vision-joined/ds10-01/01806afc7fe3f1c4591955deced7595bd23ba2a754d9ae8de8c4306038672cef.md

AO 106 (SDNY Rev. 01/17) Application for a Scarch Warrant
UNITED STATES DISTRICT COURT
for the
SO 9 MAG 8579
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address)
Case 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 (identify the person or describe the
property to be searched and give its location):
located in the
Southern
District of
person or describe the property to be seized):
See Attached Affidavit and its Attachment A
New York
, there is now concealed (identify the
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more):
XO evidence of a crime;
• contraband, fruits of crime, or other items illegally possessed;
O property designed for use, intended foruse, or used in committing a crime;
• a person to be arrested or a person who is unlawfully restrained.
The search is related to a violation of:
Code Section(s)
Offense Description(s)
18 USC 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.
• Delayed notice of
days (give exact ending date if more than 30 days:
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached she
Not,
) is requested
Sworn to before me and signed in my presence.
Date:
9/12/19
City and state: New York, NY
756
Applicant's signature
Task Force Officer Paul Byme, FBI
Printed name and title
Ful int
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:
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
19MAG
8579
TO BE FILED UNDER SEAL
SOUTHERN DISTRICT OF NEW YORK) ss.:
Paul Byrne, being duly sworn, deposes and says:
I. 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 officer" within the meaning of Federal Rule
. of Criminal Procedure 41(a)(2)(C), that is, a government agent engaged in enforcing the criminal
laws and duly authorized by the Attorney General to request a search warrant. I am also a detective
with the New York Police Department ("NYPD") and have been employed by the NYPD for
approximately 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 ("EST"). 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.
3.
B. The Subject Devices
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. 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 W89111772QT,
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 e02qm0gugwdp, 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 dmpq|25ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-4");
e. A silver iPad model A1567 bearing serial number dmpqLIrmgsy, which was
recovered from a desk in the main residence ("Subject Device-5");
f. A silver Mac desktop computer bearing serial number c02nmlm0fy14, 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-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");
1. 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-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 90J0, bearing serial number mj07ygou, which was
recovered the maintenance office on the island ("Subject Device-23");
x. A Lenovo tower bearing serial number 153306gZumjxekgx, which was recovered
the maintenance office on the island ("Subject Device-24");
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y. An HP Tower bearing serial number CNV74213M3 570-P056, 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-dorgm9, which was found on a server rack in a shed on the
island ("Subject Device-26"); and
4.
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").
Subject Device-l through Subject Device-25 are all computers and/or storage
devices capable of storing electronic picture and message files.
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.
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 L
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II. Probable Cause and the Initial Search Warrants
A. Probable Cause Regarding the Target Subjects' Commission of the Subject
Offenses
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.
11.
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-l", "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"
" 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 I
s role in EPSTEIN's sexual abuse of minors. Based on my participation
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in this investigation, I have learned that bank records obtained by the Government appear to show
that just days later, on or about December 3, 2018, the defendant wired $250,000 from a trust
account to
This course of action, and in particular its timing, suggests that EPSTEIN
was attempting to influence |
who might have been able to provide information against
him in light of the recently re-emerging allegations.
13.
As set forth in Exhibit A, from at least in or about 2002, up to and including at least
in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in Manhattan, New
York; West Palm Beach, Florida; and elsewhere. During that time and continuing to the present,
EPSTEIN possessed and controlled a residence, which is described in Exhibit A as "the New York
Residence."
14. As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or
about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous
minor victims at the New York Residence. In particular, and as alleged in the Indictment, when a
victim arrived at the New York Residence, she would be escorted to a room inside the New York
Residence with a massage table, where she would perform a massage on EPSTEIN. The victims,
who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or
fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate
the nature and scope of physical contact with his victim to include, among other things, sex acts
such as groping and direct and indirect contact with the victims' genitals. EPSTEIN typically
would also masturbate during these sexualized encounters, ask victims to touch him while he
masturbated, and touch victims' genitals with his hands or with sex toys. Following each
encounter, EPSTEIN or one of his employees or associates paid the victim in cash.
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15.
As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability
to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to
recruit additional minor girls to perform "massages and similarly engage in sex acts with
EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victim-
recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were
underage, including because certain victims told him their age.
16.
