EFTA00171832

AO 106 (SDNY Rev. 011)7) Application ror a Smell 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 ientib the person by name andaddress) See Attached Affidavit and its Attachment A M p...„ nitrAG 571 APPLICATION FOR A SEARCH AND SEIZURE WARRANT 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 searchedand give its location): located in the Southern District of New York , there is now concealed (Identify the person or describe the property to be seised): See Attached Affidavit and its Attachment A for the search under Fed. It Crim. P. 41(c) is (check one or more): Therr vidence of a crime; ntraband, fruits of crime, or other items illegally possessed; O property designed for use, intended for use, or used in committing a crime; O a person to be arrested or a person who is unlawfully restrained. The search is related to a violation of: Code Section(s) Offense Description(s) 18 U.S.C. §§ 1591 and Sex trafficking of minors; sex trafficking conspiracy 371 The application is based on these facts: See Attached Affidavit and its Attachment A Continued on the attached sheet. O Delayed notice of days (give exact ending date if more than 30 days: ) is requested under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. (Ipplioant signaiare SpeG!.Age&FBI ;Feintedname and title Sworn to before me and signed in my presence. Date: 07/07/2019 hcige's:Oahe* City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge Printedname and title --4;1414..Va\ONQ..42..Sap_Vr. (114.0A-S USAO 004242 C C- aCe In. &S.) EFTA_00022152 EFTA00171832 UNITED STATES DISTRICT COURT 1 .-.)IVIAG ob SOUTHERN DISTRICT OF NEW YORK In the Matter of the Application of the United TO BE FILED UNDER SEAL States Of America for a Search and Seizure Warrant for Compact Discs marked with FBI Agent Affidavit in Support of evidence numbers 15, 16, 17, 18, and 22, Seized Application for Search and Seizure from 9 East 71° Street, New York, NY on or Warrant about July 7, 2019, and Any Files or Media Stored Therein SOUTHERN DISTRICT OF NEW YORK) ss.: being duly sworn, deposes and says: I. Introduction A. Affiant I. I have been a Special Agent with the Federal Bureau of Investigation ("FBP") since 2012. As such, I am a "federal law enforcement officer" within the meaning of Federal Rule of Criminal Procedure 41(aX2XC), that is, a government agent engaged in enforcing the criminal laws and duly authorized by the Attorney General to request a search warrant. I have been employed by the FBI for three and a half years, and I am currently assigned to investigate violations of criminal law relating to the sexual exploitation of children. 1 have gained expertise in this area through classroom training and daily work related to these types of investigations. As part of my responsibilities, I have been involved in the investigation of sex trafficking cases, and have been involved in search warrants for electronic storage media. 2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal Rules of Criminal Procedure for a warrant to search the storage media specified below (the "Subject Devices") for the purpose of seizing the items and information described in Attachment A. This affidavit is based upon my personal knowledge; my review of documents and other evidence; and my conversations with other law enforcement personnel. Because this 1 2017.08.02 USAO_004243 EFTA_00022153 EFTA00171833 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 ofdocuments and the actions, statements, and conversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated. B. The Subject Devices 3. The Subject Devices are particularly described as compact discs stored in containers marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence of JEFFREY EPSTEIN located at 9 East 71st Street, New York, New York (the "Epstein Residence"), on or about July 7, 2019. C. The Target Subject and the Subject Offenses 4. The Target Subject of this investigation is JEFFREY EPSTEIN. 5. For the reasons detailed below, I believe that there is probable cause to believe that the Subject Devices contain evidence, fruits, and instrumentalities of violations ofTitle 18, United States Code, Section 1591 (sex trafficking of minors); Title 18, United States Code, and Section 371 (sex trafficking conspiracyXthe "Subject Offenses") by the Target Subject. II. Probable Cause 6. On or about July 2, 2019, a grand jury in this District returned an Indictment charging JEFFREY EPSTEIN with violations of Title 18, United States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 371 (sex trafficking conspiracy). A copy of the Indictment is attached hereto as Exhibit A and is incorporated by reference. The Indictment and Victim-1 7. As set forth in Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern District of New York and elsewhere. During that time and continuing to the present, EPSTEIN 2 2017.08.02 USAO_004244 EFTA_00022154 EFTA00171834 possessed and controlled the Epstein Residence, which is described in Exhibit A as "the New York Residence." 8. As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous minor victims at the Epstein Residence. In particular, and as alleged in the Indictment, when a victim arrived at the Epstein Residence, she would be escorted to a room inside the Epstein Residence with a massage table, where she would perform a massage on EPSTEIN. