AO 106 (SDNY Rev. 01/17) Applxaton for a Search Warrant
UNITED STATES DISTRICT COURT
for the
Southern District rev ,ii
In the Matter of the Search of
itAG 8 5 7 9
(Briefly describe the property to be searched
or dent& the person by name and address) Cmc No.
27 electronic devices seized on
August 12, 2019 from Little Saint James in the
Virgin Islands
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 °dent& the person or describe the
property to be searched and give its location):
located in the Southern District of New York , there is now concealed (identift the
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
The basis for the search under Fed. IL Crim. P. 41(c) is (check one or more):
X 0 evidence of a crime;
Cl contraband, fruits of crime, or other items illegally possessed;
O property designed for use, intended foruse, or used in committing a crime;
Cl a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Secdon(s) Offense Description(s)
18 USC 1591 Sex Trafficking of Minors
18 USC 371 Sex Trafficking Conspiracy
The application is based on these facts:
See Attached Affidavit and its Attachment A
Continued on the attached sheet.
Cl 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.
Applicant's Orman, ,
Task Force Officer:11i Byrne, FBI
Printed name and title
Sworn to before me and signed in my presence.
Date:
facts's:tenancy
City and state: New York, NY . Cott, United States Magistrate Judge
Printed name and title
SDNY_GM_00000354
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UNITED STATES DISTRICT COURT
19MAG 857 9
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 27 electronic devices seized on Agent Affidavit in Support of
August 12, 2019 from Little Saint James in the Application for Search and Seizure
Virgin Islands. Warrant
SOUTHERN DISTRICT OF NEW YORK) ss.:
Paul Byrne, being duly sworn, deposes and says:
L Introduction
A. Affiant
1. I have been a Task Force Officer with the Federal Bureau of Investigation ("FBI")
since 2017. As such, I am a "federal law enforcement office?' within the meaning of Federal Rule
of Criminal Procedure 41(aX2XC), that is, a government agent engaged in enforcing the criminal
laws and duly authorized by the Attorney General to request a search warrant I am also a detective
with the New York Police Department ("NYPD") and have been employed by the NYPD for
approximately thirteen years. I am currently assigned to investigate violations of criminal law
relating to the sexual exploitation of children as part of an FBI Task Force. I have gained expertise
in this area through classroom training and daily work related to these types of investigations. As
part of my responsibilities, I have been involved in the investigation of sex trafficking cases, and
have participated in the execution of search warrants for electronic devices and electronic storage
media.
2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal
Rules of Criminal Procedure for a warrant to search the electronic devices specified below (the
"Subject Devices") for the items and information described in Attachment A. This affidavit is
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based upon my personal knowledge; my review of documents and other evidence; my
conversations with other law enforcement personnel; and my training, experience and advice
received concerning the use of computers in criminal activity and the forensic analysis of
electronically stored information ('ESI"). Because this affidavit is being submitted for the limited
purpose of establishing probable cause, it does not include all the facts that I have learned during
the course of my investigation. Where the contents of documents and the actions, statements, and
conversations of others are reported herein, they are reported in substance and in part, except where
otherwise indicated.
B. The Subject Devices
3. The Subject Devices were all recovered from a search of a private island in the U.S.
Virgin Islands, latown as Little Saint James, which is an approximately 75 acre island located
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands
Residence") on or about August 12, 2019. The Virgin Islands Residence consists of multiple
structures, including a main residence as well as several other smaller structures on the island,
including a pool house, sheds, a beach house, an office, and multiple cabanas. However, as
detailed below, JEFFREY EPSTEIN, who was a Target Subject of this Investigation until his death
in August 2019, is the only known occupant of the Virgin Islands Residence. The Subject Devices
are particularly described as follows:
a. A gray Mac desktop computer labeled "kitchen mac," which was recovered from
a desk in the main residence on the island ("Subject Device-1");
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89I11772QT,
which was recovered from a desk in the main residence on the island ("Subject
Device-2");
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c. A silver MacBook Pro bearing serial number c02qmOgugwdp, which was
recovered from a desk in the main residence on the island ("Subject Device-3");
d. A silver iPad model A1567 bearing serial number dmpq125ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-4");
e. A silver iPad model A1567 bearing serial number dmpqL1rmg5y, which was
recovered from a desk in the main residence ("Subject Device-5");
f. A silver Mac desktop computer bearing serial number cO2nm1m0fy14, which was
recovered from a desk in the pool house on the island ("Subject Device-6");
g. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-7");
h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a
shed on the island ("Subject Device-8");
i. An HP laptop bearing serial number cnd81368v5, which was recovered from a desk
in a shed on the island ("Subject Device-9");
j. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-10");
k. A silver Macbook desktop computer, which was recovered from a desk in a cabana
on the island ("Subject Device-11");
1. A Dell Inspiron Tower computer model D19M QCNFA335, which was recovered
from a desk in the beach house on the island ("Subject Device-12");
m. A silver Mac desktop computer model A1311 bearing serial number
W804736DDAS, which was recovered from a desk in the beach house on the island
("Subject Device-13");
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n. A Unfi video bearing mac ID 1829f b4fbe426ea90, which was recovered from a
server rack inside a shed on the island ("Subject Device-I4");
o. A Unifi Server bearing mac ID 1735K 788A20463234-8uuu9f, which was
recovered from a server rack inside a shed in on the island ("Subject Device-15");
p. An HP server with four 500 GB drives, bearing serial number MXQ3220187, which
was recovered from a shed on the island ("Subject Device-16");
q. A Panasonic KX TDE100 computer bearing serial number ICX-Tha0104
9LCCD005398, which was found on a server rack in a shed on the island ("Subject
Device-17");
r. A 6 bay with 146 GB drives bearing serial number MXQ824A1R, which was found
on a server rack in a shed on the island ("Subject Device-18");
s. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-l9");
t. An HP desktop tower model 260-A010, bearing serial number cnv7160050, which
was recovered from the maintenance office on the island ("Subject Device-20");
u. An HP tower model 260-A010, bearing serial number cnv716004y, which was
recovered from the maintenance office on the island ("Subject Device-21");
v. A Mac desktop computer model A1312, bearing serial number w89524erspj, which
was recovered from the maintenance office on the island ("Subject Device-22");
w. A Lenovo tower machine type 9070, bearing serial number mj07yg6u, which was
recovered the maintenance office on the island ("Subject Device-23");
x. A Lenovo tower bearing serial number 153306g2umjxekgx, which was recovered
the maintenance office on the island ("Subject Device-24");
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y. An HP Tower bearing serial number CNV74213M3 5704056, which was
recovered the maintenance office on the island ("Subject Device-25");
z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID
1843kb4fbe4d30c69-dcrgtn9, which was found on a server rack in a shed on the
island ("Subject Device-26"); and
aa. A red Nikon digital camera, which was recovered on a file cabinet next to a desk in
a cabana on the island ("Subject Device-27").
4. Subject Device-1 through Subject Device-25 are all computers and/or storage
devices capable of storing electronic picture and message files.
5. Subject Device-26 is a device that identifies a user to a service over the Internet. It
acts as a key that allows users to access other data on other devices, such as Subject Device-1
through Subject Device-25.
6. Subject Device-27 is a digital camera capable of taking and storing electronic
picture files.
7. The Subject Devices have all been transported by the FBI from the Virgin Islands
to FBI offices in the Southern District of New York. At this time, all of the Subject Devices are
presently located in the Southern District of New York.
