agents of the FBI who also placed
EPSTEIN under arrest. The FBI subsequently transported Subject Device-1 and Subject Device-
2 to FBI offices located in the Southern District of New York, where they are currently located.
15.
Following his arrest, JEFFREY EPSTEIN was detained pending trial at the
Metropolitan Correctional Center ("MCC") in New York, New York. On or about August 10,
2019, the Bureau of Prisons confirmed that EPSTEIN had been found unresponsive in his cell at
the MCC that morning, and was pronounced dead shortly thereafter.
16.
Notwithstanding JEFFREY EPSTEIN's death, the investigation that led to his
indictment remains ongoing. In particular, that investigation has identified additional criminal
activity beyond that outlined in the indictment, as well as at least two potential co-conspirators:
and GHISLAINE MAXWELL.
17.
Count One of the Indictment alleged that JEFFREY EPSTEIN conspired with
others to traffic minors, and further identified three individuals who worked for EPSTEIN
(identified in Exhibit A as "Employee-1", "Employee-2," and "Employee-3") and facilitated
EPSTEIN's abuse of minor girls by, among other things, arranging victims' encounters with
EPSTEIN and paying victims after these encounters. The individual identified in Exhibit A as
"Employee-2" is
a Target Subject of the ongoing investigation.
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18.
On or about November 28, 2018, the Miami Herald began publishing a series of
articles relating to the defendant, his sexual misconduct with minors, and a previous investigation
into his conduct in Florida from in or about 2005 through 2008. The article included information
about
role in JEFFREY EPSTEIN's sexual abuse of minors. Based on my
participation in this investigation, I have learned that bank records obtained by the Government
appear to show that just days later, on or about December 3, 2018, the defendant wired $250,000
from a trust account to
This course of action, and in particular its timing, suggests that
EPSTEIN was attempting to influence
who might have been able to provide information
against him in light of the recently re-emerging allegations.'
19.
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 dozens of minor girls in Manhattan, New
York; West Palm Beach, Florida; and elsewhere. During that time and continuing to the present,
EPSTEIN possessed and controlled a residence, which is described in Exhibit A as "the New York
Residence."
20.
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, JEFFREY 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 New York 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
In or about November and December of 20 19,
participated in two proffer sessions with
the Government. During those meetings,
claimed that she did not believe the December
2018 payment was meant to influence her.
also claimed that she did not know that
EPSTEIN engaged in sex acts during massages and that she did not know that any of the females
who massaged EPSTEIN were underage. The Government did not find those statements credible.
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EFTA00076725
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.
21.
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.
22.
Since JEFFREY EPSTEIN's death, the FBI's ongoing investigation has also
revealed probable cause to believe that JEFFREY EPSTEIN's abuse of minor victims started
substantially before 2002, i.e., the starting point of the conduct alleged in the Indictment, and that
GHISLAINE MAXWELL helped to facilitate and participate in that abuse. In particular, and
among other things, the investigation has revealed that MAXWELL participated in the
transportation and enticement of at least one minor victim ("Minor Victim-1") for EPSTEIN to
sexually abuse. In particular, based on my personal participation in interviews with Minor Victim-
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EFTA00076726
1 and my review of notes and reports written by other law enforcement agents who interviewed
Minor Victim-1,2 I have learned the following:
a. Minor Victim-1 first met EPSTEIN and MAXWELL when Minor Victim-1 was
at summer camp in or about 1994. Minor Victim-1 was approximately 14 years old at the time
she met EPSTEIN and MAXWELL. Following that meeting, MAXWELL and EPSTEIN
attempted to befriend Minor Victim-1, taking her to the movies and on shopping trips.
MAXWELL also asked Minor Victim-1 about school, her classes, her family, and other aspects
of her life. Over time, MAXWELL began to normalize inappropriate and abusive conduct by,
among other things, undressing in front of Minor Victim-1 and being present when Minor
Victim-1 undressed in front of EPSTEIN. Within the first year after MAXWELL and EPSTEIN
met Minor Victim-1, EPSTEIN began sexually abusing Minor Victim-1. EPSTEIN sexually
abused Vicitm-1 on multiple occasions between 1994 and 1997. MAXWELL was present for
and involved in some of this abuse. In particular, MAXWELL involved Minor Victim-1 in
group sexualized massages of Epstein. During those group sexualized massages, MAXWELL
and/or Minor Victim-1 would engage in sex acts with EPSTEIN. EPSTEIN and MAXWELL
both encouraged Minor Victim-1 to travel to EPSTEIN's residences in both New York and
Florida. As a result, Minor Victim-1 was sexually abused by EPSTEIN in both New York and
Florida on multiple occasions when Minor Vicitm-1 was under the age of 18.
2 In or about January 2020, Vicitm-1 anonymously filed a civil lawsuit as a "Jane Doe" against
EPSTEIN's estate and MAXWELL seeking damages for the conduct described in this affidavit.
Information provided by Victim-1 has been corroborated by independent evidence, including other
witness statements and travel records, and has proven reliable.
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EFTA00076727
Searches of the New York Residence
23.
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 "First Search
Warrant"). The First Search Warrant is attached as Exhibit C and incorporated by reference herein.
24.
I know based on my conversations with other law enforcement officers and my
review of reports prepared by others that 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. JEFFREY EPSTEIN had been arrested on the charges contained in the
Indictment shortly before the execution of the search warrant. 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. On or
about July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search
warrant authorizing a search of the New York Residence (the "Second Search Warrant"). The
Second Search 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.
25.
Based on my conversations with members of the Search Team, I have learned the
following:
a. During the search, the Search Team located a room that contained a table covered
with a sheet, which appeared to be a massage table (the "Massage Room"). The walls of the
Massage Room appeared to be covered in a type of felt-like tapestry fabric. Two paintings and
three photographs, all depicting nude females, were hanging on the walls of the Massage Room.
