Extracted Text
Highlighting: “"investigation6"”
AO 106 (SDNY Rev. 01/17) Applictejon %r a Search Warrant
UNITED STAPES DISTRICT COURT
for the
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In the Matter of the Search of
(Briefly describe :improperly to be searched
or identify the person ,b,y name and addreis)
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c4, sem . r Akk ,, it ifilLIcf%TaTfity.414,k SEARCH. AND SEIZURE, WARRANT
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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 (idennfr the person or describe the
property to be searched and give its location):
located in the .(Sbletall District of Ne-AA) y O( _ , there is now concealed (identify the
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
irevidence of a crime;
O contraband, fruits of crime, or other items illegally possessed;
0 '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 USC 1511 + 311 a- 4 il r itg1tiart OC minors
sex 'ir &fel' n3 Conspiracy
The application is based on these facts:
See Attached Affidavit and its Attachment A
tic Continued on the attached sheet.
O Delayed notice of 30 days (give exact ending date if more than 30 days: ) is requested
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet.
Sworn to before me and signed in my presence.
Date:
Jul_ 1 5 2019 .001.041,e9tk-
Judge's signature
City and state: New York, NY HON. KEVIN NATHANIEL rox
UsPed Otehesitesiiistrataislul:o —1 -
Southern District of Now York
U8AO 004321
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ot:
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
In the Matter of the Application of the United TO BE FILED UNDER SEAL
States Of America for a Search and Seizure
Warrant for (1) a black iPhone with IMEI number Agent Affidavit in Support of
357201093322785, (2) a silver iPad with serial Application for Search and Seizure
number DLXQGM3KGMW3, (3) two black Warrant
binders with CDs, (4) two black hard drives, (5)
a box of CDs, and (6) two binders with various
CDs
SOUTHERN DISTRICT OF NEW YORK) ss.:
being duly sworn, deposes and says:
I. Introduction
A. Affiant
I. I have been a Special Agent 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)(2XC), that is, a government agent engaged in enforcing the criminal
laws and duly authorized by the Attorney General to request a search warrant. I am currently
assigned to investigate violations of criminal law relating to the sexual exploitation of children.
As part of my responsibilities, I have participated in numerous investigations and prosecutions of
crimes against children, including the sex trafficking of minors, and have participated in the
execution of search warrants involving electronic evidence.
2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal
Rules of Criminal Procedure for a warrant to search certain electronic devices, compact disks and
related electronic media specified below (the "Subject Items') for the items and information
described in Attachment A. This affidavit is based upon my personal knowledge; my review of
documents and other evidence; my conversations with other law enforcement personnel; and my
I
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training, experience and advice received concerning the use of computers in criminal activity and
the forensic analysis of electronically stored information (`BSI"). Because this affidavit is being
submitted for the limited purpose of establishing probable cause, it does not include all the facts
that I have learned during the course of my investigation. Where the contents of documents and
the actions, statements, and conversations of others are reported herein, they are reported in
substance and in part, except where otherwise indicated.
B. The Subject Items
3. The Subject Items are particularly described as follows':
A black iPhone with IMEI number 357201093322785, which was seized
. from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-1").
b. A silver iPad with serial number DLXQGM3KGMW3, which was seized
from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-2").
c. Two black binders with CDs, which were
about July 11, 2019 ("Subject Item-3").
d. Two black hard drives, which were seizedkfrom a blue suitcase on or about
July 11, 2019 ("Subject Item-4").
e. A box of CDs, which was seized from a blue suitcase on or about July 11
2019 ("Subject Item-5").
f. Two binders with various CDs, which were se' from a black suitcase on
or about July 11, 2019 ("Subject Item-6").
1 To the extent that the Subject Items contain any SD cards or other removable storage media, the
description of each such item encompasses those SD cards and other media.
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4. Based on my training, experience, and research, I know that Subject Item-1 and
Subject Item-2 both have capabilities that allow them to serve as a wireless telephone, digital
camera, portable media player, OPS navigation device, and PDA.
5. The Subject Items are all presently lonted in the Southern District of New York.
C. The Target Subject and the Subject Offenses
6. The Target Subject of this investigation is JEFFREY EPSTEIN.
7. For the reasons detailed below, I respectfully submit that there is probable cause to
believe that the Subject Items contain evidence, fruits, and instrumentalities of violations of Title
18, United States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code,
Section 371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject.
II. Probable Cause
A. Probable Cause Regarding the Target Subject's Commission of the Subject Offenses
8. On or about July 2, 2019, a grand jury in this District returned an Indictment
charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached
hereto as Exhibit A and is incorporated by reference.
9. That same day, the Honorable Barbara Moses, United States Magistrate Judge,
signed an arrest warrant for JEFFREY EPSTEIN. A copy of the Arrest Warrant is attached hereto
as Exhibit B and is incorporated by reference.
B. Probable Cause Justifying Search of the Subject Items
The Indictment and Victim-1
10. As set forth in Exhibit A, from at least in or about 2002, up to and including at least
in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern
District of NeW York and elsewhere. During that time and continuing to the present, EPSTEIN
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possessed and controlled a multi-story, single-family residence located at 9 East 71st Street, New
York, New York, which is described in Exhibit A as "the New York Residence."
11. As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or
about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous
minor victims at the New York Residence. In particular, and as alleged in the Indictment, when a
victim arrived at the New York Residence, she would be escorted to a room inside the Subject
Premises with a massage table, where she would perform a massage on EPSTEIN. The victims,
who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or
fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate
the nature and scope of physical contact with his victim to include, among other things, sex acts
such as groping and direct and indirect contact with the victims' genitals. EPSTEIN typically
would also masturbate during these sexualized encounters, ask victims to touch him while he
masturbated, and touch victims' genitals with his hands or with sex toys. Following each
encounter, EPSTEIN or one of his employees or associates paid the victim in cash.
12. 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.
13. One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of
the FBI's investigation of EPSTEIN, other law enforcement officers and I have interviewed
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Victim-1. 2 During those interviews, Victim-1 has provided the following information, in
substance and in part:
a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on
multiple occasions in the New York Residence. This sexual abuse all occurred when Victim-1
was under the age of 18.