C. The Subject Offenses
8. For the reasons detailed below, I believe that there is probable cause to believe that
the Subject Device contains 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"). The Target Subjects of this investigation are known and unknown co-
conspirators of JEFFREY EPSTEIN, including but not limited to
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II. Probable Cause and the Initial Search Warrants
A. Probable Cause Regarding the Target Subjects' Commission of the Subject
Offenses
9. On or about July 2, 2019, a grand jury in the Southern District of New York returned
an Indictment charging JEFFREY EPSTEIN with violations of Title 18, United States Code,
Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 371 (sex
trafficking conspiracy). A copy of the Indictment is attached hereto as Exhibit A and is
incorporated by reference. EPSTEIN was arrested pursuant to the Indictment on or about July 6,
2019, and had been detained pending trial at the Metropolitan Correctional Center ("MCC") in
New York, New York.
10. On or about August 10, 2019, the Bureau of Prisons confirmed that JEFFREY
EPSTEIN had been found unresponsive in his cell at the MCC that morning, and was pronounced
dead shortly thereafter.
II. Notwithstanding EPSTEIN's death, the sex trafficking investigation that led to his
indictment remains ongoing. In particular, Count One of the Indictment alleged that EPSTEIN
conspired with others to traffic minors, and further identified three individuals who worked for
EPSTEIN (identified in Exhibit A as "Employee-I", "Employee-2," and "Employee-3") and
facilitated EPSTEIN's abuse of minor girls by, among other things, arranging victims' encounters
with EPSTEIN and paying victims after these encounters. The individual identified in Exhibit A
as MEll' is a Target Subject of this investigation.
12. On or about November 28, 2018, the Miami Herald began publishing a series of
articles relating to the defendant his sexual misconduct with minors, and a previous investigation
into his conduct in Florida from in or about 2005 through 2008. The article included information
about s role in EPSTEIN's sexual abuse of minors. Based on my participation
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by the Government appear to show
in this investigation, I have learned that bank records obtained
wired $250,000 from a trust
that just days later, on or about December 3, 2018, the defendant
EPSTEIN
account to INN. This course of action, and in particular its timing, suggests that
was attempting to influence MI, who might have been able to provide information against
him in light of the recently re-emerging allegations.
and including at least
13. As set forth in Exhibit A, from at least in or about 2002, up to
le minor girls in Manhattan, New
in or about 2005, JEFFREY EPSTEIN sexually abused multip
time and continuing to the present,
York; West Palm Beach, Florida; and elsewhere. During that
in Exhibit A as "the New York
EPSTEIN possessed and controlled a residence, which is described
Residence."
A, from at least in or
14. As further set forth in paragraphs 8 through 10 of Exhibit
EIN sexually abused numerous
about 2002, up to and including at least in or about 2005, EPST
as alleged in the Indictment, when a
minor victims at the New York Residence. In particular, and
to a room inside the New York
victim arrived at the New York Residence, she would be escorted
massage on EPSTEIN. The victims,
Residence with a massage table, where she would perform a
or other individuals to partially or
who were as young as 14 years of age, were told by EPSTEIN
nter, EPSTEIN would escalate
fully undress before beginning the "massage." During the encou
e, among other things, sex acts
the nature and scope of physical contact with his victim to includ
s' genitals. EPSTEIN typically
such as groping and direct and indirect contact with the victim
ask victims to touch him while he
would also masturbate during these sexualized encounters,
or with sex toys. Following each
masturbated, and touch victims' genitals with his bands
the victim in cash.
encounter, EPSTEIN or one of his employees or associates paid
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Exhibit A, to further facilitate his ability
15. As set forth in paragraphs 12 through 13 of
victims to
Y EPSTEIN asked and enticed certain of his
to abuse minor girls in New York, JEFFRE
acts with
"massages" and similarly engage in sex
recruit additional minor girls to perform
m-
another min or girl for EPSTEIN, he paid both the victi
EPSTEIN. When a victim would recruit
ms were
ars in cash. EPSTEIN knew that his victi
recruiter and the new victim hundreds of doll
ims told him their age.
underage, including because certain vict
h 22 of Exhibit A is Victim-1. As part of
16. One of the victims identified in paragrap
, along with
participated in interviews with Victim-1
the FBI's investigation of EPSTEIN, I have
and my
on my participation in those interviews
other law enforcement officers. 1 Based
ided the
ent officers, I know that Victim-1 has prov
conversations with other law enforcem
in part:
following information, in substance and
5, EPSTEIN sexually abused Victim-1 on
a. Between approximately 2002 and 200
n Victim-1
dence. This sexual abuse all occurred whe
multiple occasions in the New York Resi
was under the age of 18.
k
observed multiple floors of the New Yor
b. During that same period, Victim-1
im-I has
s within the New York Residence. Vict
Residence and numerous individual room
Residence,
aspects of the interior of the New York
provided detailed descriptions of certain
rations, and
ils regarding the layout, furnishings, deco
including Victim-1's memory of specific deta
decade ago, she
im-1 has disclosed that, approximately a
1 In meetings with the Government, Vict enship. She
mitt ed mar riag e frau d in orde r to obta in a green card and, subsequently, U.S. citiz
com drugs,
disc lose d pers onal subs tanc e abus e, prim arily involving the abuse of prescription
has also losed having
y 2000s and 2019. Victim-1 has also disc
during various periods between the earl ing paid sex acts.
py-ending" massage parlor, perform
worked for approximately a year at a "hap abus e of her.
claim against EPSTEIN for his sexual
Victim-1 is currently pursuing a civil damages ent
tion prov ided by Vict im-1 has prov en reliable and has been corroborated by independ
Informa accounts of
rds obtained during the investigation and the
evidence, including documents and reco
.
other victims whom Victim-1 has never met
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floor pattern of various areas within the New York Residence. Among other details, 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. In describing the sexual
abuse that occurred in the Massage Room, Victim-1 has stated that EPSTEIN would often touch
her genital area with a vibrating sex toy during these abusive encounters.
The Search of the New York Residence
17. 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 B and incorporated by reference herein.
18. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the
"Search Team") commenced executing the search warrant at the New York Residence. JEFFREY
EPSTEIN had been arrested on the charges contained in the Indictment shortly before the
execution of the search warrant. Based on the Search Team's observations during an initial search
of the New York Residence, at approximately 7 p.m., the Search Team stopped the search and
froze the scene in order to seek a new search warrant. On or about July 7, 2019, the Honorable
Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of
the New York Residence (the "Second Warrant"). The Second Warrant is attached as Exhibit C,
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. Later on July 7, 2019, the
Honorable Barbara Moses, United States Magistrate Judge, signed a third search warrant to search
and seize certain electronic media stored on discs seized during the execution of the Second
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Warrant (the "Compact Disc Search Warrant). The Compact Disc Search Warrant is attached as
Fvhibit D, and incorporated by reference herein.
19. During the execution of the warrants described above in the New York Residence,
the Search Team located evidence of the Subject Offenses. In particular, the Search Team located
the following, among other things, the following:
a. Inside the New York Residence, the Search Team observed a room that, based on
my participation in interviews of Victim-1, appears to be consistent with Victim-I's descriptions
of the Massage Room. The room contained a table covered with a sheet, and appeared to be a
massage table. The room also contained several vibrating sex toys. The walls appeared to be
covered in a type of felt-like tapestry fabric. I further observed two paintings and three
photographs hanging on the walls of the Massage Room. The paintings and photographs depict
nude females. One of the photographs appears to depict a nude girL Thus, it appears that the
Massage Room was in substantially the same condition as Victim-1 observed the room more than
18 years ago.
b. Inside a safe in a closet on the third floor, 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. Some discs contain the
word "Zorro" or "LSJ." 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, i.e., the Virgin Islands
Residence. 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.