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EFTA00076728
One of the photographs appeared to depict a nude girl, who appeared to be approximately 15 to 20
years old. The room also contained several vibrating sex toys.
b. The Search Team observed a number of computing devices, including computers
and tablet devices, throughout the New York Residence.
c. 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
' Another disc is labeled "Nudes 00-24." Another is
labeled "Misc. Nudes." Yet another is labeled "Girl Pics Nude." Some discs contain the word
"Zorro" or "LSJ." For example, one disc is marked
Zorro Pics." 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.
d. 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.
e. 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,
which contained numerous compact discs. The majority of the discs are labeled, in handwriting,
18
2017.08.02
EFTA00076729
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 Search
Team seized all of those discs. 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 girls who appear to be
teenagers, based on my training and experience. Inside the folder is a compact disc marked "Sue
at LIS 6/03," which was seized by the Search Team.
f. 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-M3"
The remaining
discs contain titles that include female names. All of the foregoing discs were seized by the Search
Team.
g. 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
3 The Search Team did not seize the remaining binders at that time.
19
2017.08.02
EFTA00076730
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.
26.
The compact discs seized by the Search Team and described in paragraphs 24(c)-(f)
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").
27.
On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a third search warrant to seize and search electronic media stored on the Seized Discs
(the "Third Search Warrant"). The Third Search Warrant is attached as Exhibit E, and incorporated
by reference herein.
28.
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. The discs also contained approximately hundreds of photographs of GHISLAINE
MAXWELL. Some of those photographs included MAXWELL partially nude. Some of those
20
2017.08.02
EFTA00076731
photographs include MAXWELL clothed with other clothed females who appear to be
approximately between the ages of 16 and 22.
29.
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.
30.
Following the initiation of the FBI's review of the Seized Discs, on or about July
II, 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
seizure and search of electronic devices and storage media inside the New York Residence for
evidence of the Original Subject Offenses (the "Fourth Search Warrant"). The Fourth Search
Warrant is attached as Exhibit F and incorporated by reference herein.
31.
Later on July 11, 2019, the Search Team executed the Fourth Search Warrant at the
New York Residence. Based on my conversations with members of the Search Team, I have
learned the following, among other things, regarding the execution of the Fourth Search Warrant:
a.
During the July 11, 2019 execution of the Fourth Search 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 paragraphs 24(c)-(f), above, that
the Search Team had not seized during its prior search of the New York Residence on July 7, 2019,
had been removed.
21
2017.08.02
EFTA00076732
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
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
them 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 Device-3. These items, including Subject
Item-3, 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.
32.
On or about July 14, 2019, the Honorable Kevin Nathaniel Fox, United States
Magistrate Judge, signed a search warrant authorizing the search of Subject Device-1, Subject
Device-2, and Subject Device-3 for evidence of the Original Subject Offenses (the "Fifth Search
22
2017.08.02
EFTA00076733
Warrant"). The Fifth Search Warrant is attached as Exhibit G and incorporated by reference
herein.
33.
Based on my personal participation in the searches of the New York Residence, as
well as my conversations with other law enforcement agents who participated in those same
searches, and my review of documents prepared by other law enforcement agents who participated
in those same searches, I have learned that during the July 11, 2019 search of the New York
Residence:
a. Subject Device-4 was recovered from in a cardboard box along the right wall of a
room on the first floor of the New York Residence, and has been assigned internal
FBI barcode number E6515034.
b. Subject Device-5 was recovered from a shelf in the right corner of a room on the
third floor of the New York Residence under a television, and has been assigned
internal FBI barcode number E651503.
c. Subject Device-6 was recovered from under a sink in a room on the third floor of
the New York Residence, and has been assigned internal FBI barcode number
E6515032.
d. Subject Device-7 was recovered from under a sink in a room on the third floor of
the New York Residence, and has been assigned internal FBI barcode number
E6515031.
e. Subject Device-8 was recovered from inside a desk drawer in the drawing room on
the second floor of the New York Residence, and has been assigned internal FBI
barcode number E6515026.
23
2017.08.02
EFTA00076734
f. Subject Device-9 was recovered from a storage area in the basement of the New
York Residence, and has been assigned internal FBI barcode number E6515025.
g. Subject Device-10 was recovered from a storage area in the basement of the New
York Residence, and has been assigned internal FBI barcode number E6515024.
h. Subject Device-11 was recovered from a storage area in the basement of the New
York Residence, and has been assigned internal FBI barcode number E6515023.
i. Subject Device-12 was recovered from a drawer inside a room on the sixth floor of
the New York Residence, and has been assigned internal FBI barcode number
E6515022.
j. Subject Device-13 was recovered from a desk inside a room on the sixth floor of
the New York Residence, and has been assigned internal FBI barcode number
E6515021.
k. Subject Device-14 was recovered from a shoebox on top of a desk in a room on the
fifth floor of the New York Residence, and has been assigned internal FBI barcode
number E6515020.
1. Subject Device-15 was recovered from the lower left shelf of a white wooden
cabinet in a room on the fifth floor of the New York Residence, and has been
assigned internal FBI barcode number E6515019.
m. Subject Device-16 was recovered from on top of a desk inside the drawing room
on the second floor of the New York residence, and has been assigned internal FBI
barcode number E6515018.
24
2017.08.02
EFTA00076735
n. Subject Device-17 was recovered from on top of a desk in a room on the fifth floor
of the New York Residence, and has been assigned internal FBI barcode number
E6515017.
o. Subject Device-18 was recovered from a cabinet on the back wall of a storage closet
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6515016.
p. Subject Device-19 was recovered from a cabinet on the back wall of a storage closet
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6515015.
q. Subject Device-20 was recovered from a cabinet on the back wall of a storage closet
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6515014.
r. Subject Device-21 was recovered from a cabinet on the back wall of a storage closet
on the first floor of the New York Residence, and which has been assigned internal
FBI barcode number E6515013.
s. Subject Device-22 was recovered from a cabinet on the back wall of a storage closet
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6515012.
t. Subject Device-23 was recovered from a small tray on the floor of the dining room
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6515011.