The July 6. 2019 Seizure of Subject Item-1 and Subiect Item-2
14. I know from my personal participation in this investigation and my conversations
with other law enforcement agents that on July 6, 2019, JEFFREY EPSTEIN was aboard a private
Iscct
jet that flew from France and landed at approximately 5:30 ■ in Teterboro Airport in Bergen4lit
New Jersey. Upon his arrival at Teterboro Airport, and as part of his re-entry into the United
States, EPSTEIN was searched by agents of U.S. Customs and Border Protection ("CBP"), who
found both Subject Item-1 and Subject Item-2 in EPSTEIN's possession. The CBP agents then
provided Subject Item-1 and Subject Item-2 to Special Agents of the FBI who also placed
EPSTEIN under arrest. The FBI subsequently transported Subject Item-1 and Subject Item-2 to
FBI offices located in the Southern District of New York, where they are currently located.
2 In meetin with the Govemmen Victim-1 has disclosed
She
SO C OS
Victim-1 has also disclosed
Victim-1
Information prom .y proven re a e an n corro .y epcn• ent
evidence, including documents and records obtained during the investigation and the accounts of
other victims whom Victim-1 has never met.
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The July 6. 2019 and July 7, 2019 Search Warrants for the New York Residence
15. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a search warrant authorizing a search of the New York Residence. The search
warrant is attached as Exhibit C and incorporated by reference herein.
16. At approximately 6 ■. on or about July 6, 2019, law enforcement officers (the
"Search Team") commenced executing the search warrant at the New York Residence.
17. Based on the Search Team's observations during an initial search of the New York
Residence, at approximately 7M., the Search Team stopped the search and froze the scene in
order to seek a new search warrant.
18. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a second search warrant authorizing a search of the New York Residence (the
"Second Warrant"). The Second Warrant is attached as Exhibit D, and incorporated by reference
herein. At approximately 2:30 II., the Search Team resumed the search, and commenced
searching pursuant to the Second Warrant
19. Based on my conversations with members of the Search Team, I have learned the
following:
a. The Search Team observed a number of computing devices, including computers
and tablet devices, throughout the New York Residence.
b. Inside a safe in a closet on the third floor (the "Safe"), the Search Team discovered
and seized, among other items, several binders containing sleeves of compact discs, most of which
are labeled with handwriting. In total, the binders contain dozens of compact discs. One disc is
labeled Another disc is labeled "Nudes 00-24." Another is
labeled "Misc. Nudes." Yet another is labeled "Girl Pies Nude." Some discs contain the word
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"Zorro" or "LSJ." For example, one disc is marked "Dana 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.
c. During the search, the Search Team did not seize at that time certain binders of
discs located in the Safe, where the majority of the discs in the binder were labeled in a manner
that did not appear to refer to girls or nudes. The Search Team also did not seize at that time
several unlabeled hard drives, which were also located in the Safe. As detailed below, those
additional binders of discs are among the subjects of this application.
d. In addition to the Safe, in the drawer of a dresser in a room on the Fifth floor of the
New York Residence, the Search team discovered and seized, among other items, a shoebox (the
"Shoebox") which contained numerous compact discs. The majority of the discs are labeled, in
handwriting, with female names. One disc is labeled "Thai Massage." Another disc is labeled
"Blonde Girl Photo Shoot." Yet another disc is labeled "Misc. Girls Nude/Dinner—Scientists."
The discs in the Shoebox were seized by the Search Team. In another drawer of that same dresser,
the Search Team discovered loose polaroid photographs depicting young, nude females who, based
on the training and experience of law enforcement officers who observed them, appear to be
teenagers. In that same drawer, the Search Team discovered a folder marked, in handwriting,
=which contained photographs, including nude and sexually suggestive photographi 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
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girls who appear to be teenagers, based on my training and experience. Inside the folder is a
compact disc marked Mat L.TS 6/03" (the Wise"), which was seized by the Search Team.
e. In a closet on the Fifth Floor of the New York Residence, the Search Team
discovered, among othcr 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-Ell `03" The remaining
discs contain tiles that include female names. All of the foregoing discs were seized by the Search
Team.
f. In that same closet, the Search Team discovered numerous black binders containing
what appear to be print outs of digital photographs (with file names underneath) and compact discs.
The Search Team seized approximately ten binders (the "Seized Binders")3 which appeared to
contain, among other photographs, photographs of nude or partially nude young girls, some of
which are in sexually suggestive poses. Based on the training and experience of law enforcement
officers who observed them, at least some of the young girls depicted in the photographs appear
to be teenagers, including some who appear to be under the age of 18. The Seized Binders also
include photographs of what appear to be personal functions, events, and travel.
g. The compact discs seized by the Search Team and described in paragraphs
are currently stored within the Southern District of New York in containers marked for
identification with FBI evidence numbers 15, 16, 17, 18, and 22 (the "Seized Discs").
The July 7, 2019 Search Warrant for the Seized Discs
20. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate
Judge, signed a third search warrant to search and seize electronic media stored on the Seized Discs
3 The Search Team did not seize the remaining binders.
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(the "Third Search Warrant"). The Third Warrant is attached as Exhibit E, and incorporated by
reference herein.
21. Based on my conversations with law enforcement agents who have reviewed the
Seized Discs pursuant to the Third Search Warrant (the "Reviewing Agents"), I have learned the
following:
a. The discs contain approximately thousands of nude or partially nude photographs
of girls or young women, many of which are in sexually suggestive poses. Based on my
conversations with the Reviewing Agents, who have particular training and experience relating to
child erotica and visual depictions of children in child exploitation cases, I have learned that the
Reviewing Agents believe that many of the nude or partially nude images they have reviewed
appear to depict girls under the age of 18. Moreover, many of the photographs appear to be labeled
with file names that suggest the photographs depict these girls at properties associated with
JEFFREY EPSTEIN. For example, some file names are labeled "Zorro" or "LSJ."
b. Among the photographs on the Seized Discs, the Reviewing Agents identified
partially-nude photographs of a young girl, labeled with an associated name that matched a
particular individual ("Individual-1"). After identifying those photographs, the Government was
advised by Individual-1's counsel that Individual-I recalls the month and year during which she
believes those partially-nude photographs were taken, and also the location where they were taken,
and that she was 17 years old at the time.