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New York Residence,
c. In the drawer of a dresser in a room on the Fifth floor of the
shoebox (the "Shoebox") containing
the Search team discovered and seized, among other items, a
in handwriting, with female names.
numerous compact discs. The majority of the discs are labeled,
d "Blonde Girl Photo Shoot" Yet
One disc is marked "Thai Massage." Another disc is marke
The discs in the Shoebox were
another disc is marked "Misc. Girls Nude/Dinner—Scientists."
dresser, the Search Team discovered
seized by the Search Team. In another drawer of that same
who, based on the training and
loose polaroid photographs depicting young, nude females
appear to be teenagers.
experience of law enforcement officers who observed them,
ence, the Search Team
d. In a closet on the Fifth Floor of the Manhattan Resid
s." The box contained, among
discovered, among other items, a box marked "women/old photo
labeled with hand-written titles. One
other items, approximately seven compact discs, which are
her-a `03" The remaining
disc is marked "nudes 00-24." Mother is labeled "Photograp
ing discs were seized by the Search
discs contain titles that include female names. All of the forego
Team.
black binders containing
e. In that same closet, the Search Team discovered numerous
underneath) and compact discs.
what appear to be print outs of digital photographs (with file names
graphs of nude or partially nude
The binders appeared to contain, among other photographs, photo
Based on the training and experience
young girls, some of which are in sexually suggestive poses.
young girls appear to be teenagers,
of law enforcement officers who observed them, some of the
some of whom appear to be under the age of 18.
The Virgin Islands Residence
EY EPSTEIN has
20. Based on my review of property records, I believe that JEFFR
in or about 1998. In particular, it
been the owner of the Virgin Islands Residence since at least
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Virgin Islands Residence from in or
appears that an entity named "L.S.J., LLC" held title to the
the Virgin Islands Residence to an
about 1998. In or about 2011, L.S.J., LLC transferred title to
ork, EPSTEIN signed as the "sole
entity named "Nautilus, Inc.," for $10. On the transfer paperw
cial owner" of Nautilus, Inc.
member" of L.S.J., LLC and as the "president and sole benefi
s Residence was
21. In addition, I believe that up until his arrest, the Virgin Island
reviewed sex offender registration
JEFFREY EPSTEIN's principal residence. In particular, I have
EPSTEIN listed the Virgin Islands
data, and have learned that, on or about June 17, 2019,
arrest on or about July 6, 2019, I
Residence as his primary residence. At the time of EPSTEIN's
of EPSTEIN's personal effects,
and other law enforcement officers conducted an inventory search
listed the Virgin Islands Residence
and observed that EPSTEIN was carrying a driver's license that
as EPSTEIN's home address.
to believe that
22. Based on my participation in this investigation, I have reason
Offences in and around the Virgin Islands
EPSTEIN and his co-conspirators committed the Subject
red from the New York Residence.
Residence. Some of the evidence of that conduct was recove
agents who have conducted an
In particular, based on my conversations with law enforcement
seized at the New York Residence
initial review (the "Reviewing Agents") of the compact discs
"), I have learned that the discs
as described in paragraphs 15(b)-(e) above (the "Seized Discs
photographs of girls or young women,
contain approximately thousands of nude or partially nude
conversations with the Reviewing
many of which are in sexually suggestive poses. Based on my
to child erotica and visual depictions
Agents, who have particular training and experience relating
Reviewing Agents believe that many
of children in child exploitation cases, I have learned that the
r to depict girls under the age of 18.
of the nude or partially nude images they have reviewed appea
location, and/or were labeled "LSJ"
Certain of these images appear to have been taken at a tropical
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either in the image file name, or on the compact disc that contained the image. Based on the
foregoing, I believe that a portion of the foregoing photographs appear to have been taken at the
Virgin Islands Residence. In addition, I have learned that some of the file names are marked
which are the initials of As set forth below, I have interviewed an individual
who has reported that photographed her at the Virgin Islands Residence.
Accordingly, I believe that a portion of these photos may have been taken by
23. Further, based on my conversations with law enforcement agents who have
conducted an initial review of the Seized Discs, I have learned the following:
a. Many of the photographs appear to be labeled with file names that include "LSJ,"
which I believe stands for Little St. James, which is the name of the Virgin Islands Residence.
b. As discussed above, photographs seized from the New York Residence appear to
depict nude or partially nude young girls, and a portion of those photos appear to have been taken
at the Virgin Islands Residence, based on the fact that (i) some of the photos appear to have been
taken in a tropical location, and (ii) some of the file names of the photographs and/or the labels
on the discs containing the files of nude or partially nude young girls in a tropical location are
marked "LSJ," i.e., the Virgin Islands Residence.
c. Among the photographs seized from the New York Residence, the Reviewing
Agents identified partially-nude photographs of a young girl, labeled with the name of a particular
individual ("Individual-1"). The photographs appear to depict Individual-I on a beach in what
appears to be a tropical location similar to the landscape of the Virgin Islands Residence.
24. In or about August 2019, I participated in an interview of Individual-1, with her
counsel present. Based on my personal observations, I believe that the photographs described in
Paragraph 23(c) depict Individual-1. I have also spoken with another law enforcement agent who
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interviewed Individual-1 on a separate occasion in or about July 2019, with her counsel present.
During the course of these interviews, Individual-1 stated, in sum an substance that she met
EPSTEIN in 2003 when she was approximately 17, and that she travelled to several of EPSTEIN's
properties, including properties in New Mexico, Florida, and the U.S. Virgin Islands, i.e., the
Virgin Islands Residence, before she turned 18. EPSTEIN paid for the trips, and would give
Individual-1 money and gifts while she traveled with him. During these trips, EPSTEIN sexually
abused and assaulted Individual-1 on approximately four different occasions, all of which occurred
before she turned 18. Individual-1 reported that EPSTEIN raped her during two of these incidents.
Indivdual-I recalled that one or more of these instances of sexual abuse occurred on the Virgin
Islands Residence. Individual-1 further reported that, when she was approximately 17,
asked to photograph her, and did in fact photograph Individual-1 at the Virgin Islands
Residence.
25. In or about August 2019, I and another law enforcement officer interviewed an
individual ("Individual-2") whol
at the Virgin Islands Residence from approximately 1999 to 2005 or 2006. Individual-2 reported
that, on several occasions, Individual-2 observed photographs of what appeared to be nude or
partially nude young girls in several locations throughout the main residence of the Virgin Islands
Residence. Individual-2 recalled a photograph depicting and two girls, all of
three whom were topless; Individual-2 estimated that the two girls in the photograph appeared to
be approximately 15 or 16 years old. Individual-2 knew to be t
that time.
26. Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN,
I have learned that traveled to the U.S. Virgin Islands at least approximately
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once a month between October 2001 and November of 2005. These records do not include any
travel may have taken on commercial airlines.
27. For all of these reasons, I am aware that has spent significant
time at the Virgin Islands Residence and that evidence of her involvement, and potentially the
involvement of other co-conspirators, may be located at the Virgin Islands Residence. In
particular, flight logs from EPSTEIN's private jet reflect that the individual identified in the
Indictment as "Employee-3" traveled to the U.S. Virgin Islands on approximately nine separate
occasions. These records do not include any travel Employee-3 may have taken on commercial
airlines. As set forth in the Indictment, Employee-3 scheduled victims' encounters with EPSTEIN.
The Search of the Virgin Islands Residence
28. On or about August 11, 2019, United States Magistrate Judge Ruth Miller of the
District of the Virgin Islands signed a warrant authorizing the search of the Virgin Islands
Residence (the "Virgin Islands Warrant). The Virgin Islands Warrant is attached as Exhibit E,
and incorporated by reference herein. The next day, other law enforcement agents and I executed
the Virgin Islands Warrant at the Virgin Islands Residence.