25
2017.08.02
EFTA00076736
u. Subject Device-24 was recovered from a small tray on the floor of the dining room
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6515010.
v. Subject Device-25 was recovered from a drawer inside a table in the dining room
on the First Floor of the New York Residence, and has been assigned internal FBI
barcode number E6515008.
w. Subject Device-26 was recovered from a desk in a room on the first floor of the
New York Residence, and has been assigned internal FBI barcode number
E6515007.
x. Subject Device-27 was recovered from a desk in a room on the first floor of the
New York Residence, and has been assigned internal FBI barcode number
E6515006.
y. Subject Device-28 was recovered from a desk in a room on the first floor of the
New York Residence, and which has been assigned internal FBI barcode number
E6515005.
z. Subject Device-29 was recovered from a desk in a room on the first floor of the
New York Residence, and which has been assigned internal FBI barcode number
E6515004.
aa. Subject Device-30 was recovered from a desk in a room on the first floor of the
New York Residence, and which has been assigned internal FBI barcode number
E6515003.
26
2017.08.02
EFTA00076737
bb. Subject Device-3I was recovered from a desk in a room on the first floor of the
New York Residence, and has been assigned internal FBI barcode number
E6515002.
cc. Subject Device-32 was recovered from inside a book shelf cabinet in an oval study
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6515001.
dd. Subject Device-33 was recovered from inside a bookshelf cabinet in an oval study
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6515000.
ee. Subject Device-34 was recovered from inside a bookshelf cabinet in an oval study
on the first floor of the New York Residence, and has been assigned internal FBI
barcode number E6433827.
ff. Subject Device-35 was recovered from a desk in an oval study on the first floor of
the New York Residence, and has been assigned internal FBI barcode number
E6433828.
Search of the Virgin Islands Residence
34.
Based on my review of property records, I believe that JEFFREY EPSTEIN has
been the owner of the Virgin Islands Residence since at least in or about 1998. In particular, it
appears that an entity named "L.S.J., LLC" held title to the Virgin Islands Residence from in or
about 1998. In or about 2011, L.S.J., LLC transferred title to the Virgin Islands Residence to an
entity named "Nautilus, Inc.," for $10. On the transfer paperwork, EPSTEIN signed as the "sole
member" of L.S.J., LLC and as the "president and sole beneficial owner" of Nautilus, Inc.
27
2017.08.02
EFTA00076738
35.
In addition, I believe that up until his arrest, the Virgin Islands Residence was
JEFFREY EPSTEIN's principal residence. In particular, I have reviewed sex offender registration
data, and have learned that, on or about June 17, 2019, EPSTEIN listed the Virgin Islands
Residence as his primary residence. At the time of EPSTEIN's arrest on or about July 6, 2019, I
and other law enforcement officers conducted an inventory search of EPSTEIN's personal effects,
and observed that EPSTEIN was carrying a driver's license that listed the Virgin Islands Residence
as EPSTEIN's home address.
36.
Based on my participation in this investigation, I have reason to believe that
EPSTEIN and his co-conspirators committed and/or maintained evidence of the Original and
Additional Subject Offences in and around the Virgin Islands Residence. Some of the evidence
of that conduct was recovered from the New York Residence. In particular, as described above,
compact discs seized from the New York Residence contain approximately thousands of nude or
partially nude photographs of girls or young women, many of which are in sexually suggestive
poses. Certain of these images appear to have been taken at a tropical location, and/or were labeled
"LSJ" either in the image file name, or on the compact disc that contained the image. Based on
the foregoing, I believe that a portion of the foregoing photographs appear to have been taken at
the Virgin Islands Residence. In addition, I have learned that some of the file names are marked
which are the initials of
Target Subject of the ongoing investigation.
As set forth below, I and other law enforcement agents have interviewed Individual-I,4 who has
In or about November 2019, Individual-1 filed a civil lawsuit against EPSTEIN's estate seeking
damages for the conduct described in this affidavit. Information provided by Individual-1 has been
corroborated by independent evidence, including other witness statements and travel records, and
has proven reliable.
28
2017.08.02
EFTA00076739
reported that ahotographed
her at the Virgin Islands Residence. Accordingly,
I believe that a portion of these photos may have been taken by
37.
Further, based on my conversations with law enforcement agents who have
conducted an initial review of the Seized Discs, I have learned the following:
a. Many of the photographs appear to be labeled with file names that include "LSJ,"
which I believe stands for Little St. James, which is the name of the Virgin Islands Residence.
b. As discussed above, photographs seized from the New York Residence appear to
depict nude or partially nude young girls, and a portion of those photos appear to have been taken
at the Virgin Islands Residence, based on the fact that (i) some of the photos appear to have been
taken in a tropical location, and (ii) some of the file names of the photographs and/or the labels
on the discs containing the files of nude or partially nude young girls in a tropical location are
marked "LSJ," i.e., the Virgin Islands Residence.
c. Among the photographs seized from the New York Residence, the Reviewing
Agents identified partially-nude photographs of a young girl, labeled with the name of Individual-
1. The photographs appear to depict Individual-1 on a beach in what appears to be a tropical
location similar to the landscape of the Virgin Islands Residence.
38.
In or about August 2019, I participated in an interview of Individual-1, with her
counsel present. Based on my personal observations, I believe that the photographs described in
Paragraph 29 depict Individual-1. I have also spoken with another law enforcement agent who
interviewed Individual-1 on a separate occasion in or about July 2019, with her counsel present.
During the course of these interviews, Individual-1 stated, in sum an substance that she met
EPSTEIN in 2003 when she was approximately 17, and that she travelled to several of EPSTEIN's
properties, including properties in New Mexico, Florida, and the U.S. Virgin Islands, i.e., the
29
2017.08.02
EFTA00076740
Virgin Islands Residence, before she turned 18. EPSTEIN paid for the trips, and would give
Individual-1 money and gifts while she traveled with him. During these trips, EPSTEIN sexually
abused and assaulted Individual-1 on approximately four different occasions, all of which occurred
before she turned 18. Individual-1 reported that EPSTEIN raped her during two of these incidents.