One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of
the FBI's investigation of EPSTEIN, I have participated in interviews with Victim-1, along with
other law enforcement officers. Based on my participation in those interviews and my
conversations with other law enforcement officers, I know that Victim-1 has provided the
following information, in substance and in part:
a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on
multiple occasions in the New York Residence. This sexual abuse all occurred when Victim-1
was under the age of 18.
b. During that same period, Victim-1 observed multiple floors of the New York
Residence and numerous individual rooms within the New York Residence. Victim-1 has
provided detailed descriptions of certain aspects of the interior of the New York Residence,
including Victim-l's memory of specific details regarding the layout, furnishings, decorations, and
' In meetings with the Government, Victim-1 has disclosed that, approximately a decade ago, she
committed marriage fraud in order to obtain a green card and, subsequently, U.S. citizenship. She
has also disclosed personal substance abuse, primarily involving the abuse of prescription drugs,
during various periods between the early 2000s and 2019. Victim-1 has also disclosed having
worked for approximately a year at a "happy-ending" massage parlor, performing paid sex acts.
Victim-1 is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her.
Information provided by Victim-1 has proven reliable and has been corroborated by independent
evidence, including documents and records obtained during the investigation and the accounts of
other victims whom Victim-1 has never met.
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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 dises 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
Exhibit 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-], 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 dises
in the binders seized by the Search Team have titles that appear to refer to trips or vacations.
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c. In the drawer of a dresser in a room on the Fifth floor of the New York Residence,
the Search team discovered and seized, among other items, a shoebox (the "Shoebox") containing
numerous compact discs. The majority of the discs are labeled, in handwriting, with female names.
One disc is marked "Thai Massage." Another disc is marked "Blonde Girl Photo Shoot." Yet
another disc is marked "Misc. Girls Nude/Dinner--Scientists." The discs in the Shoebox were
seized by the Search Team. In another drawer of that same dresser, the Search Team discovered
loose polaroid photographs depicting young, nude females who, based on the training and
experience of law enforcement officers who observed them, appear to be teenagers.
d. In a closet on the Fifth Floor of the Manhattan Residence, the Search Team
discovered, among other items, a box marked "women/old photos." The box contained, among
other items, approximately seven compact discs, which are labeled with hand-written titles. One
dise is marked "nudes 00-24." Another is labeled *Photographer-
*03" The remaining
discs contain titles that include female names. All of the foregoing discs were seized by the Search
Team.
e. In that same closet, the Search Team discovered numerous black binders containing
what appear to be print outs of digital photographs (with file names underneath) and compact discs.
The binders appeared to contain, among other photographs, photographs of nude or partially nude
young girls, some of which are in sexually suggestive poses. Based on the training and experience
of law enforcement officers who observed them, some of the young girls appear to be teenagers,
some of whom appear to be under the age of 18.
The Virgin Islands Residence
20.
Based on my review of property records, I believe that JEFFREY EPSTEIN has
been the owner of the Virgin Islands Residence since at least in or about 1998. In particular, it
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appears that an entity named "L.S.J., LL.C" held title to the Virgin Islands Residence from in or
about 1998. In or about 2011, L.S.J., LLC transferred title to the Virgin Islands Residence to an
entity named "Nautilus, Inc.," for $10. On the transfer paperwork, EPSTEIN signed as the "sole
member" of L.S.J., LLC and as the "president and sole beneficial owner" of Nautilus, Inc.
In addition, I believe that up until his arrest, the Virgin Islands Residence was
JEFFREY EPSTEIN's principal residence. In particular, I have reviewed sex offender registration
data, and have learned that, on or about June 17, 2019, EPSTEIN listed the Virgin Islands
Residence as his primary residence. At the time of EPSTEIN's arrest on or about July 6, 2019, I
and other law enforcement officers conducted an inventory search of EPSTEIN's personal effects,
and observed that EPSTEIN was carrying a driver's license that listed the Virgin Islands Residence
as EPSTEIN's home address.
22.
Based on my participation in this investigation, I have reason to believe that
EPSTEIN and his co-conspirators committed the Subject Offences in and around the Virgin Islands
Residence. Some of the evidence of that conduct was recovered from the New York Residence.
In particular, based on my conversations with law enforcement agents who have conducted an
initial review (the "Reviewing Agents") of the compact discs seized at the New York Residence
as described in paragraphs 15(b)-(e) above (the "Seized Discs"), I have learned that the discs
contain approximately thousands of nude or partially nude photographs of girls or young women,
many of which are in sexually suggestive poses. Based on my conversations with the Reviewing
Agents, who have particular training and experience relating to child erotica and visual depictions
of children in child exploitation cases, I have learned that the Reviewing Agents believe that many
of the nude or partially nude images they have reviewed appear to depict girls under the age of 18.