29. Based on my personal participation in the August 12, 2019 search of the Virgin
Islands Residence, as well as my conversations with other law enforcement agents who
participated in that same search, and my review of documents prepared by other law enforcement
agents who participated in that same search, I have learned that during the August 12, 2019 search
of the Virgin Islands Residence:
a. Subject Device-1 was recovered from a desk in the main residence on the island.
b. Subject Device-2 was recovered from a desk in the main residence on the island.
c. Subject Device-3 was recovered from a desk in the main residence on the island.
16
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d. Subject Device-4 was recovered from a desk in the main residence on the island.
e. Subject Device-5 was recovered from a desk in the main residence on the island.
f. Subject Device-6 was recovered from a desk in the pool house on the island.
g. Subject Device-7 was recovered from a desk in a cabana on the island.
h. Subject Device-8 was recovered from a box on the floor near a desk in a shed on
the island.
i. Subject Device-9 was recovered from a desk in a shed on the island.
j. Subject Device-10 was recovered from a desk in a cabana on the island.
k. Subject Device-11 was recovered from a desk in a cabana on the island.
1. Subject Device-12 was recovered from a desk in the beach house on the island.
m. Subject Device-13 was recovered from a desk in the beach house on the island.
n. Subject Device-14 was recovered from a server rack inside a shed on the island.
o. Subject Device-15 was recovered from a server rack inside a shed in on the island.
p. Subject Device-16 was recovered from a shed on the island.
q. Subject Device-17 was found on a server rack in a shed on the island.
r. Subject Device-18 was found on a server rack in a shed on the island.
s. Subject Device-19 was recovered from a desk in a cabana on the island.
t. Subject Device-20 was recovered from the maintenance office on the island.
u. Subject Device-21 was recovered from the maintenance office on the island.
v. Subject Device-22 was recovered from the maintenance office on the island.
w. Subject Device-23 was recovered the maintenance office on the island.
x. Subject Device-24 was recovered the maintenance office on the island.
Y. Subject Device-25 was recovered the maintenance office on the island.
17
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z. Subject Device-26 was found on a server rack in a shed on the island.
aa. Subject Device-27 was recovered on a file cabinet next to a desk in a cabana on the
island.
B. Probable Cause Justifying Search of the Subject Devices
30. Based on my training, experience, and participation in this investigation, I believe
that there is probable cause that evidence of the Subject Offenses, such as photographs of
EPSTEIN's victims and coconspirators, will be found on the Subject Devices. In particular,
information provided by Individual-1, with whom EPSTEIN engaged in sex acts at the Virgin
Islands Residence while Individual-I was a minor, confirms that EPSTEIN engaged in conduct
relevant to the Subject Offenses at the Virgin Islands Residence. In addition, photographs on the
Seized Discs recovered during the search of the New York Residence depict other young and
partially nude girls photographed at the Virgin Islands Residence, which suggests that EPSTEIN
brought those girls to the Virgin Islands Residence and that, consistent with the accounts provided
by Individual-I, Victim-1and other victims identified in the Indictment, EPSTEIN likely sexually
abused them at the Virgin Islands Residence and maintained evidence of that abuse there on the
Subject Devices. Moreover, evidence ofco-conspirators' presence at the VirginIslands Residence
at times when victims were abused, including photographs, may also be found on the Subject
Devices. Indeed, as noted above, Individual-2 has observed a photograph of partially-
nude young girls at the Virgin Islands Residence, suggesting that similar photographs may have
been saved on the Subject Devices. Similarly, there is probable cause to believe that evidence of
victims' and/or co-conspirators' travel arrangements, contact information, and communications
will be located on the Subject Devices.
31. Moreover, though the sexual abuse described above occurred principally between
approximately 2002 and 2005, as evidence recovered from the New York Residence including the
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Seized Discs makes clear, EPSTEIN continued to maintain substantial evidence of the Subject
Offenses up until the time he was arrested in 2019. Indeed, as described above, in addition to the
Seized Discs, Epstein continued to maintain a "massage room" complete with a massage table and
various sex toys that remained similar in makeup and appearance to descriptions of the same room
provided by Victim-1 based on Victim-1's encounters with EPSTEIN in 2004. Accordingly, there
is probable cause to believe that the Subject Devices, which were seized from a residence where
EPSTEIN and his co-conspirators committed the Subject Offenses, will similarly contain evidence
of the Subject Offenses.
32. In addition, I believe that evidence of the Subject Offenses, including but not
limited to photographs/evidence created at the Virgin Islands Residence, may be located on the
Subject Devices because (i) the Virgin Islands Residence was the location of multiple photo shoots
of young girls; (ii) the Virgin Islands Residence appears to have been, for the last several years
and up until the time of his arrest, EPSTEIN's primary residence; and (iii) given its location, the
Virgin Islands Residence is JEFFREY EPSTEIN's most private residence. Therefore, given that
EPSTEIN has maintained evidence of the Subject Offenses in the New York Residence, he is likely
to have similarly maintained some of that evidence in the Subject Devices maintained at the Virgin
Islands Residence. Moreover, given that there is probable cause to believe that JEFFREY
EPSTEIN and others, including conspired to commit the Subject Offenses,
evidence of EPSTEIN's involvement in trafficking minors would also be relevant to the
investigation of, and any future charges against, other members of the conspiracy, such as
33. According to international flight records that I have reviewed, a private jet owned
and utilized by Epstein has traveled to or from the U.S. Virgin Islands at least on or about April
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14, 2019; May 5, 2019; May 18, 2019; and June 11, 2019. Accordingly, there is probable cause
to believe that EPSTEIN was present at the Virgin Islands Residence a short time before the
recovery of the Subject Devices.
34. Based on my training and experience in investigating individuals who engage in
sex trafficking of minors, and who sexually exploit minors, such individuals often maintain
photographs of their victims, and/or other erotic images of minors, at their residences. Individuals
who engage in such offenses often hoard such images in the privacy of their residences. In
particular, data related to their illegal activity is often stored on their computers.
35. In my training and experience, individuals who store nude and/or sexually
suggestive photographs of minors on compact discs or other external storage devices typically
access those images from computers and other electronic devices in order to view those images,
and individuals who store such materials on compact discs typically store similar files on other
computing devices and storage devices.
36. Like individuals engaged in any other kind of activity, individuals who engage in
sex trafficking of minors store records relating to their illegal activity and to persons involved with
them in that activity on electronic devides such as the Subject Device. Such records can include,
for example, logs of online communications with co-conspirators; email correspondence; contact
information of co-conspirators, including telephone numbers, email addresses, and identifiers for
instant messaging and social medial accounts; travel records for victims and/or co-conspirators;
payment records for victims and/or co-conspirators; and/or photographs of victims and/or co-
conspirators. Individuals engaged in criminal activity often store such records in order to, among
other things, (I) keep track of co-conspirator's contact information; (2) keep a record of illegal
transactions for future reference; (3) remain in contact with co-conspirators and victims; (4) enable
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payment of co-conspirators and victims; and (4) store exploitative photographs for future sexual
gratification.
37. Computer files or remnants of such files can be recovered months or even years
after they have been created or saved on an electronic device such as the Subject Devices. Even
when such files have been deleted, they can often be recovered, depending on how the hard drive
has subsequently been used, months or years later with forensics tools. Thus, the ability to retrieve
from information from the Subject Devices depends less on when the information was first created
or saved than on a particular user's device configuration, storage capacity, and computer habits.
38. Based on the foregoing, I respectfully submit there is probable cause to believe that
evidence of the Target Subjects' commission of the Subject Offenses is likely to be found on the
Subject Devices.
Procedures for Searching ESI
A. Review of ESI
39. Law enforcement personnel (who may include, in addition to law enforcement
officers and agents, attorneys for the government, attorney support staff, agency personnel
assisting the government in this investigation, and outside technical experts under government
control) will review the ESI contained on the Subject Device for information responsive to the
warrant.