Indivdual-1 recalled that one or more of these instances of sexual abuse occurred on the Virgin
Islands Residence. Individual-1 further reported that, when she was approximately 17,
asked to photograph her, and did in fact photograph Individual-1 at the Virgin Islands
Residence.
39.
In or about August 2019, I and another law enforcement officer interviewed an
individual ("Individual-21 who regularly performed work for JEFFREY EPSTEIN as a contractor
at the Virgin Islands Residence from approximately 1999 to 2005 or 2006. Individual-2 reported
that, on several occasions, Individual-2 observed photographs of what appeared to be nude or
partially nude young girls in several locations throughout the main residence of the Virgin Islands
Residence. Individual-2 recalled a photograph depicting
and two girls, all three
of whom were topless; Individual-2 estimated that the two girls in the photograph appeared to be
approximately 15 or 16 years old. Individual-2 knew =to
be EPSTEIN's assistant at that
time.
40.
Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN,
I have learned that
traveled to the U.S. Virgin Islands at least approximately
once a month between October 2001 and November of 2005. These records do not include any
travel
may have taken on commercial airlines.
30
2017.08.02
EFTA00076741
41.
In or about October 2019, I and another law enforcement officer interviewed
another individual ("Individual-3")5 who travelled at JEFFREY EPSTEIN's invitation to the
Virgin Islands Residence on multiple occasions in or about 2006 and 2007 when Individual-3 was
approximately 21 years old. Individual-3 reported that EPSTEIN sexually assaulted Individual-3
on multiple occasions at the Virgin Islands Residence. Individual-3 also reported that during at
least some of her visits to the Virgin Islands Residence, GHISLAINE MAXWELL was present at
the Virgin Islands Residence. On multiple occasions at the Virgin Islands residence, MAXWELL
instructed Individual-3 and other young women to engage in sex acts with EPSTEIN. Among
other things, MAXWELL provided Individual-3 and other young women with specific instructions
regarding how to perform oral sex on EPSTEIN. MAXWELL told Individual-3 that Individual-3
was only at the Virgin Islands Residence to sexually please EPSTEIN. Individual-3 further
reported that some of the sex acts she engaged in with EPSTEIN involved other females who
appeared young and may have been under the age of 18, but whose age Individual-3 did not know.
42.
Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN
for the years 1998 through 2006, I have learned that GHISLAINE MAXWELL travelled to the
U.S. Virgin Islands at least approximately four times in 1998, eleven times in 1999, five times in
2000, eight times in 2001, seven times in 2002, five times in 2003, two times in 2004, one time in
2005, and one time in 2006. These records do not include any travel MAXWELL may have taken
on commercial airlines.
5 In or about August 2020, Individual-3 filed a civil lawsuit against EPSTEIN's estate seeking
damages for the conduct described in this affidavit. Information provided by Individual-3 has been
corroborated by independent evidence, including other witness statements and travel records, and
has proven reliable.
31
2017.08.02
EFTA00076742
43.
For all of these reasons, I am aware that
d GHISLAINE
Sri
MAXWELL have both spent significant time at the Virgin Islands Residence, among JEFFREY
EPSTEIN's various other properties, and that evidence of their involvement, and potentially the
involvement of other co-conspirators, in the Subject Offenses may be located at the Virgin Islands
Residence. In particular, flight logs from EPSTEIN's private jet reflect that the individual
identified in the Indictment as "Employee-3" traveled to the U.S. Virgin Islands on approximately
nine separate occasions. These records do not include any travel Employee-3 may have taken on
commercial airlines. As set forth in the Indictment, Employee-3 scheduled victims' encounters
with EPSTEIN.
44.
On or about August 11, 2019, United States Magistrate Judge Ruth Miller of the
District of the Virgin Islands signed a warrant authorizing the search of the Virgin Islands
Residence for fruits, evidence and instrumentalities of the Original Subject Offenses (the "Sixth
Search Warrant"). The Sixth Search Warrant is attached as Exhibit H, and incorporated by
reference herein. The next day, other law enforcement agents and I executed the Virgin Islands
Warrant at the Virgin Islands Residence.
45.
Based on my personal participation in the August 12, 2019 search of the Virgin
Islands Residence, as well as my conversations with other law enforcement agents who
participated in that same search, and my review of documents prepared by other law enforcement
agents who participated in that same search, I have learned that during the August 12, 2019 search
of the Virgin Islands Residence:
a. Subject Device-36 was recovered from a desk in the main residence on the island.
b. Subject Device-37 was recovered from a desk in the main residence on the island.
c. Subject Device-38 was recovered from a desk in the main residence on the island.
32
2017.08.02
EFTA00076743
d. Subject Device-49 was recovered from a desk in the main residence on the island.
e. Subject Device-40 was recovered from a desk in the main residence on the island.
f Subject Device-41 was recovered from a desk in the pool house on the island.
g. Subject Device-42 was recovered from a desk in a cabana on the island.
h. Subject Device-43 was recovered from a box on the floor near a desk in a shed on
the island.
i. Subject Device-44 was recovered from a desk in a shed on the island.
j. Subject Device-45 was recovered from a desk in a cabana on the island.
k. Subject Device-46 was recovered from a desk in a cabana on the island.
1. Subject Device-47 was recovered from a desk in the beach house on the island.
m. Subject Device-48 was recovered from a desk in the beach house on the island.
n. Subject Device-49 was recovered from a server rack inside a shed on the island.
o. Subject Device-50 was recovered from a server rack inside a shed in on the island.
p. Subject Device-51 was recovered from a shed on the island.
q. Subject Device-52 was found on a server rack in a shed on the island.
r. Subject Device-53 was found on a server rack in a shed on the island.
s. Subject Device-54 was recovered from a desk in a cabana on the island.
t. Subject Device-55 was recovered from the maintenance office on the island.
u. Subject Device-56 was recovered from the maintenance office on the island.
v. Subject Device-57 was recovered from the maintenance office on the island.
w. Subject Device-58 was recovered the maintenance office on the island.
x. Subject Device-59 was recovered the maintenance office on the island.