Certain of these images appear to have been taken at a tropical location, and/or were labeled "LSJ"
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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 "1"
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 (i) 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-1 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-1 recalled that one or more of these instances of sexual abuse occurred on the Virgin
Islands Residence. Individual-1 further reported that, when she was approximately 17,
asked to photograph her, and did in fact photograph Individual-1 at the Virgin Islands
Residence.
25.
In or about August 2019, I and another law enforcement officer interviewed an
individual ("Individual-2") who
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
Land two girls, all of
Residence. Individual-2 recalled a photograph depicting LI
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 l
to be
lat
that time.
26.
I have learned that
Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN,
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.
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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.
I. 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.
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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 co-conspirators, 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-1 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 Dises 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-1, Victim-1 and other victims identified in the Indictment, EPSTEIN likely sexually
abused them at the Virgin Islands Residence and maintained evidence of that abuse there on the
Subject Devices. Moreover, evidence of co-conspirators' presence at the Virgin Islands 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 I
|| 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 (i) 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 devices such as the Subject Device. Such records can include,
for example, logs of online communications with co-conspirators; email correspondence; contact
information of co-conspirators, including telephone numbers, email addresses, and identifiers for
instant messaging and social medial accounts; travel records for victims and/or co-conspirators;
payment records for victims and/or co-conspirators; and/or photographs of victims and/or co-
conspirators. Individuals engaged in criminal activity often store such records in order to, among
other things, (1) keep track of co-conspirator's contact information; (2) keep a record of illegal
transactions for future reference; (3) remain in contact with co-conspirators and victims; (4) enable
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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.
III. 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
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 ESI
from the Subject Device to locate 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, (i) 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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In light of the confidential nature of the continuing investigation, I respectfully
request that this affidavit and all papers submitted herewith be maintained under seal until the
Court orders otherwise.
Paul Byrne
lip 156
Task Force Officer
Federal Bureau of Investigation
Sworn to before me on
September|2, 2019
FumL.latt
HON. JAMES L. COTT
UNIȚED STATES MAGISTRATE JUDGE
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Attachment A
I. Devices Subjeet 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 c02qm0gugwdp, 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 dmpq|25ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-4");
e. A silver iPad model A1567 bearing serial number dmpqLIrmg5y, which was
recovered from a desk in the main residence ("Subject Device-5");
f. A silver Mac desktop computer bearing serial number c02nmlmOfy14, 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");
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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-12");
m. A silver Mac desktop computer model A1311 bearing serial number
W804736DDAS, which was recovered fiom a desk in the beach house on the island
("Subject Device-13);
n. A Unfi video bearing mac ID 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 788A20463234-8uuu9r, 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");
4. 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 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-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 90J0, 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");
2
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z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID
1843kb4fbe4d30c69-dergm9, 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").
II. Review of ESI on the Subject Devices
Law enforcement personnel (who may include, in addition to law enforcement officers and
agents, attorneys for the government, attorney support staff, agency personnel assisting the
government in this investigation, and outside technical experts under government control) are
authorized to review the ESI contained on the Subject Device for evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows:
Evidence concerning the identity or location of the owners) or users) of the
Subject Devices
2.
Evidence concerning the identity or location of, and communications with, co-
conspirators of Jeffrey Epstein, including L
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
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.
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.
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
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:.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
- V.
JEFFREY EPSTEIN,
Defendant.
SEALED
INDICTMENT
19 Cr.
19 CRIM
490
- -
- - x
COUNT ONE
(Sex Trafficking Conspiracy)
The Grand Jury charges:
OVERVIEW
As set forth herein, over the course of many
1.
years, JEFFREY EPSTEIN, the defendant, sexually exploited and
• abused dozens of minor girls at his homes in Manhattan, New
York, and Palm Beach, Florida, among other locations.
2. In particular, from at least in or about 2002, up
to and including at least in or about 2005, JEFFREY EPSTEIN, the
defendant, enticed and recruited, and caused to be enticed and
recruited, minor girls to visit his mansion in Manhattan, New
York (the "New York Residence") and his estate in Palm Beach,
• Florida (the "Palm Beach Residence") to éngage in sex acts with
him, after which he would give the victims hundreds of dollars
in cash. Moreover, and in order to maintain and increase his
supply of victims, EPSTEIN also paid certain of his victims to
recruit additional girls to be similarly abused by EPSTEIN.
In
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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.
1.
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 the victim's
genitals. EPSTEIN
typically would also masturbate during these
sexualized encounters, ask victims to touch him while he
masturbated, and touch victims' genitals with his hands or with
sex toys.
10. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars in cash for each encounter.