40. 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);
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• conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
• "scanning" storage areas to discover and possibly recover recently deleted data;
scanning storage areas for deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of search terms related to the subject matter of the
investigation. (Keyword searches alone are typically inadequate to detect all
information subject to seizure. For one thing, keyword searches work only for text data,
yet many types of files, such as images and videos, do not store data as searchable text.
Moreover, even as to text data, there may be information properly subject to seizure
but that is not captured by a keyword search because the information does not contain
the keywords being searched.)
41. 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 BSI
from the Subject Device to locor all data responsive to the warrant.
B. Return of the Subject Device
42. If the Government determines that the Subject Device is no longer necessary to
retrieve and preserve the data on the device, and that the Subject Device is not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return the Subject
Device, upon request. Computer data that is encrypted or unreadable will not be returned unless
law enforcement personnel have determined that the data is not (i) an instrumentality of the
offense, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed,
or (v) evidence of the Subject Offenses.
IV. Conclusion and Ancillary Provisions
43. 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
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44. In light of the confidential nature of the continuing investigation, I respectfully
until the
request that this affidavit and all papers submitted herewith be maintained under seal
Court orders otherwise.
7st
Paul Byrn
Task Force Officer
Federal Bureau of Investigation
Sworn to before me on
Septyaberti,, 2019
MES L. con
STATES MAGISTRATE JUDGE
' • '
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Attachment A
I. Devices Subject to Search and Seizure
The devices that are the subject of this search and seizure warrant (the "Subject Devices")
are described as follows:
The Subject Devices were all recovered from a search of a private island in the U.S. Virgin
Islands, known as Little Saint James, which is an approximately 75 acre island located
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands
Residence") on or about August 12, 2019. The Virgin Islands Residence consists of multiple
structures, including a main residence as well as several other smaller structures on the island,
including a pool house, sheds, a beach house, an office, and multiple cabanas. The Subject Devices
are particularly described as follows:
a. A gray Mac desktop computer labeled "kitchen mac," which was recovered from a
desk in the main residence on the island ("Subject Device-1");
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89111772QT,
which was recovered from a desk in the main residence on the island ("Subject
Device-2");
c. A silver MacBook Pro bearing serial number c02qmOgugwdp, which was
recovered from a desk in the main residence on the island ("Subject Device-3");
d. A silver Wad model Al 567 bearing serial number dmpq125ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-4");
e. A silver Wad model A1567 bearing serial number dinpqL1nng5y, which was
recovered from a desk in the main residence ("Subject Device-5");
f. A silver Mac desktop computer bearing serial number cO2nmlmOfy14, which was
recovered from a desk in the pool house on the island ("Subject Device-C');
g. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-7");
h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a
shed on the island ("Subject Device-8");
i. An HP laptop bearing serial number cnd81368v5, which was recovered from a desk
in a shed on the island ("Subject Device-9");
A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-10");
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k. A silver Macbook desktop computer, which was recovered from a desk in a cabana
on the island ("Subject Device-11");
1. A Dell Inspiron Tower computer model D19M QCNFA335, which was recovered
from a desk in the beach house on the island ("Subject Device-121;
m. A silver Mac desktop computer model A1311 bearing serial number
W804736DDAS, which was recovered from a desk in the beach house on the island
("Subject Device-13");
n. A Unfi video bearing mac ED 1829f b4fbe426ea90, which was recovered from a
server rack inside a shed on the island ("Subject Device-14");
o. A Unifi Server bearing mac ID 1735K 788A20463234-8uuu9f, which was
recovered from a server rack inside a shed in on the island ("Subject Device-15");
p. An HP server with four 500 GB drives, bearing serial number MXQ3220187, which
was recovered from a shed on the island ("Subject Device-16");
q. A Panasonic KX TDE100 computer bearing serial number KX-TDa0104
9LCCD005398, which was found on a server rack in a shed on the island ("Subject
Device-17");
r. A 6 bay with 146 GB drives bearing serial number MXQ824Allt, which was found
on a server rack in a shed on the island ("Subject Device-18");
s. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-19");
t. An HP desktop tower model 260-A010, bearing serial number cnv7160050, which
was recovered from the maintenance office on the island ("Subject Device-20");
u. An HP tower model 260-A010, bearing serial number cnv716004y, which was
recovered from the maintenance office on the island ("Subject Device-21");
v. A Mac desktop computer model A1312, bearing serial number w89524czspj, which
was recovered from the maintenance office on the island ("Subject Device-22");
w. A Lenovo tower machine type 9030, bearing serial number mj07yg6u, which was
recovered the maintenance office on the island ("Subject Device-23");
x. A Lenovo tower bearing serial number 153306g2umjxekgx, which was recovered
the maintenance office on the island ("Subject Device-24");
y. An HP Tower bearing serial number CNV74213M3 570-P056, which was
recovered the maintenance office on the island ("Subject Device-25");
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z. A Unifi cloudkey with FCCID: SWX-UCCK. IC 6545A-UCC1C and Mac ID
1843kb4fbe4d30c69-clergin9, which was found on a server rack in a shed on the
island ("Subject Device-26"); and
aa. A red Nikon digital camera, which was recovered on a file cabinet next to a desk in
a cabana on the island ("Subject Device-27").
a Review of ESI on the Subject Devices
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Device Sr 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. Evidence concerning the identity or location of the owner(s) or user(s) of the
Subject Devices
2. Evidence concerning the • ' location of, and communications with, co-
conspirators of Jeffrey Epstein, including
3. Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
4. Documents or records reflecting payments to victims and/or co-conspirators
including but not limited to bank and financial records, spreadsheets, ledgers, account listings,
check and wire records, and documents reflecting cash withdrawals.
5. Any photographs of victims or potential victims of the Subject Offenses.
6. Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
7. Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to stress, 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.
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).
If the Government determines that any of the Subject Devices is no longer necessary to retrieve
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject
Device, upon request.
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EXHIBIT A
CONFIDENTIAL -----
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
x
SEALED
UNITED'STATES OF AMERICA INDICTMENT
19 Cr.
JEFFREY EPSTEIN,
Defendant.
19 CRBI 490
x
COUNT ONE
(Sex Traf fick ing Conspiraby)
The Grand Jury charges:
OVERVIEW
se of many
1. As set forth herein, over the cour
sexually exploited and .
years, JEFFREY EPSTEIN, the defendant,
s in Manhattan, New
abused dozens of minor girls at his home
r locations.
York, and Palm Beach, Florida, among othe
t 2002, up
2. In particular, from at least in or abou
2005, JEFFREY EPSTEIN, the
to and including at least in or about
caused to be enticed and
defendant, enticed and recruited, and
ion in Manhattan, New
recruited, minor girls to visit his mans
estate in Palm Beach,
York (the "New York Residence") and his
to engage in sex acts with
Florida (the "Palm Beach Residence")
ims hundreds of dollars •
him, after which he would give the vict
increase his
in cash. Moreover, and in order to maintain and
certain of his victims to
supply of victims, EPSTEIN also paid
y'abused by EPSTEIN. In
recruit additional girls to be similarl
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this way, EPSTEIN created a vast network of underage victims for
him to sexually exploit in locations including New York and
Palm Beach.
3. The victims described herein were as young as 14
years old at the time they were abused by JEFFREY EPSTEIN, the
defendant, and were, for various reasons, often particularly
vulnerable to exploitation. EPSTEIN intentionally sought out
minors and knew that many of his victims were in fact under the
age of 18, including because, in some instances, minor victims
expressly told him their age.