The July 11, 2019 Search Warrant for All Electronic Devices and Storage Media in the
New York Residence
22. Following the initiation of the FBI's review of the Seized Discs, on or about July
11, 2019, the Honorable Henry B. Pitman, United States Magistrate Judge, signed another search
warrant authorizing another search of the New York Residence and specifically authorizing the
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seizure and search of electronic devices and storage media inside the New York Residence (the
"Fourth Warrant"). The Fourth Warrant is attached as Exhibit F and incorporated by reference
herein.
23. Later on July 11, 2019, the Search Team executed the Fourth Warrant at the New
York Residence.
24. Based on my conversations with members of the Search Team, I have learned the
following, among other things, regarding the execution of the Fourth Warrant:
a. During the July 11, 2019 execution of the Fourth Warrant inside the New
York Residence, the Search Team found that the Safe described above was empty and, in
particular, that the collection of discs and hard drives described in paragraph 19b, above, that the
Search Team had not seized during its prior search of the New York Residence on July 7, 2019,
had been removed.
b. After discovering that the Safe was empty, the Search Team spoke with an
employee who worked at the New York Residence (the "Employee"). During that conversation,
the Employee told the Search Team that after the completion of the prior search on July 7, 2019,
the Employee had been instructed by a third party ("the Third Party") to take the contents of the
Safe out of the New York Residence and deliver those items to the Third Party. The Employee
further told the Search Team that after receiving that instruction, the Employee packed the contents
of the Safe into two suitcases and delivered those suitcases to the Third Party. The Employee
provided the Search Team with the Third Party's contact information.
c. The Search Team then contacted the Third Party. During the ensuing
conversation, the Third Party confirmed receipt of two suitcases from the Employee but also told
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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
Sf.e3. .sc tritess•with the two suitcases described above, one of which was blue and one of which was black.
0\
onsistent with standard law enforcement protocol, the Search.Team conducted an inventory of
th suitcases before taking custody of them. While taking an inventory of the blue suitcase, the
Search Team discovered, among other items, Subject Item-3, Subject Item-4, and Subject Item-5.
While taking an inventory of the black suitcase, the Search Team discovered, among other items,
Subject Item-6. These items, i.e., Subject Items -3, -4, -5, and -6, appeared to be the same items
observed in the Safe by the Search Team during the July 7, 2019 search of the New York
Residence.
The 2018 Payments
25. Based on my participation in this investigation, my review of open source materials,
and my review of financial records, I have further learned the following:
a. On or about November 28, 2018, the Miami Herald began publishing a
series of articles related to JEFFREY EPSTEIN, his sex trafficking of minor girls, and the
circumstances of a non-prosecution agreement ("NPA") he previously negotiated with the
Southern District of Florida. Among other things, the NPA identified several individuals as
EPSTEIN's co-conspirators in the sex trafficking of minor girls.
b. Records obtained by the Government from a financial institution
("Institution-1") appear to show that just two days after the Miami Herald began publishing its
series, on or about November 30, 2018, the defendant wired $100,000 from a trust account he
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controlled to an individual named as a possible co-conspirator in the NPA. The same records from
Institution-1 appear to show that just three days after that, on or about December 3, 2018, the
defendant wired $250,000 from the same trust account to another individual named as a possible
co-conspirator in the NPA and also identified as one of the defendant's employees in the
Indictment. Neither of these payments appears to be recurring or repeating during the
approximately five years of bank records presently available.
c. This course of action, and in particular its timing, suggests the defendant
was still in communication with and attempting to further influence co-conspirators who might
provide information against him in light of the recently re-emerging allegations.
Request to Search the Subiect Items
26. Based on my training and experience and participation in this investigation, I
respectfully submit that there is probable cause to believe that the Subject Items will contain and/or
constitute additional fruits, evidence and instrumentalities of the Subject Offenses. As an initial
matter, all of the Subject Items were initially found in the same Safe in which EPSTEIN was
storing discs and other media already reviewed and which contain hundreds of not thousands of
nude and suggestive images of young females, some of whom appear to be under 18. Given as
much, and because there is probable cause to believe that Epstein engaged in sex trafficking of
underage girls, there is probable cause to believe that the additional storage media in EPSTEIN's
possession and control—Le., the Subject Items—will contain evidence of the Subject Offenses.
Moreover, that efforts were made to remove Subject Items -3, -4, -5, and -6 from the New York
Residence after the initial search only further reinforces the probable cause to believe that those
Subject Items contain and constitute fruits, evidence and instrumentalities of the Subject Offenses.
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27. With respect to Subject Item-1 and Subject Item-2, both are electronic devices
capable of sending, receiving, and containing thousands of messages and images. Based on my
training and experience, I am aware that individuals who store nude and/or sexually suggestive
photographs of minors on compact discs or other external storage devices typically annws those
images from computers and other electronic devices in order to view those images, and individuals
who store such materials on compact discs typically store similar files on other computing devices
and storage devices like Subject Item-1 and Subject Item-2. Further, in light of the payments to
potential co-conspirators described in paragraph 25, above, I respectfully submit there is probable
cause to believe that EPSTEIN still communicates with at least some of his co-conspirators about
the Subject Offenses and that such communications may occur using Subject Item-1 and Subject
Item-2.
28. I further know from my training and experience that computer files or remnants of
such files can be recovered months or even years after they have been created or saved on an
electronic device such as the Subject Items. Even when such files have been deleted, they can
often be recovered, depending on how the device has subsequently been used, months or years
later with forensics tools. Thus, the ability to retrieve from information from the Subject Items
depends less on when the information was first created or saved than on a particular user's device
configuration, storage capacity, and computer habits.
29. Based on the foregoing, I respectfully submit there is probable cause to believe that
evidence of JEFFREY EPSTEIN's commission of the Subject Offences is likely to be found on
the Subject steins..