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victims' genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. Following each encounter, EPSTEIN or one of his employees or associates paid the victim in cash. 9. As set forth in paragraphs 12 through 13 ofExhibit 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. 3 2017.08.02 USAO_004245 EFTA_00022155 EFTA00171835 10. One of the victims identified in paragraph 22 ofExhibit A is Victim-1. As part of the FBI's investigation of EPSTEIN, other law enforcement officers have interviewed Victim-1} I know from my conversations with other law enforcement officers who have interviewed Victim- I, that Victim-1 has provided the following information, in substance and in part: a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-I on multiple occasions in the Epstein Residence. This sexual abuse all occurred when Victim-1 was under the age of 18. b. During that same period, Victim-1 observed multiple floors of the Epstein Residence and numerous individual rooms within the Epstein Residence. Victim-1 has provided detailed descriptions of certain aspects of the interior of the Epstein Residence, including Victim- I 's memory of specific details regarding the layout, furnishings, decorations, and floor pattern of various areas within the Epstein Residence. c. In particular, Victim-1 observed that a bathroom in the residence contained what appeared to be a bust of a human torso (the "Torso"). Victim-1 believed that the Torso was possibly a type of sex toy. d. In addition, Victim-1 recalled observing what appeared to be a taxidermied dog in a living space in the Epstein Residence. Victim-1 has also disclosed Victim- Information provided by Victim-1 has proven reliable and has been corrobora epen ent evidence, including documents and records obtained during the investigation and the accounts of other victims whom Victim-1 has never met. 4 2017.08.02 USAO_004246 EFTA_00022156 EFTA00171836 e. Victim-1 recalled that EPSTEIN typically abused her in a room she described as a "massage room," (the "Massage Room"), which contained a massage table, and was decorated with artwork depicting naked women, hung on walls that appeared to be adorned with fabric. f. Victim-1 has not been in the Epstein Residence since approximately 2005. The July 6.2019 Search Warrant of the Epstein Residence 11. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search ofthe Epstein Residence (the "First Warrant"). 12. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the "Search Team") commenced executing the search warrant at the Epstein Residence; I joined the Search Team thereafter. 13. Based on the Search Team's observations during an initial search of the Epstein Residence, at approximately 7 p.m., the Search Team stopped the search and froze the scene in order to seek a new search warrant. 14. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the Epstein Residence (the "Second Warrant"). The search warrant is attached as Exhibit B, and incorporated by reference herein. At approximately 2:30 a.m., the Search Team resumed the search, and commenced searching pursuant to the Second Warrant. 15. Based on my conversations with members of the search team, and my participation in the search, I have learned the following: a. Inside a safe in a closet on the third floor, the Search team discovered, among other items, several binders containing sleeves of compact discs, most of which are labeled with handwriting. In total, the binders contain dozens ofcompact discs. One disc is marked 'MI -- 5 2017.08.02 USAO_004247 EFTA_00022157 EFTA00171837 Another is marked "Misc. Nudes." " Another disc is marked "Nudes 00-24." "LSJ." For Some discs contain the word "Zorro" or Yet another is marked "Girl Pies Nude." enforcement Pies." Based on my conversations with law example, one disc is marked 'IlliZorro o stigation, I believe the name "Zorro" refers to Zorr agents who have participated in this inve Saint James, ico, and the name LSJ refers to Little Ranch, EPSTEIN's property in New Mex that include ds. The majority of the discs contain titles EPSTEIN's property in the U.S. Virgin Islan ers seized by the Search Team have titles that appear female names. Some of the discs in the bind , where based n that these discs were contained in a safe to refer to trips or vacations. However, give these discs contraband is often stored, and given that on my training and experience I know that able cause girls and nudes, I submit that there is prob were stored together with discs referencing the Subject by the Search Team contain evidence of that all of the discs in the binders seized Offenses.2 the Fifth floor of the Epstein residence, the b. In the drawer of a dresser in a room on numerous s, a shoebox (the "Shoebox") containing Search team discovered, among other item One labe led, in handwriting, with female names. compact discs: The majority of the discs are Yet another disc is marked "Blonde Girl Photo Shoot" disc is marked "Thai Massage." Another were seized by r—Scientists." The discs in the Shoebox disc is marked "Misc. Girls Nude/Dinne loose sam e dresser, the Search Team discovered the Search Team. In another drawer of that rience, females who, based on my training and expe polaroid photographs depicting young, nude marked, in er, the Search Team discovered a folder appear to be teenagers. In that same draw majority behind binders that contained discs, where the 2 During the search, the Search Team left nude s. Acc ordi ngly, did not appear to refer to girls or of the discs were labeled in a manner that were left at the to search those compact discs, which this application does not seek authorization Epstein Residence. 