4. In creating and maintaining this network of minor
victims in multiple states to sexually abuse and exploit,
JEFFREY EPSTEIN, the defendant, worked and conspired with
others, including employees and associates who facilitated his
conduct by, among other things, contacting victims and
scheduling their sexual encounters with EPSTEIN at the New York
Residence and at the Palm Beach Residence.
FACTUAL BACKGROUND
5. During all time periods charged in this
Indictment, JEFFREY EPSTEIN, the defendant, was a financier with
multiple residences in the continental United States, including
the New York Residence and the Palm Beach Residence.
6. Beginning in at least 2002, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
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recruited, dozens of minor girls to engage in sex acts with him,
after which EPSTEIN paid the victims hundreds of dollars in
cash, at the New York Residence and the Palm Beach Residence.
7: In both New York and Florida, JEFFREY EPSTEIN,
the defendant, perpetuated this abuse in similar ways. Victims
were initially recruited to provide "massages" to EPSTEIN, which
would be performed nude or partially nude, would become
increasingly sexual in nature, and would typically include one
or more sex acts. EPSTEIN paid his victims hundreds of dollars
in cash for each encounter. Moreover, EPSTEIN actively
encouraged certain of his victims to recruit additional girls to
be similarly sexually abused. EPSTEIN incentivized his victims
to become recruiters by paying these victim-recruiters hundreds
of dollars for each girl that they brought to EPSTEIN. In so
doing, EPSTEIN maintained a steady supply of new victims to
exploit.
The New York Residence
8. At all times relevant to this Indictment, JEFFREY
EPSTEIN, the defendant, possessed and controlled a multi-story
private residence on the Upper East Side of Manhattan, New York,
i.e., the New York Residence. Between at least in or about 2002
and in or about 2005, EPSTEIN abused numerous minor victims at
the New York Residence by causing these victims to be recruited
to engage in paid sex acts with him.
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9. When a victim arrived at the New York Residence,
she typically would be escorted to a room with a massage table,
where she would perform a massage on JEFFREY EPSTEIN, the
defendant. The victims, who were as young as 14 years of age,
were told by EPSTEIN or other individuals to partially or fully
undress before beginning the "massage." During the encounter,
EPSTEIN would escalate the nature and scope of physical contact
with his victim to include, among other things, sex acts such as
groping and direct and indirect contact with tho 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 occasion& at the New York Residence. EPSTEIN
sometimes personally contacted victims to schedule appointments
at the New York Residence. In other instances, EPSTEIN directed
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employees and associates, including a New York-based employee
("Employee-1"), to communicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash. Through these victim-
recruiters/ EPSTEIN gained access to and was able to abuse
dozens of additional minor'girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter. In
addition, certain victim-recruiters routinely scheduled these
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s asked the
encounters through Employee-1, who sometime
fox EPSTEIN.
recruiters to bring a specific minor girl
The Palm Beach Residence
minor girls
14. In addition to recruiting and abusing
ndant, created a similar
in New York, JEFFREY EPSTEIN, the defe
Beach, Florida,
network of minor girls to victimize in Palm
ed another large
where EPSTEIN owned, possessed and controll
e. EPSTEIN frequently
residence, i.e., the Palm Beach Residenc
by private jet, before
traveled from New York to Palm Beach
re that minor victims
which an employee or associate would ensu
val in Florida.
were'available for encounters upon his arri
EPSTEIN, the
15. At the Palm Beach Residence, JEFFREY
abusive conduct.
defendant, engaged in a similar course of
Palm Beach Residence, she
When a victim initially arrived at the
an employee of
would be escorted to a room, sometimes by
stants ("Employee-2" and'
EPSTEIN's, including, At times, two assi
Were also responsible
"Employee-3") who, as described herein,
minor victims. Once
for scheduling sexual encounters with
or'semi-nude massage for
inside, the victim would provide a nude
naked. During these
EPSTEIN, who would himself typically be
re and scope of the
encounters, EPSTEIN would escalate the natu
as groping and direct
physical contact to include sex acts such
genitals. EPSTEIN would
and indirect contact with the victim's
e encounters, ask victims
also typically masturbate during thes
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touch victims' genitals
to touch him while he masturbated, and
with his hands or with sex toys.
unter, JEFFREY
16. In connection with each sexual enco
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.
that certain
17. JEFFREY EPSTEIN, the defendant, knew
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
multiple additional
JEFFREY EPSTEIN, the defendant, on
occasions.
during the
18. JEFFREY EPSTEIN, the defendant, who
New York, would arrange
relevant time period was frequently in
contact victims by phone in
for Employee-2 or other employees to
to ensure appointments
advance of EPSTEIN's travel to Florida
In particular, in certain
were scheduled for when he arrived.
s to minor victims in
instances, Employee-2 placed phone call
Palm Beach Residence. At
Florida to schedule encounters at the
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
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dy
19. Moreover, as in New York, to ensure a stea
the defendant, asked
stream of minor victims, JEFFREY EPSTEIN,
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
20. From at least in or about 2002, up to and
hern District of New York
including in or about 2005, in the Sout
ndant, and others known
and elsewhere, JEFFREY EPSTEIN, the defe
combine, conspire,
and unknown, willfully and knowingly did
each other to commit an
confederate, and agree together and with
sex trafficking of
offense against the United States, to wit,
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
ide, and obtain, by any
recruit, entice, harbor, transport, prov
lly and by receiving
means a person, and to benefit, financia
a venture which has
anything of value, from participation in
person had not
engaged in any such act, knowing that the
d be caused to engage in a
attained the age of 18 years and woul
SONY_GM_00000388
CONFIDENTIAL
EFTA_00114472
EFTA01263058
e 18, United States
commercial sex act, in violation of Titl
Code, Sections 1591(a) and (b)(2).
Overt Acts
to effect
22. In furtherance of the conspiracy and
g overt acts, among
the illegal object thereof, the followin
District of New York and
others, were committed in the Southern
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
engage in sex acts with
Minor Victim-2, and Minor Victim-3, to
New•York, and Palm
EPSTEIN at his residences in Manhattan,
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
was, and Minor
did. EPSTEIN asked Minor Victim-1 how old she
Victim-1 answered truthfully.
the
c. In or about 2004, Employee-1, located in
behalf of EPSTEIN, placed
Southern District of New York, and on
SONY_GM_00000389
CONFIDENTIAL
EFTA_00114473
EFTA01263059
order to schedule an
a telephone call to Minor Victim-1 in
in paid sex acts with
appointment for Minor Victim-1 to engage
EPSTEIN.
d. In or about 2004, Minor Victim-2 was
EPSTEIN and was repeatedly
recruited to engage in sex acts with
Beach Residence over a
sexually abused by EPSTEIN at the Palm
dollars after each
period of years and was paid hundreds of
r Victim-2
encounter. EPSTEIN also encouraged and enticed Mino
sex acts, which she
to recruit other girls to engage in paid
did.
the
e. In or about 2005, Employee-2, located in
behalf of EPSTEIN, placed
Southern District of New York, and on
order to schedule an
a telephone call to Minor Victim-2 in
in paid sex acts with
appointment for Minor Victim-2 to engage
EPSTEIN.
f. In or about 2005, Minor Victim-3 was
EPSTEIN and was repeatedly
recruited to engage in sex acts with
Beach Residence over a
sexually abused by EPSTEIN at the Palm
of dollars for each
period of years and was paid hundreds
r Victim-3
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-3 how old
Victim-3 answered truthfully.
SONY_GM_00000390
CONFIDENTIAL
EFTA_00114474
EFTA01263060
in the
g. In or about 2005, Employee-2, located
lf of EPSTEIN, placed
Southern District of New York, and on beha
Florida in order to
a telephone call to Minor Victim-3 in
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
ge in paid sex acts with
appointment for Minor Victim-3 to enga
EPSTEIN.