3/- Subject Device-60 was recovered the maintenance office on the island.
33
2017.08.02
EFTA00076744
z. Subject Device-61 was found on a server rack in a shed on the island.
aa. Subject Device-62 was recovered on a file cabinet next to a desk in a cabana on the
island.
46.
On or about September 12, 2019, the Honorable James L. Cott, United States
Magistrate Judge, signed a warrant authorizing the search of Subject Device-37 through Subject
Device-63 for fruits, evidence, and instrumentalities of the Original Subject Offenses
(the "Seventh Search Warrant"). The Seventh Search Warrant is attached as Exhibit I,
and incorporated by reference herein.
The Initial Search of the Subject Devices
47.
I know from my personal involvement in this investigation, as well as my
conversations with other law enforcement agents, that pursuant to the Fourth Search Warrant, the
Fifth Search Warrant, and the Seventh Search Warrant—which, collectively, authorized the search
of all of the Subject Devices for evidence of the Original Subject Offenses—the FBI has
undertaken a multi-step process to review all of the data from all of the Subject Devices. First, the
FBI extracted data from all of the Subject Devices. This process involved multiple months of work
by technical specialists at the FBI to access the data on the devices and convert the data into a
reviewable format. Second, at the request of attorneys for JEFFREY EPSTEIN, the United States
Attorney's Office for the Southern District of New York has conducted a privilege review of the
extracted data as it has been received from the FBI. Third, as data has been cleared through the
privilege review, it has then been reviewed by the case team. That review has involved both the
examination of individual documents and the application of search terms for particular keywords
through the data.
34
2017.08.02
EFTA00076745
48.
I know from my personal involvement in this investigation, as well as my
conversations with other law enforcement agents, that during the third stage of the above-described
search process, the case team identified within the data extracted from the Subject Devices
electronic communications that involve GHISLAINE MAXWELL as either a sender or recipient,
but which do not include JEFFREY EPSTEIN as a sender or recipient. For example, I have
reviewed the following communications contained in the data extracted from the Subject Devices:
a. In an email sent to MAXWELL on or about February 7, 2004, an individual
("Individual-4") asked for details regarding the payments MAXWELL would provide to
Individual-4 in exchange for Individual-4 identifying "beautiful, talented young women ... to train
/ work with" EPSTEIN. Individual-4 further noted, "i have a couple of girls in mind, so let me
know what arrangement we will have, and i will do my best to help." Based on my training,
experience, and participation in this investigation, I believe that in this email Individual-4 was
discussing with MAXWELL the recruitment of young females to engage in sex acts with
EPSTEIN.
b. In an email sent to MAXWELL on or about August 16, 2002, an individual
("Individual-5") asked MAXWELL, "Have you found me some new inappropriate friends?"
Based on my training, experience, and participation in this investigation, I believe that in this email
Individual-5 was asking whether MAXWELL had found any young females to engage in sex acts
with Individual-5.
c. In an email sent to MAXWELL on or about February 28, 2002, Individual-5
discussed an upcoming trip that MAXWELL was helping to arrange for Individual-5. In that same
email, Individual-5 wrote, "As for girls well I leave that entirely to you and [another individual]!"
Based on my training, experience, and participation in this investigation, I believe that in this email
35
2017.08.02
EFTA00076746
Individual-5 was discussing MAXWELL's attempts to arrange for young females to engage in sex
acts with Individual-5.
d. In an email that MAXWELL sent to Individual-5 on March 3, 2002, MAXWELL
informed Individual-5 that she was trying to arrange, "some 2 legged sight seeing (read intelligent
pretty fun and from good families)" for Individual-5 on an upcoming trip. Based on my training,
experience, and participation in this investigation, I believe that in this email MAXWELL was
discussing her attempts to arrange for young females to engage in sex acts with Individual-5.
49.
I further know from my personal involvement in this investigation, as well as my
conversations with other law enforcement agents, that the ongoing investigation into JEFFREY
EPSTEIN and his associates has revealed that on multiple occasions, and as recently as August 8,
2019, EPSTEIN changed his will to adjust bequests to his co-conspirators, including
and GHISLAINE MAXWELL. Specifically, in February 2019, EPSTEIN's will
bequeathed a $10,000,000 annuity to
and forgave any loans EPSTEIN had made to
EPSTEIN's February 2019 will did not mention MAXWELL. On August 8, 2019,
EPSTEIN amended his February 2019 will to, among other things, change the bequests to
and MAXWELL. In particular, the August 2019 will bequeathed $10,000,000 to
MAXWELL and forgave any loans EPSTEIN had made to
but no longer made any
bequest toMMI
50.
I further know from my personal involvement in this investigation that as the FBI's
investigation continued, the case team uncovered new evidence regarding GHISLAINE
MAXWELL's participation in the Additional Subject Offenses, some of which is detailed above.
51.
In light of the MAXWELL communications observed in the data extracted from
the Subject Devices, as well as the new evidence of MAXWELL's participation in the Subject
36
2017.08.02
EFTA00076747
Offenses obtained since EPSTEIN's death, I now seek, out of an abundance of caution, the
requested warrant to broaden the scope of the search of the Subject Devices. In particular, and out
of an abundance of caution, this application seeks to expand the scope of the search of the Subject
Devices to include the Additional Subject Offenses, to specifically permit the search for documents
relating to MAXWELL, and to permit a search of documents dated between the earliest known
abuse of a minor victim in 1994 through Epstein's most recent revision of his will on August 8,
2019.
B. Probable Cause Justifying Further Search of the Subject Devices for Evidence
of the Additional Subject Offenses
52.