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IR. Procedures for Searching ESI
A. Review of ESI `'
30. Law enforcement personnel (who may include, in addition to law enforcement
officers and agents, attorneys for the government, attorney support staff, agency personnel
assisting the government in this investigation, and outside technical experts under government
control) will review the ESI contained on the Subject Items for information responsive to the
warrant
31. In conducting this review, law enforcement may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
• surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
• conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation's; and
• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
keyword searches work only for text data, yet many types of files, such as images and videos, do
not store data as searchable text. Moreover, even as to text data, there may be information properly
subject to seizure but that is not captured by a keyword search because the information does not
contain the keywords being searched.
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32. Law enforcement personnel will make reasonable efforts to restrict their search to
data falling within the categories of evidence specified in the warrant. Depending on the
circumstances, however, law enforcement may need to conduct a complete review of all the ESI
from the Subject Items to evaluate its contents and to locate all data responsive to the warrant.
B. Return of the Subject Items
33. If the Government determines that•the Subject Items are no longer necessary to
retrieve and preserve the data on the Subject Items, and that the Subject Items are not subject to
seizure pursuant to F ule of Criminal Procedure 41(c), the Government will return the
Subject Items,, Computer data that is encrypted or unreadable will not be returned
unless law enforcement personnel have determined that the data is not (i) an instrumentality of the
offense, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed,
or (v) evidence of the Subject Offenses.
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IV. Conclusion and Ancillary Provisions
34. Based on the foregoing, I respectfully request the court to issue a warrant to seize
the items and information specified in Attachment A to this affidavit and to the Search and Seizure
Warrant.
35. In light of the confidential nature of the continuing investigation, I respectfully
request that this affidavit and all papers submitted herewith be maintained under seal until the
Court orders otherwise.
pecialP,gen
• Federal Bureau of Investigation
Sworn to before me on . 1 5 20191
July IS• 2019
HON., KEVIN NATHANIEL FOX
STATES lvLAGISTRATE JUDGE
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Attachment A
I. Items Subject to Search and Seizure
The Subject Items are particularly described as follows':
• A black iPhone with IMEI number 357201093322785, which was seized from
JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-1").
• A silver iPad with serial number DLXQGM3KOMW3, which was seized from
JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-2").
• Two black binders with CDs, which were seizedkom a blue sur
July 11, 2019 ("Subject Item-3").
r kk‘ Adj
• Two black hard drives, which were from a b ue suitcase on or about July 11
2019 ("Subject Item-4"). '
k)v,\ Soc-C-Itt4 /ben
• A box of CDs, which was seizedkom a blue suite
("Subject Item-5'). \It*
Two binders with various CDs, which were seized
• a black suitcase on or a out
July 11, 2019 ("Subject Item-6"):
13 5re.c/141
IL Review of ESI on the Subject Items
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Items for evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
1. Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
2. Any photographs of victims or potential victims of the Subject Offenses;
3. Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger;
4. Records, data, or other items that evidence ownership, control, or use of, or access
to the Subject Items, including, but not limited to access history data, historical location data,
To the extent that the Subject Items contain any SD cards or other removable storage media, the
description of each such item encompasses those SD cards and other media.
2017.08.02
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configuration files, saved usernames and passwords, user profiles, e-mail contacts, and
photographs;
5. Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
As to Subject Item-1 and Subject Item-2, Law enforcement personnel (who may include,
in addition to law enforcement officers and agents, attorneys for the government, attorney support
staff, agency personnel assisting the government in this investigation, and outside technical experts
under government control) are further authorized to review the EST contained on Subject Item-1
and Subject Item-2 for evidence, fruits, and instrumentalities of violations of Title 18, United
States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the
"Subject Offenses") described as follows:
1. Any documents or communications with or regarding co-conspirators in the Subject
Offenses.
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
• surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
• conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation; and
• reviewing metarlfirn, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section II
of this Attachment. However, law enforcement personnel are authorized to conduct a complete
review of all the PSI from seized devices or storage media if necessary to evaluate its contents and
to locate all data responsive to the warrant.
2
2017.08.02
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EXHIBIT A
.17.08.02
USAO_004340
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EFTA00171930
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
SEALED
UNITED. STATES OF AMERICA INDICTMENT
19 Cr.
JEFFREY EPSTEIN,
Defendant.
19 CREW 4910
x
COUNT ONE
(Sex Trafficking Conspiraby)
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
USAO 004341
EFTA_00022251
EFTA00171931
ork of underage victims for
this way, EPSTEIN created a vast netw
including New York and
him to sexually exploit in. locations
Palm Beach.
g as 14
3. The victims described herein were as youn
JEFFREY EPSTEIN, the
years old at the time they were abused by
ons, often particularly
defendant, and were, for various reas
vulnerable to exploitation. EPSTEIN intentionally sought out
were in fact under the
minors and knew that many of his victims
instances, minor victims
age of 18, including because, in some
expressly told him their age. •
of mino r
4. In creating and maintaining this network
abuse and exploit,
victims in multiple states to sexually
and conspired with,
JEFFREY EPSTEIN, the defendant, worked
es who facilitated his
others, including employees and associat
ng victims and
conduct by, among other things, contacti
EPSTEIN at the New York
scheduling their sexual encounters with
e.