371.)
(Title 18, United States Code, Section
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
hs. ).
23. The allegations contained in paragrap
repeated and realleged
through 19 and 22 of this Indictment are
as if fully set forth within.
and
24. From at least in or about 2002, up to.
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
EIN recruited, enticed,
did aid and abet the same, to wit, EPST
obtained numerous
harbored, transported, provided, and
SDNY_GM_00000391
CONFIDENTIAL
EFTA_00114475
EFTA01263061
s old, including but not
individuals who were less than 18 year
d above, and who were then
limited to Minor Victim-1, as describe
ercial sex act in
caused to engage in at least one comm
Manhattan, New York.
1591(a),
(Title 18, United. States Code, Sections
(b)(2), and 2.)
FORFEITURE ALLEGATIONS
alleged in
25. As a result of committing the offense
EPSTEIN, the defendant,
Count Two of this Indictment, JEFFREY
uant to Title 18, United
shall forfeit to the United States, purs
property, real and
States Code, Section 1594(c)(1), any
be used to commit or to
personal, that was used or intended to
nse alleged in Count Two,
facilitate the commission of the offe
tituting or derived from
and any property, real or personal, cons
indirectly, as a result of
any proceeds obtained, directly or
or any property traceable to
the offense alleged in Count Two,
ific property:
such property, and the following spec
its
a. The lot or parcel of land, together with
, fixtures, attachments
buildings, appurtenances, improvements
New York, New
and easements, located at
number 10, owned by
York, with block number 1386 and lot
Maple, Inc.
SONY_GM_00000392
CONFIDENTIAL
EFTA_00114476
EFTA01263062
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
value; or
(d), has been substantially diminished in
which cannot
(e) has been commingled with other property
be subdivided without difficulty;
uant to 21 U.S.C.
it is the intent of the United States, purs
forfeiture of any
853(p) and 28 U.S.C. § 2461(c), to seek
value of the above
other property of the defendant up to the
forfeitable property.
; Title 21,
(Title 18, United States Code, Section 1594
United States Code, Sect ion 853( p); and
Sect ion 2461 .)
Title 28, United States Code,
GEOFFRRY . BERMAN
United States Attorney
SONY_GM_00000393
CONFIDENTIAL
EFTA_OOI14477
EFTA01263063
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
2),
(18 U.S.C. §§ 371, 1591(a), (b)(
and 2)
GEOFFREY S. BERMAN
United States Attorney
For=
SDNY_GM_00000394
CONFIDENTIAL
EFTA_00114478
EFTA01263064
EXHIBIT B
CONFIDENTIAL -- --
EFTA,11,1479
EFTA01263065
AO 93 (SDNY Rev. 01/17) Sca-oh and Seizure Warrant
IMP
UNITED STATES DISTRICT COURT
for the
Southern District ofNew York
In the Matter of the Search of
(Briefly describe the property to be merited
or dentin) theperson byname and address) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
y for the government requests the search
An application by a federal law enforcement officer or an attorne
District of Nevi York
of the following person or property located in the Southern
scathed and give Its location ):
(rdent& the person or describe the property to be
See AttacivnentA
d to conceal adentO the person or describe the property
The person or property to be searched, described above, is believe
to be seised): .
See Attachment A
citations):
The search and seizure are related to violation(s) of (bunt statutory
1591
Title 18, United States Code, Sections 371 and
sh probable cause to search and seize the pardon or
I fmd that the affidavit(s), or any recorded testimony, establi
proPertY. - 2-0 • keit
YOU ARE COMMANDED to execute this warrant on or before (not to exceed 14 deco)
been
Fe in the daytime 6:00 a.m. to 10 p.m. D at any time in the day or night as I find reasonable cause has
established.
copy of the warrant and a receipt for the property
Unless delayed notice is authorized below, you must give a
property was taken, or leave the copy and receipt at the
taken to the person from whom, or from whose premises, the
place where the property was taken.
the execution of the warrant, must prepare an
The officer executing this warrant, or an officer present during
t and inventory to the Clerk of the Court.
inventory as required by law and promptly return this warran
be filed under seal by the Clerk of the Court
O Upon its return, this warrant and inventory should USWInitials
listed in 18 U.S.C. § 2705 (except for delay
O I find that immediate notification may have an adverse result
to delay notice to the person who, or whose property, will be
of trial), and authorize the officer executing this warrant
days (mot to exceed 30).
searched or seized (check the appropriate box) Ofor
Duntil, the facts justifying,JhalatQ specific date of
Date and time issued: 6 l9 (DIA O0 V\ •
Judge's signore
New York, NY Hon. Barbara Moses, U.S. Magistrate Judge
City and state:
CONFIDENTIAlt na
r. me and title SONY_GM_00000396
EFTA_001 4480
EFTA01263066
AO 93 (SONY Ra. 01/17) Search and Scion Wanard (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
the original warrant
I declare under penalty of perjury that this inventory is correct and was returned along with
to the Court.
Date:
Executing officer's :knottily
Printed name and title
SDNY_GM_00000397
CONFIDENTIAL
EFTA_00114481
EFTA01263067
ATTACHMENT A
I. Premises to be Searched —Subject Premises
are describes' as a nearly
1. The premises to be searched (the "Subject Premises") New York,
locate d a
19,000 square foot multi-story single-family residence photog raph of the front
found therein . A
New York, and include all locked and closed containers
entrance to the Subject Premises is included below:
II. Items to Be Seized
raph, video record and otherwise
I. This warrant authorizes executing agents to photog
ing any items, furnishings, or possessions
document the full interior of the Subject Premises, includ
therein.
of certain evidence, fruits, and
2. In addition, this warrant authorizes the seizure
Code, Sections 1591 (sex trafficking of
instrumentalities of violations of Title 18, United States
ct Offenses") described as follows:
minors) and 371 (sex trafficking conspiracy) (the "Subje
the Subject Premises,
a. Evidence concerning occupancy or ownership of
sed correspondence,
including utility and telephone bills, mail envelopes, addres
books, telephone
diaries, statements, identification documents, address
directories, and photographs of its occupant(s).
tions, and floor pattern of
b. Evidence concerning the ►ayout, furnishings, decora
blueprints of the Subject
the Subject Premises, including photographs and
Premises.
2017.08.02
SDNY_GM_00000398
CONFIDENTIAL
EFTA_0011448,
EFTA01263068
EXHIBIT C
CONFIDENTIAL -----
EFTA,11,1483
EFTA01263069
AO 93 (SDNY Rev. 0In7t Se3tch and SCITAITC Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched )
or identify the person by name and address) ) Case No.
)
See Attachment A
)
)
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
(tangy the person or describe she property to be starched and gin 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 OnSell statido.y citation*
Title 18, United States Code, Sections 371 and 1591
person or
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the
proPerIY. July 7, 2019
YOU ARE COMMANDED to execute this warrant on or before
(not to exceed 14 days)
O in the daytime 6:00 a.m. to 10 p.m. at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
at the
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt
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.
WM) Initials
O 1 find that immediate notification may have an adverse result listed in I8 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) Ofor _ days (not to exceed 30)
Ountil, the facts justify' later specific date q
Date and time issued: 11-0 lei ct.ti. Judge's signature
City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judie
Printed name and title
SDNY_GM_00000400
CONFIDENTIAL
EFTA_001114484
EFTA01263070
AO 93 (SDNY Roy. 0187) Seardt and Sarum Warrant (Pate 2)
Return
Case No.: Date and time warrant executed: Copy of wan-ant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date: _
Executing officer's signature
Printed none and title
SDNY_GM_00000401
CONFIDENTIAL
EFTA_OOI14485
EFTA01263071
ATTACHMENT A
1. Premises to be Searched—Subject Premises
The premises to be " bject Premises") are described as a multi-story
single-family residence located at 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.