6 2017.08.02 USAO_004248 EFTA_00022158 EFTA00171838 nude and sexually suggestive handwriting, .1" which contained photographs, including ger than training and experience appears to be youn photographs ofa young girl who, based on my s, based phs of young girls who appear to be teenager IS. The folder contains other nude photogra at Lilt (the folder is a compact disc marked ill on my training and experience. Inside the s in m. Given that the labels of the compact disc Disc"), which was seized by the Search Tea discs in the and the name of a girl, and the fact that the Shoebox reference "massage," "girls," and sexually from a dresser that also contained nude Shoebox and the III Disc were seized cause to believe respectfully submit that there is probable suggestive photographs of a young girl, I ject Offenses. the disc s seiz ed from the Sho ebox and the. Disc contain evidence of the Sub that ed, tein Residence, the Search Team discover c. In a closet on the Fifth Floor ofthe Eps other items, /old photos." The box contained, among among other items, a box marked "women disc is marked roxim ately seve n com pact disc s, whic h are labeled with hand-written titles. One app ain titles graphera '03" The remaining discs cont "nudes 00-24." Another is labeled "Photo m. Given that going discs were seized by the Search Tea that include female names. All of the fore "women/old thes e disc s is mar ked "nud es" and that the discs were stored in a box marked one of mit that there is ed from the Epstein Residence, I sub photos," and given the other evidence seiz ence of the Subject Offenses. probable cause that the discs contain evid ing discovered numerous black binders contain d. In that same closet, the Search Team com pact discs. ographs (with file names underneath) and what appear to be print outs ofdigital phot appeared to ten binders (the "Seized Binders")3 which The Search Team seized approximately girls , some of ographs of nude or partially nude young contain, among other photographs, phot e of the young Based on my training and experience, som which are in sexually suggestive poses. 3 The Search Team did not seiz e the remaining binders. 7 2017.08.02 USAO_004249 EFTA_00022159 EFTA00171839 ers m appear to be under the age of 18. The Seized Bind girls appear to be teenagers, some of who el. However, to be family functions, events, and trav also include photographs of what appear phs of nude or ers were stored together with photogra given that the discs in the Seized Bind Seized nud e you ng girls , I sub mit that ther e is probable cause that all of the discs in the partially nses! Binders contain evidence of the Subject Offe Tea m and described in paragraphs 15(a)-(d) e. The compact discs seized by the Search York in stored within the Southern District of New are the Subject Devices, and are currently bers 15, 16, 17, 18, and 22. containers marked with FBI evidence num d the search and seizure for "any other 16. The Second Warrant expressly authorize of the Subject regarding victims of potential victims documents of communications with or because, authorizes the search ofthe Subject Devices Offenses." Accordingly, the Second Warrant ar to able cause to believe they included discs that appe based on their markings, there was prob Subject girls who may be victims of the contain documents regarding underage an abundance not yet reviewed the Subject Devices. In Offenses. However, law enforcement has ch the ther efor e, I resp ectf ully requ est that the Court issue a warrant to seize and sear of caution, and Seizure ent A to this affidavit and to the Search items and information specified in Attachm Warrant. mit that there is probable cause to believe 17. Based on the foregoing, I respectfully sub of the Subject Offenses. that the Subject Devices contain evidence discs, where the majority 4 During the search, the Search Team left behind binders that contained s. Accordingly, that did not appear to refer to girls or nude of the discs were labeled in a manner left at the app licat ion does not seek auth oriza tion to search those compact discs, which were this Epstein Residence. 