Residence and at the Palm Beach Residenc
FACTUAL BACKGROUND
5. During all time periods charged in this
ndant, was a financier with
Indictment, JEFFREY EPSTEIN, the defe
united States, including
multiple residences in the continental
h Residence.
the New York Residence and the Palm Beac
EPSTEIN, the
6. Beginning in at least 2002, JEFFREY
caused to be enticed and
defendant, enticed and recruited, and
2
USAO 004342
EFTA_00022252
EFTA00171932
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
USA() 004343
EFTA_00022253
EFTA00171933
dence,
9. When a victim arrived at the New York Resi
with a massage table,
she typically would be escorted to a room
•
EPSTEIN, the
where she would perform a massage on JEFFREY
s of age,
defendant. The victims, who were as young as 14 year
to partially or fully
were told by EPSTEIN or other individuals
During the encounter,
undress before beginning the "massage."
e of physical contact
EPSTEIN would escalate the nature and scop
things, sex acts such as
with his victim to include, among other
with the victim's
groping and direct and indirect contact
during these
genitals. EPSTEIN typically would also masturbate
h him while he
sexualized encounters, ask victims to touc
with his hands or with
masturbated, and touch victims' genitals
sex toys.
r, JEFFREY
10. In connection with each sexual encounte
oyees or associates,
EPSTEIN, the defendant, or one of his empl
the victim in cash. Victims typically were paid hundreds
of dollars in cash for each encounter.
many of
11. JEFFREY EPSTEIN, the defendant, knew that
uding because certain
his New York victims were underage, incl
victims told him their age. Further, once these minor victims
EIN on multiple
were recruited, many were abused by EPST
dence. EPSTEIN
subsequent occasions at the New York Resi
to schedule appo intments
sometimes personally contacted victims
at the New York Residence. In other instances, EPSTEIN directed
4
USAO 004344
EFTA_00022254
EFTA00171934
New York-based employee
employees and associates, including a
ims via phone to arrange
("Employee-1"), to communicate with vict
York Residence for
for these victims to return to the New
EIN.
additional sexual encounters with EPST
te his
12. Additionally, and to further facilita
, JEFFREY EPSTEIN, the
ability to abuse minor girls in New York
of his victims to recruit
defendant, asked and enticed certain
and similarly engage in
additional girls to perform "massages"
sex acts with EPSTEIN. When a victim would recruit another girl
-recruiter and the new
for EPSTEIN, he paid both the victim
Through these victim-
victim hundreds of dollars in cash.
was able to abuse
recruiters, EPSTEIN gained access to and
dozens of additional minor girls.
ght dozens
13. In particular, certain recruiters brou
York Residence to give
of additional minor girls to the New
with JEFFREY EPSTEIN, the
massages to and engage in sex acts
additional
defendant. EPSTEIN encouraged victims to recruit
ecruiters for every
girls by offering to pay these victim-r
EIN. When a victim-
additional girl they brought to EPST
im to the New York
recruiter accompanied a new minor vict
and the new minor victim
Residence, both the victim-recruiter
EIN for each encounter. In
were paid hundreds of dollars by EPST
routinely scheduled these
addition, certain victim-recruiters
5
USAO 004345
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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 miner girls
in New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence. EPSTEIN frequently
traveled from New York to Palm Beach by private jet, before
which an employee or associate would ensure that minor victims
were available for encounters upon his arrival in Florida.
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times, two assistants ("Employee-2" and'
"Employee-3") who, as described herein, were also responsible
for scheduling sexual encounters with minor victims. Once
inside, the victim would provide a nude or semi-nude massage for
EPSTEIN, who would himself typically be naked. During these
encounters, EPSTEIN would escalate, the nature and scope of the
physical contact to include sex acts such as groping and direct
and indirect contact with the victim's genitals. EPSTEIN would
also typically masturbate during these encounters, ask victims
6
USAO 004346
EFTA_00022256
EFTA00171936
touch victims' genitals
to touch him while he masturbated, and
with his hands or with sex toys.
r, JEFFREY
16. In connection with each sexual encounte
employees or associates,
EPSTEIN, the defendant, or one of his
paid the victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
certain
. 17. JEFFREY EPSTEIN, the defendant, knew that
because certain victims
of his victims were underage, including
told him their age. In addition, as with New York-based
uited, were abused by
victims, many Florida victims, once recr
iple additional
JEFFREY EPSTEIN, the defendant, on mult
'occasions.
ng the
18. JEFFREY EPSTEIN, the defendant, who duri
York, would arrange
relevant time period was frequently in New
contact vict ims by phone in
for Employee-2 or other employees to
ensure appointments
advance of EPSTEIN's travel to Florida to
In particular, in certain
were scheduled for when he arrived.
s to minor victims in
instances, Employee-2 placed phone call
Beach Residence. At
Florida to schedule encounters at the Palm
s, EPSTEIN and Employee-2
the time of certain of those phone call
were in New York, New York. Additionally, certain of the
h Residence were
individuals victimized at the Palm Beac
schedule these encounters.
contacted by phone by Employee-3 to
7
USAO 004347
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EFTA00171937
steady
19. Moreover, as in New York, to ensure a
EIN, the defendant, asked
stream of minor victims, JEFFREY EPST
recruit other girls to
and enticed certain victims in Florida to
im-
engage in sex acts. EPSTEIN paid hundreds of dollars to vict
brought to the Palm
recruiters for each additional girl they
Beach Residence.
STATUTORY ALLEGATIONS
and
20. From at least in or about 2002, up to
hern District of New York
including in or about 2005, in the Sout
ndant, and others known
and elsewhere, JEFFREY EPSTEIN, the defe
did combine, conspire,
and unknown, willfully and knowingly
each other to commit an
confederate, and agree together and with
wit, sex trafficking of
offense against the United States, to
States Code, Section.
minors, in violation of Title 18, United
1591(a) and (b).
cy that
21. It was a part and object of the conspira
rs known and unknown,
JEFFREY EPSTEIN, the defendant, and othe
te and foreign commerce,
would and did, in and affecting intersta
provide, and obtain, by any
recruit, entice, harbor, transport,
lly and by receiving
means a person, and to benefit, financia
a venture which has
anything of value, from participation in
the person had not
engaged in any such act, knowing that
caused to engage in a
attained the age of 18 years and would be
8
USAO 004348
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EFTA00171938
e 18, United States
commercial sex act, in violation of Titl
Code, Sections 1591(a) and (b)(2).