2017.08.02
SDNY_GM_00000402
CONFIDENTIAL
EFTA_OOI14486
EFTA01263072
or
vi. A binder labeled "PB Girls" and any other documents
communications with or regarding victims or potential victims of the
Subject Offenses.
2
2017.08.02
SDNY_GM_00000403
CONFIDENTIAL
EFTA_00114487
EFTA01263073
EXHIBIT D
CONFIDENTIAL
EFT,00116488
EFTA01263074
A093 (SDNY Rev. 01/17)Seanat and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the a_ District of New York_
(identify the person or describe the properly lo be searchedand give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identifighe person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
Property.
YOU ARE COMMANDED to execute this warrant on or before July 21, 2019
(not to exceed 14 days)
O in the daytime 6:00 a.m. to 10 p.m. IV 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.
LISALIInitials
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 bor) 0 for __ days (not to exceed 30).
O until, the facts justifying, the later specific date of
Date and time issued: 1- :1- AS 1l`• ?.1Ji •
Jude S signature
City and state: New York, NY o
FIDEin arrA me anal
EFTA_00 I 14489
EFTA01263075
AO 93 (SONY Rev. 01117) 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
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date: _
Executing officer's signature
Printed name and dde
SDNY_GM_00000406
CONFIDENTIAL
EFTA_00 I 14490
EFTA01263076
ATTACHMENT A
I. The Subject Devices to Be Searched
The Subject Devices are particularly described as compact discs stored in containi
marked with FBI evidence numbers 15, 16, 17, IS, and 22, seized from the residence located at
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 or communications with or regarding victims or potential victims
of the Subject Offenses;
2. Any photographs of victims or potential victims of the Stibject 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 ES1 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
SDNY_GM_00000407
CONFIDENTIAL
EFTA_00114491
EFTA01263077
• 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 perfonning a cursory
examination of each document in a file cabinet to determine its relevance);
• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation's; and
• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section
1I.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
SDNY_GM_00000408
CONFIDENTIAL
EFTA_00114492
EFTA01263078
EXHIBIT E
10 M08.01
CONFIDENTIAL ----
EFTA,11,1493
EFTA01263079
AO 93 (Rte. 1 I/13) Search and Seizure %mut
UNITED STATES DISTRICT COURT
for the
District of Virgin Islands
In the Matter of the Search of )
(Briefly describe the properly to be searched )
or tdent(h) the person by name and address) )
)
Case No.
ct-c 2141 —6666
Premises Known as Little Saint James Island, USVI, and
Any Buildings, Structures or Containers Thereupon )
)
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 District of the Virgin Islands
(idenh), the person or describe the property to be searched and give its location):
Premises Known and Described as LITRE SAINT JAMES ISLAND, U.S. VIRGIN ISLANDS, and Any Buildings or Other
Structures Contained Thereon, and Any Locked or Closed Contalners/items Contained Therein.
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property
described above, and that such search will reveal °cloth), the person or describe the property to be seizect):
See Attachments A, antHEP
YOU ARE COMMANDED to execute this warrant on or before August 24, 2019 (not to exceed 14 days)
O in the daytime 6:00 a.m. to 10:00 p.m. 0
at any time in the day or night because good cause has been established.
taken to the
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
was taken, or leave the copy and receipt at the place where the
person from whom, or from whose premises, the property
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 Honorable Ruth Miller
(Untied States Magistrate Judge)
adverse result listed in 18 U.S.C.
Cl Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an
§ 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)
of
Cl for 30 days (not to exceed 30) Cl until, the facts justifying, the later s ific date
Date and time issued: alt4d Paa t Atc00
Judge's signature
St. Thomas, VI Ruth Miller, United States Magistrate Judge
City and state: Printed name and tide
SDNY_GM_00000410
CONFIDENTIAL
EFTA_00114494
EFTA01263080
AO 93. (Rev. 11/13) Ranh and Set= Warrant (Rego 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 to the
I declare under penalty of perjury that this inventory is correct and was returned
designated judge.
Date: .
Erectaing officer's sknattins
Printed name and title
SDNY_GM_00000411 •
CONFIDENTIAL
EFTA_OOI14495
EFTA01263081
ATTACHMENT A
I. Premises to be Searched—Subject Premises
The Subject Premises are particularly described as a private island in. the U.S. Virgin
Tslands known as Little Saint James, any buildings or other structures contained thereon, and any
closed containers/items contained therein. Little Saint James is an approximately 75 acre island
located approximately four (4) miles off the southeast coast of St Thomas. The Subject Premises
is depicted in the following photograph:
." lidos el I At S1 Jaminz, ,„
. • •
,
The Subject Premises contains multiple structures, including but not limited to:
a. On the northeast end of the Subject Premises, there is a single story structure next
to a pool.
b. On the southwest end of the Subject Premises, there is a single-story, four-wall
structure. The walls are painted with blue and white stripes. The structure has large double doors
as its main entrance and large windows on the three remaining walls.
c. On the north east end of the Subject Premises, there are multiple structures. The
main structure is a single story residence (the "Main Residence") with a stone exterior, a blue roof,
and a white detailed exterior that includes white columns.
d. A separate structure ("Residence One") with a blue roof and stone exterior is at the
back of the Main Residence, located at the end of the northeast tip of the island and surrounded by
coastline on two of its sides.
SDNY_GM_00000412
2017.08.02
CONFIDENTIAL
EFTA_OOI14496
EFTA01263082
e. A second larger structure ("Residence Two) is set between the Main Residence and
the coastline.
f. Four smaller single story structures (the "Four Cabanas") are next to the Main
Residence and a large pool. All four smaller structures have blue roofs.
g. A third large structure ("Residence Three") set off from the four smaller structures
and next to the coast line is painted white and has a blue roof. Residence Three appears to have
two levels throughout and also appears to be at a lower elevation than the Main Residence,
Residence Two, and the Four Cabanas.
h. Behind Residence Three and along the coastline is a small roofed structure at the
end of a wooden dock (the "Dock House").
i. There are two single story sheds ("Shed One" and "Shed Two") that are located
just southwest of the Main Residence. Shed One and Shed Two appear to have a metal-like
exterior that is a green-blue color.
j. Next to Shed One and Shed Two is a four wall structure that appears to have several
sally port type doors ("Maintenance One"). A second structure ("Maintenance Two") is next to
Maintenance One and has a white exterior with four sets of white double doors and three single
white doors.
k. Near the center of the island is a single story structure ("Residence Four") that has
a stone exterior and blue roof. The front of Residence Four has three dark double doors.
I. Next to the helicopter landing pad are two small structures with blue roofs
("Helipad Buildings").
m. On the west side of the Subject Premises on the coast is an approximately two-level
structure with a blue roof ("Residence Five").
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 Cod; Sections 1591 (Sex Trafficking of Knots), 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 or between EPSTEIN and co-conspirators to the Subject Offenses;
2. Any photographs of victims or potential victims of the Subject Offenses or co-
conspirators to the Subject Offenses.
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3. Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
4. Any documents evidencing the presence of co-conspirators at the Subject Premises.,
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 arnss, 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).
7. Any computer devices and storage media believed to be owned or used by
JEFFREY EPSTEIN 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.
8. Any items or records needed to access the data stored on 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.
9. My 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.
10. 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.
11. My evidence concerning the ownership of the Subject Premises, and any maps or
other geographical guides to the Subject Premises.
SDNY_GM_00000414
2017.08.02
CONFIDENTIAL
EFTA_OOI14498
EFTA01263084