8 2017.08.02 USAO_004250 EFTA_00022160 EFTA00171840 III. Procedures for Searching ESI A. Review of ESI ement officers and IS. Law enforcement personnel (including, in addition to law enforc of the investigation and related agents, and depending on the nature of the ESI and the status agency personnel assisting the proceedings, attorneys for the government, attorney support staff, ts under government control) will government in this investigation, and outside technical exper review the ESI contained therein create a forensic image of the Subject Devices (if practicable) and for information responsive to the warrant. various techniques 19. In conducting this review, law enforcement personnel may use of the Subject Offenses. Such to determine which files or other ESI contain evidence or fruits techniques may include, for example: they contain (analogous to • surveying directories or folders and the individual files ns and opening a drawer looking at the outside of a file cabinet for the markings it contai believed to contain pertinent files); the first few "pages" of such • conducting a file-by-file review by "opening" or reading gous to performing a cursory files in order to determine their precise contents (analo ine its relevance); examination of each document in a file cabinet to determ r recently deleted data or • "scanning" storage areas to discover and possibly recove deliberately hidden files; and all electronic storage areas to • performing electronic keyword searches through to the subject matter of determine the existence and location of data potentially related the investigations; and les, registry data, and any • reviewing metadata, system information, configuration fi the computer was used. other information reflecting how, when, and by whom detect all relevant data. For one thing, s Keyword searches alone are typically inadequate to of files, such as images and videos, do keyword searches work only for text data, yet many types text data, there may be information properly not store data as searchable text. Moreover, even as to rd search because the information does not subject to seizure but that is not captured by a keywo contain the keywords being searched. 9 2017.08.02 USAO_004251 EFTA_00022161 EFTA00171841 20. Law enforcement personnel will make reasonable efforts to restrict their search to data falling within the categories of evidence specified in the warrant. Depending on the circumstances, however, law enforcement personnel may need to conduct a complete review of all the ESI from seized devices or storage media to evaluate its contents and to locate all data responsive to the warrant. B. Return of ESI 21. If the Government determines that the electronic devices are no longer necessary to retrieve and preserve the data, and the devices themselves are not subject to seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return these items, upon request. Computer data that is encrypted or unreadable will not be returned unless law enforcement personnel have determined that the data is not (i) an instrumentality of the offense, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, or (v) evidence of the Subject Offenses. IV. Conclusion and Ancillary Provisions 22. Based on the foregoing, I respectfully submit there is probable cause to believe that evidence of the Subject Offenses, and in particular the items described in Attachment A, will be located within the Subject Devices and therefore request the court to issue a warrant to seize the items and information specified in Attachment A to this affidavit and to the Search and Seizure Warrant. 10 2017.08.02 USAO_004252 EFTA_00022162 EFTA00171842 23. The investigation is ongoing, and the investigative team anticipates beginning a search of the Subject Devices this evening, possibly after 10 p.m. In view of the circumstances, I submit that good cause exists to begin the search after 10 p.m. Special Agent Federal Bureau ofInvestigation Sworn to before me on July 7, 2019 THE HONORABLE BARBARA MOSES UNITED STATES MAGISTRATE JUDGE ‘makerSert9- .23Q1Nici\t_ szgalua Cc-ctizekkosA) II 2017.08.02 USAO_004253 EFTA_00022163 EFTA00171843 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. H. Items to Be Seized A. Evidence, Fruits, and Instrumentalities of the Subject Offenses This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: I. Any documents or communications with or regarding victims or potential victims of the Subject Offenses; 2. Any photographs of victims or potential victims of the Subject Offenses; 3. Any nude, partially nude, or sexually suggestive photographs of individuals who appear to be teenage girls, or younger; 4. Motion pictures, films, videos, and other recordings of visual or written depictions of minors engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2); 5. Records or other items that evidence ownership, control, or use of, or access to devices, storage media, and related electronic equipment used to access, transmit, or store information relating to the Subject Offenses, including, but not limited to, sales receipts, warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved usernames and passwords, user profiles, e-mail contacts, and photographs; 6. Any child erotica, defined as suggestive visual depictions of nude minors that do not constitute child pornography as defined by 18 U.S.C. § 2256(8). B. Review of ESI Law enforcement personnel (including, in addition to law enforcement officers and agents, and depending on the nature of the ESI and the status of the investigation and related proceedings, attorneys for the government, attorney support staff, agency personnel assisting the government in this investigation, and outside technical experts under government control) will create a forensic image