Overt Acts
effect
22. In furtherance of the conspiracy and to
g overt acts, among
the illegal object thereof, the followin
rict of New York and
others, were committed in the Southern Dist
elsewhere:
a. In or about 2004, JEFFREY EPSTEIN, the
minor victims,
defendant, enticed and recruited multiple
in as Minor Victim-1,
including minor victims identified here
ge in sex acts with
Minor Victim-2, and Minor Victim-3, to enga
n, New York, and Palm
EPSTEIN at his residences in Manhatta
them with hundreds of
Beach, Florida, after which he provided
dollars in cash for each encounter.
b. In or about 2002, Minor Victim-1 was
EIN and was repeatedly
recruited to engage in sex acts with EPST
Residence over a
sexually abused by EPSTEIN at the New York
dollars for each
period of years and was paid hundreds of
r Victim-1
encounter. EPSTEIN also encouraged and enticed Mino
sex acts, which she
to recruit other girls to engage in paid
she was, and Minor
did. EPSTEIN asked Minor Victim-1 how old
Victim-1 answered truthfully.
the
c. In or about 2004, Employee-1, located in
lf of EPSTEIN, placed
Southern District of New York, and on beha
9
USA() 004349
EFTA_00022259
EFTA00171939
a telephone call to Minor Victim-1.in order to schedule an
appointment for Minor Victim-1 to engage in paid sex acts with
EPSTEIN.
d. In or about 2004, Minor Victim-2 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars after each
encounter. EPSTEIN also encouraged and enticed Minor Victim-2
to recruit other girls to engage in paid sex acts, which she
did.
e. In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-2 in order to schedule an
appointment for Minor Victim-2 to engage in paid sex acts with
EPSTEIN.
f. In or about 2005, Minor Victim-3 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars for each
encounter. _EPSTEIN also encouraged and enticed Minor Victim-3
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim-3 how old she was, and Minor
Victim-3 answered truthfully.
10
USFOD 004350
EFTA_00022260
EFTA00171940
the
g• In or about 2005, Employee-2, located in
lf of EPSTEIN, placed
Southern District of New York, and on beha
ida in order to
a telephone call to Minor Victim-3 in Flor
im-3 to engage in paid sex
schedule an appointment for Minor Vict
acts with EPSTEIN.
h. In or about 2004, Employee-3 placed a
r to schedule an
telephone call to Minor Victim-3 in orde
in paid sex acts with'
appointment for Minor Victim-3 to engage
EPSTEIN.
)
(Title 18, United States Code, Section 371.
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
23. The allegations contained in paragraphs'l
repeated and realleged
through 19 and 22 of this Indictment are
as if fully set forth within.
24. From at least in or about 2002, up to and
District of New
including in or about 2005, in the Southern
willfully and knowingly,
York, JEFFREY EPSTEIN, the defendant,
commerce, did recruit,
in and affecting interstate and foreign
obtain by any means a
entice, harbor, transport, provide, and
attained the.age of 18
person, knowing that the person had not
commercial sex act, and
years and would be caused to engage in a
recruited, enticed,
did aid and abet the same, to wit, EPSTEIN
obtained numerous
harbored, transported, provided, and
11
USAO 004351
EFTA_00022261
EFTA00171941
individuals who were less than 18 years old, including but not
limited to Minor Victim-1, as described above, and who were then
caused to engage in at least one commercial sex act in
Manhattan, New York.
(Title 18, United States Code, Sections 1591(a),
(b)(2), and 2.)
FORFEITURE ALLEGATIONS
25. As a result of committing the offense alleged in
Count Two of this Indictment, JEFFREY EPSTEIN, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594(c)(1), any property, real and
personal, that was used or intended to be used to commit or to
facilitate the commission of the offense alleged in Count Two,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Two, or any property traceable to
such property, and the following specific property:
a. The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at 9 East 71st Street, New York, New
York, with block number 1386 and lot number 10, owned by
Maple, Inc.
12
USAO 004352
EFTA_00022262
EFTA00171942
Substitute Asset Provision
26. If any of the above-described forfeitable
sion of the defendant:
property, as a result of any act or omis
of due diligence;
(a) cannot be located upon the exercise
deposited with, a
(b) has been transferred or sold to, or
third person;
tion of the Court;
(c) has been placed beyond the jurisdic
e; or
(d), has been substantially diminished in valu
which cannot
(e) has been commingled with other property
be subdivided without difficulty;
pursuant to 21 U.S.C.
it is the intent of the United States,
to seek forfeiture of any
§ 853(p) and 28 U.S.C. § 2461(c),
the value of the above
other property of the defendant up to
forfeitable property.
; Title 21,
(Title 18, United States Code, Section 1594
United States Code, Section 853( p); and
2461 .)
Title 28, United States Code, Section
EPERSON GEOFFREY S. BERMAN
United States Attorney
13 .
USAO 004353
EFTA_00022263
EFTA00171943
Form No. USA-33s-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
JEFFREY EPSTEIN,
Defendant.
'INDICTMENT
(18 U.S.C. §S 371, 1591(a), (b)(2),
and 2)
GEOFFREY S. BERMAN
United States Attorney
14
USAO 004354
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EFTA00171944
EXHIBIT B
2017.08.02
USAO_004355
EFTA_00022265
EFTA00171945
Mod AO 442 (09113) Arrest Wanarrt AUSA Name & Telno: isJlson Moe, 212-637-2225
UNITED STATES DISTRICT COURT
for the
Southern District of New York
United States of America
v.
Case No.
Jeffrey Epstein
19CEN 490
Deeendant
ARREST WARRANT
To: Any authorized law enforcement officer
YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay
(name °Jaen»), to be arrested) Jeffrey Epstein
who is accused of an offense or violation based on the following document filed with the court
Indictment 0 Superseding Indictment Cl Information 0 Superseding Information 0 Complaint
0 Fibbed= Violation Petition CI Supervised Release Violation Petition °Violation Notice CI Order of the Court
This offense is briefly deathbed as follows:
. Title 18, United States Code, Section 371 (sex trafficking conspiracy) %owl'',
Title 18, Linked States Code, Sections 1591(a), (b)(2), and (2) (sex trafficking of minors) •
%il l ' /,, ,''r,
41/4. ; '4",f •' ••
Date: 07/0212019
':'•,.