Based on my training, experience, and participation in this investigation, I believe
that there is probable cause that evidence of the Additional Subject Offenses, such as photographs
of EPSTEIN's victims and co-conspirators and communications involving EPSTEIN's co-
conspirators, including GHISLAINE MAXWELL and
will be found on the
Subject Devices. In particular, information provided by Individual-1, who traveled across state
lines at EPSTEIN's invitation and with whom EPSTEIN engaged in sex acts at the Virgin Islands
Residence while Individual-1 was a minor, confirms that EPSTEIN engaged in conduct relevant
to the Additional Subject Offenses at the Virgin Islands Residence. Similarly, information
provided by Minor Victim-1, who similarly traveled across state lines at EPSTEIN's invitation
with whom EPSTEIN engaged in sex acts at the New York Residence, as well as information
provided by the other victims identified in the Indictment, confirms that EPSTEIN engaged in
conduct relevant to the Additional Subject Offenses at the New York Residence. In addition,
photographs on the Seized Discs recovered during the search of the New York Residence depict
other young and partially nude girls photographed at multiple locations, including the Virgin
Islands Residence, which suggests that EPSTEIN brought some girls to the Virgin Islands
37
2017.08.02
EFTA00076748
Residence and that, consistent with the account provided by Individual-1 and other victims
identified in the Indictment, EPSTEIN likely sexually abused them at the Virgin Islands Residence
and maintained evidence of that abuse there on the Subject Devices, all of which would be relevant
to the Additional Subject Offenses. Moreover, evidence of co-conspirators' presence at the New
York Residence and/or the Virgin Islands Residence at times when victims were abused, including
photographs, may also be found on the Subject Devices. Similarly, there is probable cause to
believe that evidence of victims' and/or co-conspirators' travel arrangements, contact information,
and communications, including those of
and MAXWELL, will be located on the Subject
Devices.
53.
Moreover, though the sexual abuse described in the Indictment occurred principally
between approximately 2002 and 2005, and although the abuse described by Minor Victim-1
occurred principally between 1994 and 1997, as evidence recovered from the New York Residence
including the Seized Discs makes clear, EPSTEIN continued to maintain substantial evidence of
the Original and Additional Subject Offenses up until the time he was arrested in 2019. Indeed,
as described above, in addition to the Seized Discs, EPSTEIN continued to maintain a "massage
room" complete with a massage table and various sex toys. Accordingly, there is probable cause
to believe that the Subject Devices, which were seized from a residence where EPSTEIN and his
co-conspirators committed the Additional Subject Offenses, will similarly contain evidence of the
Additional Subject Offenses.
54.
In addition, I believe that evidence of the Additional Subject Offenses may be
located on the Subject Devices because (i) the Virgin Islands Residence was the location of
multiple photo shoots of young girls; (ii) the Virgin Islands Residence appears to have been, for
the last several years and up until the time of his arrest, EPSTEIN's primary residence; and (iii)
38
2017.08.02
EFTA00076749
given its location, the Virgin Islands Residence is JEFFREY EPSTEIN's most private residence.
Therefore, given that EPSTEIN has maintained evidence of the Original and Additional Subject
Offenses in the New York Residence, he is likely to have similarly maintained some of that
evidence in the Subject Devices maintained at the Virgin Islands Residence. Moreover, given that
there is probable cause to believe that JEFFREY EPSTEIN and others, including
and GHISLAINE MAXWELL, conspired to commit the Original and Additional
Subject Offenses, evidence of EPSTEIN's involvement in trafficking, enticing, and transporting
minors would also be relevant to the investigation of, and any future charges against, other
members of the conspiracy, such as
and MAXWELL.
55.
According to international flight records that I have reviewed, a private jet owned
and utilized by EPSTEIN has traveled to or from the U.S. Virgin Islands at least on or about April
14, 2019; May 5, 2019; May 18, 2019; and June 11, 2019. Accordingly, there is probable cause
to believe that EPSTEIN was present at the Virgin Islands Residence a short time before the
recovery of the Subject Devices.
56.
Based on my training and experience in investigating individuals who engage in
sex trafficking, enticement, and transportation of minors, such individuals often maintain
photographs of their victims, and/or other erotic images of minors, at their residences. Individuals
who engage in such offenses often hoard such images in the privacy of their residences. In
particular, data related to their illegal activity is often stored on their computers.
57.
In my training and experience, 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,
39
2017.08.02
EFTA00076750
and individuals who store such materials on compact discs typically store similar files on other
computing devices and storage devices.
58.
Like individuals engaged in any other kind of activity, individuals who engage in
sex trafficking, enticement, and transportation of minors store records relating to their illegal
activity and to persons involved with them in that activity on electronic devices such as the Subject
Device.
Such records can include, for example, logs of online communications with co-
conspirators; email correspondence; contact information of co-conspirators, including telephone
numbers, email addresses, and identifiers for instant messaging and social medial accounts; travel
records for victims and/or co-conspirators; payment records for victims and/or co-conspirators;
and/or photographs of victims and/or co-conspirators. Individuals engaged in criminal activity
often store such records in order to, among other things, (1 ) keep track of co-conspirator's contact
information; (2) keep a record of illegal transactions for future reference; (3) remain in contact
with co-conspirators and victims; (4) enable payment of co-conspirators and victims; and (4) store
exploitative photographs for future sexual gratification.
59.
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 Devices. Even
when such files have been deleted, they can often be recovered, depending on how the hard drive
has subsequently been used, months or years later with forensics tools. Thus, the ability to retrieve
from information from the Subject Devices depends less on when the information was first created
or saved than on a particular user's device configuration, storage capacity, and computer habits.
60.
Based on the foregoing, I respectfully submit there is probable cause to believe that
evidence of the Target Subjects' commission of the Additional Subject Offenses is likely to be
found on the Subject Devices.
40
2017.08.02
EFTA00076751
III. Procedures for Searching ESI
A. Review of ESI
61.
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 Device for information responsive to the
warrant.
62.
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;
scanning storage areas for deliberately hidden files; and
•
performing electronic keyword searches through all electronic storage areas to
determine the existence and location of search terms related to the subject matter of the
investigation. (Keyword searches alone are typically inadequate to detect all
information subject to seizure. 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.)
63.
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 Device to locate all data responsive to the warrant.