11. JEFFREY EPSTEIN, the defendant, knew that many of
his New York victims were underage, including because certain
victims told him their age. Further, once these minor victims
were recruited, many were abused by EPSTEIN on multiple
subsequent occasions at the New York Residence. EPSTEIN
sometimes personally contacted victims to schedule appointments
at the New York Residence. In other instances,
EPSTEIN directed
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:.
employees and associates, including a New York-based employee
("Employee-1"), to conmunicate with victims via phone to arrange
for these victims to return to the New York Residence for
additional sexual encounters with EPSTEIN.
12. Additionally, and to further facilitate his
ability to abuse minor girls in New York, JEFFREY EPSTEIN, the
defendant, asked and enticed certain of his victims to recruit
additional girls to perform "massages" and similarly engage in
sex acts with EPSTEIN. When a victim would recruit another girl
for EPSTEIN, he paid both the victim-recruiter and the new
victim hundreds of dollars in cash. Through these victim-
recruiters, EPSTEIN gained access to and was able to abuse
dozens of additional minor'
girls.
13. In particular, certain recruiters brought dozens
of additional minor girls to the New York Residence to give
massages to and engage in sex acts with JEFFREY EPSTEIN, the
defendant. EPSTEIN encouraged victims to recruit additional
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter: In
addition, certain victim-recruiters routinely scheduled these
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encounters through Employee-1, who sometimes asked the
recruiters to bring a specific minor girl for EPSTEIN.
The Palm Beach Residence
14. In addition to recruiting and abusing minor girls
in New York, JEFFREY EPSTEIN, the defendant, created a similar
network of minor girls to victimize in Palm Beach, Florida,
where EPSTEIN owned, possessed and controlled another large
residence, i.e., the Palm Beach Residence. EPSTEIN frequently
traveled from New York to Palm Beach by private jet, before
which an employee or associate would ensure that minor victims
were available for encounters upon his arrival in Florida.
•
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the
defendant, engaged in a similar course of abusive conduct.
When a
victim initially arrived at the Palm Beach Residence, she
would be escorted to a room, sometimes by an employee of
EPSTEIN's, including, at times,
two assistants ("Employee-2" and
"Employee-3") who, as described herein, were also responsible
for scheduling sexual encounters with minor victims.
Once
inside, the victim would provide à nude or semi-nude massage for
EPSTEIN, who would himself typically be naked. During these
ençounters,
EPSTEIN would escalate the nature and scope of the
physical contact to include sex acts such as groping and direct
and indirect contact with the victim's genitals.
EPSTEIN would
also typically masturbate during these
encounters, ask victims
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:.
to touch him while he masturbated, and touch victims' genitals
with his hands or with sex toys.
16. In connection with each sexual encounter, JEFFREY
EPSTEIN, the defendant, or one of his employees or associates,
paid the victim in cash. Victims typically were paid hundreds
of dollars for each encounter.
17. JEFFREY EPSTEIN, the defendant, knew that certain
of his victims were underage, including because certain victims
told him their age, In addition, as with New York-based
victims, many Florida victims, once recruited, were abused by
JEFFREY EPSTEIN, the defendant, on multiple additional
occasions.
18. JEFFREY EPSTEIN, the defendant, who during the
relevant time period was frequently in New York, would arrange
fox Employee-2 or other employees to contact victims by phone in
advance of EPSTEIN' s travel to Florida to ensure appointments
were scheduled for when he arrived. In particular, in certain
instances, Employee-2 placed phone calls to minor victims in
Florida to schedule encounters at the Palm Beach Residence. At
the time of certain of those phone calls!
EPSTEIN and Employee-2
weré in New York, New York. Additionally, certain of the
individuals victimized at the Palm Beach Residence were
contacted by phone by Employee-3 to schedule these
encounters.
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19. Moreover, as in New York, to ensure a steady
stream of minor victims, JEFFREY EPSTEIN, the defendant, asked
and enticed certain victims in Florida to recruit other girls to
engage in sex acts. EPSTEIN paid hundreds of dollars to victim-
recruiters for each additional girl they brought to the Palm
Beach Residence.
STATUTORY ALLEGATIONS
20. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New York
and elsewhere, JEFFREY EPSTEIN, the defendant, and others known
and unknown, willfully and knowingly did combine, conspire,
• confederate,
and agree together and with each other to commit an
offense against the United States, to wit, sex trafficking of
minors, in violation of Title 18, United States Code, Section.
1591 (a) and (D) •
21. It was a part and object of the conspiracy that
JEFFREY EPSTEIN, the defendant, and others known and unknown,
would and did, in and affecting interstate and foreign commerce,
recruit, entice, harbor, transport, provide, and obtain, by any
means a person, and to benefit, financially and by receiving
anything of value, from participation in a venture which has
engaged in any such act, knowing that the person had not
attained the age of 18 years and would be caused to engage in a
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commercial sex act, in violation of Title 18, United States
Code, Sections 1591 (a) and (b) (2).