15, ; •' :t
•
City and state: New York, NY The Honorable Barbara Mosek,,U.B. taglWate Judge
Printed name and title
Bern
This warrant was received on (date) , and the person was arrested on (elate)
at (city andstate)
Date:
4Intabig qificeesslattalure
Printed name and tale
• USAO_004356
EFTA_00022266
EFTA00171946
EXHIBIT C
2017.08.02
USAO_004357
EFTA_00022267
EFTA00171947
AO 93 (SDNY Rut 01/17) Sarah cod Seiture Werrart
ra.
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Brie describe theproperly to be searched
or klent(5, the penon by name and address) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
(Ident(, the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (Went& the person or describe the property
to be seised): .
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the perion or
propertY.
7-40 lci
YOU ARE COMMANDED to execute this warrant on or before
ow to *wed 14 days)
e in the daytime 6:00 to 10 M. Cl at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court
O Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USWInitials
O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
will be
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property,
searched or seized (check the appropriate bos) Ofor days (not to exceed 30).
Otmtil, the facts justifying, specific date of
Date and time issued: - ‘O1AA ek:1A.
.hedge's signabere
City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
USAO 004358
EFTA_00022268
EFTA00171948
2)
AO 93 (SONY Rev.01/17)Se:itch and Seine Warrant(Pago
Return
Date and time warrant executed: Copy of warrant and inventory left with:
Case No.:
Inventory made in the presence of:
seized:
Inventory of the property taken and name of any person(s)
Certification
and was returned along with the original warrant
I declare under penalty of perjury that this inventory is correct
to tho Court.
Date: Executing rates signal=
Printed name and title
USAO 004359
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EFTA00171949
ATTACHMENT A
L Premises to be Searched—Subject Premises
1. The premises to be searched (the "Subject Premises") are described as a nearly
19,000.square foot multi-story single-family residence located at 9 East 71st Street, New York,
New York, and include all locked and closed containers found therein. A photograph of the front
entrance to the Subject Premises is included below:
IL Items to Be Seized
1. This warrant authorizes executing agents to photograph, video record and otherwise
document the full interior of the Subject Premises, including any items, furnishings, or possessions
therein.
• • 2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sox trafficking of
minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy or ownership of the Subject Premises,
including utility and telephone bills, mail envelopes, addressed correspondence,
diaries, statements, identification documents, address books, telephone
directories, and photographs of its occupant(s).
b. Evidence concerning the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2017.08.02
USAO_004360
• EFTA_00022270
EFTA00171950
EXHIBIT D
2017.08.02
USAO_004361
EF1,00022271
EFTA00171951
AO 93 (SONY Rev. 01/I 7 ) Search and Seizure Will0111
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
Briefly describe the property to be searched
or identify the person by name and address) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of Jew York
(identify the person or describe the property to be searched and give Its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (ident1)5, the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory &colons):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before July 7, 2019
(not to exceed 14 days)
O in the daytime 6:00 M.
to 10 Rlf at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
O Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USW Initials
O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or Seized (check the appropriate box) Ofor days (not to exceed JO).
Ountil, the facts justify' later specific date o
Date and time issued: .1 tq tkiz3a,µ Judge's signature
City and state: New York. NY Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
USAO 004362
EFTA_00022272
EFTA00171952
AO 93 (SONY Rev.OM 7)Search end Seizure Werrani(Page 2)
Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:
Inventory made in the presence of:
Inventory of the property taken and name of any person(s) seized:
Certification
warrant
I declare under penalty of perjury that this inventory is correct and was returned along with the original
to the Court.
Date: _ .
Executing officer's signature
Printed name and fide
USAO_004363
EFTA_00022273
EFTA00171953
ATTACHMENT A
1. Premises to be Searched—Subject Premises
I. The premises to be searched (the "Subject Premises") are described as a multi-story
single-family residence located at 9 East 71st Street, New York, New York, and include all locked
and closed containers found therein. A photograph of the front entrance to the Subject Premises
is included below:
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title IS, United States Code, Sections 1591 (sex trafficking of minors) and 371
(sex trafficking conspiracy) (the "Subject Offenses") described as follows:
i. Any and all taxidennied dogs.
ii. Any and all massage tables and massage paraphernalia.
iii. Any and all busts or three-dimensional representations of female human
torsos.
iv. Any and all photos or representations depicting nude or partially nude
women located in the Massage Room, as defined herein.
v. Any and all sex toys and sex paraphernalia located in the Massage
Room, as defined herein.
2017.05.02
USAO 004364
EFTA_00022274
EFTA00171954
vi. A binder labeled "PB Girls" and any other documents or
communications with or regarding victims or potential victims of the
Subject Offenses.
2
2017.08.02
• USAO_004365
EFTA_00022275
EFTA00171955
EXHIBIT E
2017.08.02
USAO_004366
EFT/1_00022276
EFTA00171956
AU 93 (SDNY 01/17) Sean:1r and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District ofNew York
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
(ides?* the person or describe the property to be searchedand give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seised):
See Attachment A
The search and seizure are related to violation(s) of(insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I fmd that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before July 21, 2019
(not to exceed 14 Any
O in the daytime 6:00E. to 10 M.d at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
O Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USW Initials
O 1 find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), mid authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate bar) Ofet.wr days (not to mead341.
Ountil, the facts 'ustifying, the later specific date of
Date and time issued: `%'.?ca?-µ
• signature
City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and tide
USAO_004367
EFTA_00022277
EFTA00171957
A093 (SONY Rev. MU) Search and Same Wanant (Page 3)
Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:
Inventory made in the presence of:
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
&stiffing officer's signature
Primedname and ad.
USAO_004368
EFTA_00022278
EFTA00171958
ATTACHMENT A
I. The Subject Devices to Be Searched
The Subject Devices are particularly described as compact discs stored in containers
marked with FBI evidence numbers 15, 16, 17, 18, and 22., seized from the residence located at 9
East 71st Street, New York, New York, on or about July 7, 2019.