of the Subject Devices (if practicable) and review the ESI contained therein for information responsive to the warrant. In conducting this review, law enforcement personnel may use various techniques to determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such techniques may include, for example: 2017.08.02 USAO_004254 EFTA_00022164 EFTA00171844 • surveying directories or folders and the individual files they contain (analogous to looking at the outside ofa file cabinet for the markings it contains and opening a drawer believed to contain pertinent files); • conducting a file-by-file review by "opening" or reading the first few "pages" of such files in order to determine their precise contents (analogous to performing a cursory examination of each document in a file cabinet to determine its relevance); • "scanning" storage areas to discover and possibly recover recently deleted data or deliberately hidden files; and • performing electronic keyword searches through all electronic storage areas to determine the existence and location of data potentially related to the subject matter of the investigation6; and • reviewing metadata, system information, configuration files, registry data, and any other information reflecting how, when, and by whom the computer was used. Law enforcement personnel will make reasonable efforts to search only for files, documents, or other electronically stored information within the categories identified in Section 11.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_004255 EFTA_00022165 EFTA00171845 EXHIBIT A 2017.08.02 USAO_004256 EF1,00022166 EFTA00171846 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x SEALED UNITED. STATES OF AMERICA INDICTMENT 19 Cr. JEFFREY EPSTEIN, Defendant. 19 CIO 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 USAO 004257 EFTA_00022167 EFTA00171847 this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in. locations including New York and Palm Beach. 3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the age of 18, including because, in some instances, minor victims expressly told him their age. 4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence. FACTUAL BACKGROUND 5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence. 6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and 2 USAO 004258 EFTA_00022168 EFTA00171848 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 USFOD 004259 EFTA_00022169 EFTA00171849 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. Fuither, 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 4 USAO 004260 EFTA_00022170 EFTA00171850 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 5 USACI) 004261 EFTA_00022171 EFTA00171851 encounters through Employee-1, who sometimes asked the recruiters to bring a specific minor girl for EPSTEIN. The Palm Beach Residence 14 In addition to recruiting and abusing minor girls in New York, JEFFREY EPSTEIN, the defendant, created a similar network of minor girls to victimize in Palm Beach, Florida, where EPSTEIN owned, possessed and controlled another large residence, i.e., the Palm Beach Residence. EPSTEIN frequently traveled from New York to Palm Beach by private jet, before which an employee or associate would ensure that minor victims were available for encounters upon his arrival in Florida. 15. At the Palm Beach Residence, JEFFREY EPSTEIN, the defendant, engaged in a similar course of abusive conduct. When a victim initially arrived at the Palm Beach Residence, she would be escorted to a room, sometimes by an employee of EPSTEIN's, including, at times, two assistants ("Employee-2" and "Employee-3") who, as described herein, Were also responsible for scheduling sexual encounters with minor victims. Once inside, the victim would provide a nude or semi-nude massage for EPSTEIN, who would himself typically be naked. During these encounters, EPSTEIN would escalate the nature and scope of the physical contact to include sex acts such as groping and direct and indirect contact with the victim's genitals. EPSTEIN would also typically masturbate during these encounters, ask victims 6 USAO 004262 EFTA_00022172 EFTA00171852 to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. 16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars for each encounter. 17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions. 18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance of EPSTEIN's travel to Florida to ensure appointments were scheduled for when he arrived. In particular, in certain instances, Employee-2 placed phone calls to minor victims in Florida to schedule encounters at the Palm Beach Residence. At the time of certain of those phone calls, EPSTEIN and Employee-2 were in New York, New York. Additionally, certain of the individuals victimized at the Palm Beach Residence were contacted by phone by Employee-3 to schedule these encounters. 7 USAO 004263 EFTA_00022173 EFTA00171853 19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victim- recruiters for each additional girl they brought to the Palm Beach Residence. STATUTORY ATJRGATIONS 20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section. 1591(a) and (b). 