41
2017.08.02
EFTA00076752
B. Return of the Subject Devices
64.
If the Government determines that the Subject Devices are no longer necessary to
retrieve and preserve the data on the device, and that the Subject Devices are not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return the Subject
Device, 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
65.
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.
66.
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.
sworn via telephone
Task Force Officer
Federal Bureau of Investigation
Sworn to before me on
June 26, 2020 at 9:11 am
80 to
orttio le;""
42
2017.08.02
EFTA00076753
Attachment A
I. Devices Subject to Search and Seizure
The devices that are the subject of this search and seizure warrant (the "Subject Devices")
are described as follows:
Two of the Subject Devices were seized from JEFFREY EPSTEIN's person during the
course of his arrest by the FBI on or about July 6, 2020 (the "Arrest Subject Devices"). The Arrest
Subject Devices are particularly described as follows:
a. A silver iPad with serial number DLXQGM3KGMW3 ("Subject Device-1"); and
b. A black iPhone with IMEI number 357201093322785 ("Subject Device-2").
33 of the Subject Devices were recovered from a search of JEFFREY EPSTEIN's private
residence located at 9 East 71st Street, New York, New York, which took place on July 11, 2019
(the "New York Subject Devices"). The New York Subject Devices are particularly described as
follows:
a. Two black hard drives, which were seized by Special Agent
from a
blue suitcase on or about July 11, 2019 ("Subject Device-3");
b. An Apple desktop computer, which was seized from in a cardboard box along the
right wall of a room on the first floor of the New York Residence, and which has
been assigned internal FBI barcode number E65 15034 ("Subject Device-4");
c. A silver iPad, which was seized from a shelf in the right corner of a room on the
third floor of the New York Residence under a television, and which has been
assigned internal FBI barcode number E65 15033 ("Subject Device-5");
d. A gray Apple iPad, which was seized from under a sink in a room on the third floor
of the New York Residence, and which has been assigned internal FBI barcode
number E65 15032 ("Subject Device-6");
e. A gray Apple iPad, which was seized from under a sink in a room on the third floor
of the New York Residence, and which has been assigned internal FBI barcode
number E6515031 ("Subject Device-7");
f. A Sony Vaio laptop, which was seized from inside a desk drawer in the drawing
room on the second floor of the New York Residence, and which has been assigned
internal FBI barcode number E65 15026 ("Subject Device-8");
A Dell Precision Tower 5810, which was seized from a storage area in the basement
of the New York Residence, and which has been assigned internal FBI barcode
number E65 15025 ("Subject Device-9");
2017.08.02
EFTA00076754
h. A Seagate Barracuda 7200 hard drive, which was seized from a storage area in the
basement of the New York Residence, and which has been assigned internal FBI
barcode number E65 15024 ("Subject Device-10");
i. A MSI PC Computer, which was seized from a storage area in the basement of the
New York Residence, and which has been assigned internal FBI barcode number
E65 15023 ("Subject Device-11");
A Sony Camera with a black case, which was seized from in a drawer inside a room
on the sixth floor of the New York Residence, and which has been assigned internal
FBI barcode number E65 15022 ("Subject Device-12");
k. A gray Apple desktop computer, which was seized from a desk inside a room on
the sixth floor of the New York Residence, and which has been assigned internal
FBI barcode number E6515021 ("Subject Device-13");
I. A Seagate Backup Plus portable drive, which was seized from a shoebox on top of
a desk in a room on the fifth floor of the New York Residence, and which has been
assigned internal FBI barcode number E65 15020 ("Subject Device-14");
m. A white Apple iPhone 5, which was seized from the lower left shelf of a white
wooden cabinet in a mom on the fifth floor of the New York Residence, and which
has been assigned internal FBI barcode number E6515019 ("Subject Device-15");
n. An Apple desktop computer, which was seized from on top of a desk inside the
drawing room on the second floor of the New York residence, and which has been
assigned internal FBI barcode number E6515018 ("Subject Device-16");
o. An Apple desktop computer, which was seized from on top of a desk in a room on
the fifth floor of the New York Residence, and which has been assigned internal
FBI barcode number E6515017 ("Subject Device-17");
A SPIEF 2014 silver USB, which was seized from a cabinet on the back wall of a
storage closet on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E65 15016 ("Subject Device-18");
q. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515015 ("Subject Device-19");
r. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E65 15014 ("Subject Device-20");
2
2017.08.02
EFTA00076755
s. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515013 ("Subject Device-21");
t. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage
closet on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515012 ("Subject Device-22");
u. A blue EMTEC USB, which was seized from a small tray on the floor of the dining
room on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E651501 I ("Subject Device-23");
v. An EMTEC USB, which was seized from a small tray on the floor of the dining
room on the first floor of the New York Residence, and which has been assigned
internal FBI barcode number E6515010 ("Subject Device-24");
w. A silicone power micro SD adaptor, which was seized from a drawer inside a table
in the dining room on the First Floor of the New York Residence, and which has
been assigned internal FBI barcode number E65 15008 ("Subject Device-25");
x. A DELL Machine, which was seized from a desk in a room on the first floor of the
New York Residence, and which has been assigned internal FBI barcode number
E6515007 ("Subject Device-26");
y. A Cube 9000 Siteserver, which was seized from a desk in a room on the first floor
of the New York Residence, and which has been assigned internal FBI barcode
number E65 15006 ("Subject Device-27");
z. An HP Compaq Machine, which was seized from a desk in a room on the first floor
of the New York Residence, and which has been assigned internal FBI barcode
number E65 15005 ("Subject Device-28");
aa. A Mentor Media USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E65 15004 ("Subject Device-29");
bb. A Data Traveler USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E65 15003 ("Subject Device-30");
cc. A Data Traveler USB, which was seized from a desk in a room on the first floor of
the New York Residence, and which has been assigned internal FBI barcode
number E65 15002 ("Subject Device-31");
3
2017.08.02
EFTA00076756
dd. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E65 15001 ("Subject Device-32");
ee. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E65 15000 ("Subject Device-33");
ff. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet
in an oval study on the first floor of the New York Residence, and which has been
assigned internal FBI barcode number E6433827 ("Subject Device-34"); and
gg. A silver Apple desktop computer, which was seized from a desk in an oval study
on the first floor of the New York Residence, and which has been assigned internal
FBI barcode number E6433828 ("Subject Device-35").