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex
trafficking conspiracy) (the "Subject Offenses") described as follows:
1. Any documents of communications with or regarding victims or potential victims
of the Subject Offenses;
2. Any photographs of victims or potential victims of the Subject Offenses;
3. Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger,
4. Motion pictures, films, videos, and other recordings of visual or written depictions
of minors engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2);
5. Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usemames and passwords, user profiles, e-mail contacts, and photographs;
6. Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
B. Review of ESI
Law enforcement personnel (including, in addition to law enforcement officers and agents,
and depending on the nature of the ESI and the status of the investigation and related proceedings,
attorneys for the government, attorney support staff, agency personnel assisting the government in
this investigation, and outside technical experts under government control) will create a forensic
image of the Subject Devices (if practicable) and review the ESI contained therein for information
responsive to the warrant.
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
2017.08.02
USAO_004369
EFTA_00022279
EFTA00171959
• surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
• conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately bidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation6; and
• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section
II.A of this Attachment. However, law enforcement personnel are authorized to conduct a
complete review of all the ESI from seized devices or storage media if necessary to evaluate its
contents and to locate all data responsive to the warrant.
6 Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
keyword searches work only for text data, yet many types of files, such as images and videos, do
not store data as searchable text. Moreover, even as to text data, there may be information properly
subject to seizure but that is not captured by a keyword search because the information does not
contain the keywords being searched.
2
2017.08.02
USAO_004370
EFTA_00022280
EFTA00171960
EXHIBIT F
2017.08.02
USA0_004371
EFTA_00022281
EFTA00171961
AO 93 (SONY Rot OM) Satoh and Sea= Wanat
UNITED STATES DISTRICT COURT
for the
Southern District of New York —
In the Matter of the Search of
(Briefly describe theproperty to be searched
)
)
1 9MAG 6 4 3 9
or Went& theperson by name andaddress) ) Case No. 19 Cr. 490 (RMB)
See Attachment A )
)
)
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southe District of New York
Went(fy the person or describe theproperty to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal Went* the person or describe theproperty
to be se reap:
See Attachment A
The search and seizure are related to violation(s) of (Seristatutory citations):
Title 18, United States Code, Sections 371 and 1591 •
I fmd that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property. •
or before July12, 2019
YOU ARE COMMANDED to execute this warrant on
• (not to exceed14 days)
t5 in the daytime 6:00 a.m. to 10 at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you, must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
❑ Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
usiaIn!tlals
O I find that immediate notification may have an adverse result listed in 18 § pos (except for delay
of trial), and authorize the officer executing this warrant to delay notice to thaptirrma'..tho,p whose property, will be
searched or seized Peck the appropriate box) Ofor days (not to cresol:60.r . • . • , • .
Ountil, the facts justifying, ttAriatef:skecific date of
Date end time issued: -7 ( •• ;$/,iiesg-ilsitIFP :
• 1.1.
City and state: New York, NY Hon. Henry pit7 n: liS2Nlistraie Judge
'''PrfA/99,114Ifi;*?qe‘
USAO 004372
EFTA_00022282
EFTA00171962
A093 (SONY Rev.01/17)Search and Seizure warrant(Page 2)
Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
along with the original warrant
I declare under penalty of perjury that this inventory is correct and was returned
to the Court.
Date:
Keeeittbkg officer's signature
Printedname and title
USAO_004373
EFTA_00022283
EFTA00171963
ATTACHMENT A
L Premises to be Searched—Subject Premises
1. The premises to be searched (the "Subject Premises") are described as a multi-story
single-family residence located at 9 East 71st Street, New York, New York, and include all ocked
and closed containers found theitin. A photograph of the front entrance to the Subject Premises
is included below:
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex
trafficking conspiracy) (the "Subject Offenses") described as follows:
The items to be seized from the Subject Premises are any computer devices and storage
media that may contain any electronically stored information falling within the categories set forth
in Section B of this Attachment, including, but not limited to, desktop and laptop computers, disk
drives, modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners,
routers, modems, and network equipment used to connect to the Internet. In lieu of seizing any
such computer devices or storage media, this warrant also authorizes, in the alternative, the
copying of such devices or media for later review. •
The items to be seized from the Subject Premises also include:
2017.08.02 USAO_004374
EFTA_00022284
EFTA00171964
1. Any items or records needed to access the data stored.= any seized or copied
computer devices or storage media, including but not limited to any physical keys, encryption
devices, or records of login credentials, passwords, private encryption keys, or similar information.
2. Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or software manuals or other information
concerning the configuration of the seized or copied computer devices or storage media.
3. Any evidence concerning the identities or locations of those persons with access to,
control over, or ownership of the seized or copied computer devices or storage media.
B. Search and Seizure of Electronically Stored Information
As set forth in Section A to this attachment, this warrant authorizes the search of the Subject
Premises for any computer devices and storage media that may contain any electronically stored
information falling within the categories set forth below:
4. Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
5. Any photographs of victims or potential victims of the Subject Offenses;
6. Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger;
7. Records or other items that evidence ownership, control, or use 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 arnos, handwritten notes, registry entries, configuration files, saved
usemames and passwords, user profiles; e-mail contacts, and photographs;
8. Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
C. Review of ESI
Law enforcement personnel (including, in addition to law enforcement officers and agents,
and depending on the nature of the ESI and the status of the investigation and related proceedings,
attorneys for the government, attorney support staff, agency personnel assisting the government in
this investigation, and outside technical experts under government control) will create a forensic
image of the Subject Devices (if practicable) and review the BSI contained therein for information
responsive to the warrant, that is, for the materials specified in Section B of this Attachment
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
2
2017.08.02 USAO_004375
EFTA_00022285
EFTA00171965
• 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 "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation6; and
• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section
ITS of this Attachment However, law enforcement personnel are authorized to conduct a
complete review of all the EST from seized devices or storage media if necessary to evaluate its
contents and to locate all data responsive to the warrant
6 Keyword searches alone are typically inadequate to detect all relevant data. For
one thing,
keyword searches work only for text data, yet many types:of files, such* as images and videos, do
not store data as searchable text. Moreover, even as to text data, there may be information properly
subject to seizure but that is not captured by a keyword search because the information does not
contain the keywords being searched.
2017.08.02 USAO_004376
EFTA_00022286
EFTA00171966