21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a 8 USAO 004264 EFTA_00022174 EFTA00171854 commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2). Overt Acts 22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter. b. In or about 2002, Minor Victim-1 was recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage •in paid sex acts, which she did. EPSTEIN asked Minor Victim-1 how old she was, and Minor Victim-1 answered truthfully. c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed 9 USAID 004265 EFTA_00022175 EFTA00171855 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 USAO 004266 EFTA_00022176 EFTA00171856 g. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN. h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with' EPSTEIN. (Title 18, United States Code, Section 371.) COUNT TWO (Sex Trafficking) The Grand Jury further charges: 23. The allegations contained in paragraphs 1 through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within. 24. From at least in or about 2002, up to. and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the'defendant, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous 11 USAO 004267 EFTA_00022177 EFTA00171857 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 004268 EFTA_00022178 EFTA00171858 Substitute Asset Provision 26. If any of the above-described forfeitable property, as a result of any act or omission of the defendant: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third person; (c) has been placed beyond the jurisdiction of the Court; (d). has been substantially diminished in value; or (e) has been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, pursuant to 21 U.S.C. 853(p) and 28 U.S.C. S 2461(c), to seek forfeiture of any other property of the defendant up to the value of the above forfeitable property. (Title 18, United States Code, Section 1594; Title 21, United States Code, Section 853(p); and Title 28 United States Code, Section 2461.) GEOFFREY 5. BERMAN United States Attorney 13 USAO 004269 EFTA_00022179 EFTA00171859 k 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 O.S.C. SS 371, 1591(a), (b)(2), and 2) GEOFFREY S. BERMAN 19 USAO_004270 EFTA_00022180 EFTA00171860 EXHIBIT B 13 2017.08.02 USA0_004271 EF1,00022181 EFTA00171861 iyUNY Kt's. , .1."171Scardl and Seaute WORM UNITED STATES DISTRICT COURT for the Southern District of New York In the Matter of the Search of (Briefly describe the prolvro. to be searched or Montt:he 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 admit the person or describe the poperty to be .earched and give Inlocation): See Attachment A The person or property to be searched, described above, is believed to conceal /Nemo, PenOn Or describe the ItoPerrY to be seixely: See Attachment A The search and seizure arc related to violation(s) of (insert sraturocretiortems): 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 a.m. to 10 p.m. at any time in the day or night as I find reasonable cause has been established. Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place where the property was taken. The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory as required by law and promptly return this warrant and Inventory to the Clerk of the Court. ID Upon its return, this warrant and inventory should be filed under seal by the Clerk ortbe-Court. LOW 0 I find that immediate notification may have an adverse result listed in IS U.S.C..§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person wbo, or whose properly, will be searched or seized (check the appropriate box) Ofor days (not to exceed 30). • Ountil. the facts justifyi later spetific date o — • Date and time issued: '1 -1 TAct rkaa.ft. Judge smgriande City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judje Printedmane and title USAO0114277 EFTA_00022182 EFTA00171862 A093 (SONY Rev. 01/17) Smith and Stint %Yanant (Pus 21 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 Tine 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 Coon. Date: ..._ ___ brewing officer's signature hintedname andiiik USAO_004273 EFTA_00022183 EFTA00171863 ATTACHMENT A I. Premises to be Searched—Subject Premises 1. The premises to be searched (the "Subject Premises") are described as a multi-story single-family residence located at 9 East 71st Street, New York, New York, and include all locked and closed containers found therein. A photograph of the front entrance to the Subject Premises is included below: II. Items to Be Seized A. Evidence, Fruits, and Instrumentalities of the Subject Offenses This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371. (sex trafficking conspiracy) (the "Subject Offenses") described as follows: i. Any and all taxidermied dogs. ii. Any and all massage tables and massage paraphernalia. iii. Any and all busts or three-dimensional representations of female human torsos. iv. Any and all photos or representations depicting nude or partially nude women located in the Massage Room, as defined herein. v. Any and all sex toys and sex paraphernalia located in the Massage Room, as defined herein. 2017.03.02 USAO_004274 EFTA_00022184 EFTA00171864 vi. A binder labeled "PB Girls" and any other documents or communications with or regarding victims or potential victims of the Subject Offenses. 2 20 1 7 .03.02 USAO_004275 EFTA_00022185 EFTA00171865