27 of the Subject Devices were recovered from a search of a private island in the U.S.
Virgin Islands, known as Little Saint James, which is an approximately 75 acre island located
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands
Residence") on or about August 12, 2019 (the "Virgin Islands Subject Devices"). The Virgin
Islands Residence consists of multiple structures, including a main residence as well as several
other smaller structures on the island, including a pool house, sheds, a beach house, an office, and
multiple cabanas. The Virgin Islands Subject Devices are particularly described as follows:
a. A gray Mac desktop computer labeled "kitchen mac," which was recovered from a desk
in the main residence on the island ("Subject Device-36");
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89111772QT,
which was recovered from a desk in the main residence on the island ("Subject Device-
37");
c. A silver MacBook Pro bearing serial number c02qmOgugwdp, which was recovered
from a desk in the main residence on the island ("Subject Device-38");
d. A silver iPad model A1567 bearing serial number dmpq125ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-39");
e. A silver iPad model A1567 bearing serial number dmpqL1rrng5y, which was recovered
from a desk in the main residence ("Subject Device-40");
f. A silver Mac desktop computer bearing serial number cO2nm1m0fy14, which was
recovered from a desk in the pool house on the island ("Subject Device-41");
A silver Mac desktop computer, which was recovered from a desk in a cabana on the
island ("Subject Device-42");
4
2017.08.02
EFTA00076757
h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a shed
on the island ("Subject Device-43");
i. An HP laptop bearing serial number cnd81368v5, which was recovered from a desk in
a shed on the island ("Subject Device-44");
A silver Mac desktop computer, which was recovered from a desk in a cabana on the
island ("Subject Device-45");
k. A silver Macbook desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-46");
I. A Dell Inspiron Tower computer model D19M QCNFA335, which was recovered from
a desk in the beach house on the island ("Subject Device-47");
m. A silver Mac desktop computer model A1311 bearing serial number W804736DDAS,
which was recovered from a desk in the beach house on the island ("Subject Device-
48");
n. A Unfi video bearing mac ID 1829f b4fbe426ea90, which was recovered from a server
rack inside a shed on the island ("Subject Device-49");
o. A Unifi Server bearing mac ID 1735K 788A20463234-8uuu9f, which was recovered
from a server rack inside a shed in on the island ("Subject Device-50");
An HP server with four 500 GB drives, bearing serial number MXQ3220187, which
was recovered from a shed on the island ("Subject Device-51");
q. A Panasonic IOC TDE100 computer bearing serial number 1OC-TDa0104
9LCCD005398, which was found on a server rack in a shed on the island ("Subject
Device-52");
r. A 6 bay with 146 GB drives bearing serial number MXQ824A1R, which was found on
a server rack in a shed on the island ("Subject Device-53");
s. A silver Mac desktop computer, which was recovered from a desk in a cabana on the
island ("Subject Device-54");
t. An HP desktop tower model 260-A010, bearing serial number cnv7160050, which was
recovered from the maintenance office on the island ("Subject Device-55");
u. An HP tower model 260-A010, bearing serial number cnv716004y, which was
recovered from the maintenance office on the island ("Subject Device-56");
v. A Mac desktop computer model A1312, bearing serial number w89524czspj, which
was recovered from the maintenance office on the island ("Subject Device-57");
5
2017.08.02
EFTA00076758
w. A Lenovo tower machine type 90J0, bearing serial number mj07yg6u, which was
recovered the maintenance office on the island ("Subject Device-58");
x. A Lenovo tower bearing serial number 153306g2umjxekgx, which was recovered the
maintenance office on the island ("Subject Device-59");
y. An HP Tower bearing serial number CNV742I3M3 570-P056, which was recovered
the maintenance office on the island ("Subject Device-60");
z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID
1843kb4fbe4d30c69-dcrgm9, which was found on a server rack in a shed on the island
("Subject Device-61"); and
aa. A red Nikon digital camera, which was recovered on a file cabinet next to a desk in a
cabana on the island ("Subject Device-62").
II. Review of ESI on the Subject Devices
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 Device for evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors), 2422 (transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to
commit sex trafficking, transportation of minors, and enticement to travel) (the "Subject
Offenses"), for the period 1994 through August 8, 2019, described as follows:
1.
Evidence concerning the identity or location of the owner(s) or user(s) of the
Subject Devices.
2.
Evide
•
identity or location of co-conspirators of JEFFREY
EPSTEIN, including
d GHISLAINE MAXWELL.
3.
Evidence concernin
•
to, from, by, and/or among co-conspirators
of JEFFREY EPSTEIN, including
and GHISLAINE MAXWELL.
4.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses.
5.
Documents or records reflecting payments to victims and/or co-conspirators
including but not limited to bank and financial records, spreadsheets, ledgers, account listings,
check and wire records, and documents reflecting cash withdrawals.
6.
Documents or records reflecting travel plans or arrangements for victims or
potential victims of the Subject Offenses, or co-conspirators in those Subject Offenses, including
6
2017.08.02
EFTA00076759
but not limited to itineraries, tickets, receipts, flight manifests, passport or identification
information, and related records.
7.
Any photographs of victims or potential victims of the Subject Offenses.
8.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
9.
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.
10.
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).
If the Government determines that any of the Subject Devices is no longer necessary to retrieve
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject
Device, upon request.
7
2017.08.02
EFTA00076760
EXHIBIT A
EFTA00076761
x
Defendant.
SEALED
INDICTMENT
19 Cr.
1 9 UN 490
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
EFTA00076762
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.
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
2
EFTA00076763
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.
3
EFTA00076764
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 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 als