Overt Acts
22. In furtherance of the conspiracy and to effect
the illegal object thereof, the following overt acts, among
others, were conmitted in the Southern District of New York and
elsewhere:
a.
In or about 2004, JEFFREY EPSTEIN, the
defendant, enticed and recruited multiple minor victims,
including minor victims identified herein as Minor Victim-1,
Minor Victim-2, and Minor Victim-3, to engage in sex acts with
EPSTEIN at his residences in Manhattan, New York, and Palm
Beach, Florida, after which he provided them with hundreds of
dollars in cash for each encounter.
b. In or about 2002, Minor Victim-1 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the New York Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-1
to recruit other girls to engage, in paid sex acts, which she
did. EPSTEIN asked Minor Victim-1 how old she was, and Minor
Victim-1 answered truthfully.
c. In or about 2004, Employee-1, located in the
Southern District of New York, and on behalf of EPSTEIN, Placed
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:.
a telephone call to Minor Victim-1, in order to schedule an
appointment for Minor Victim-1 to engage in paid sex acts with
EPSTEIN.
d. In or about 2004, Minor Victim-2 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residerice over a
period of years and was paid hundreds of dollars after each
encounter. EPSTEIN also encouraged and enticed Minor Victim-2
to iecruit other girls to engage in paid sex acts, which she
did.
e. In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-2 in order to schedule an
appointment for Minor Victim-2 to engage in paid sex acts with
EPSTEIN.
I. In or about 2005, Minor Victim-3 was
recruited to engage in sex acts with EPSTEIN and was repeatedly
sexually abused by EPSTEIN at the Palm Beach Residence over a
period of years and was paid hundreds of dollars for each
encounter. EPSTEIN also encouraged and enticed Minor Victim-3
to recruit other girls to engage in paid sex acts, which she
did. EPSTEIN asked Minor Victim-3 how old she was, and Minor
Victim-3 answered truthfully.
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:.
9. In or about 2005, Employee-2, located in the
Southern District of New York, and on behalf of EPSTEIN, placed
a telephone call to Minor Victim-3 in Florida in order to
schedule an appointment for Minor Victim-3 to engage in paid sex
acts with EPSTEIN.
h. In oi about 2004, Employee-3 placed a
telephone call to Minor Victim-3 in order to schedule an
appointment for Minor Victim-3 to engage in paid sex acts with
EPSTEIN.
(Title 18, United States Code, Section 371.)
COUNT TWO
(Sex Trafficking)
The Grand Jury further charges:
23. The allegations contained in paragraphs 1
• through 19 and 22 of this Indictment are repeated and realleged
as if fully set forth within.
24. From at least in or about 2002, up to and
including in or about 2005, in the Southern District of New
York, JEFFREY EPSTEIN, the defendant, willfully and knowingly,
in and affecting interstate and foreign commerce, did recruit,
entice, harbor, transport, provide, and obtain by any means a
person, knowing that the person had not attained the age of 18
years
and would be caused to engage in a commercial sex act, and
did aid and abet the same, to wit, EPSTEIN recruited, enticed,
harbored, transported, provided, and obtained numerous
CONFIDENTIAL
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individuals who were less than 18 years old,
including but not
limited to Minor Victim-1, as described above, and who were then
caused to engage in at least one commercial sex
act in
Manhattan, New York.
(Title 18, United States Code, Sections 1591(a);
(b) (2), and 2.)
FORFEITURE ALLEGATIONS
25. As a result of committing the offense alleged in
Count Iwo of this Indictment, JEFFREY EPSTEIN, the defendant,
shall forfeit to the United States, pursuant to Title 18, United
States Code, Section 1594 (c) (1), any property, real and
personal, that was used or intended to be used to commit or to
facilitate the commission of the offense alleged in Count Iwo,
and any property, real or personal, constituting or derived from
any proceeds obtained, directly or indirectly, as a result of
the offense alleged in Count Iwo, or any property traceable to
such property, and the following specific property:
a.
The lot or parcel of land, together with its
buildings, appurtenances, improvements, fixtures, attachments
and easements, located at
New York, New
York, with block number 1386 and lot number 10, owned by
Maple,
Inc.
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Substitute Asset Provision
26. If any of the above-described forfeitable
property, as
a result of any act or omission of the defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a
third person;
(c) has been placed beyond the jurisdiction of the Court;
(d), has been substantially diminished in value; or
(e) has been cormingled with other property which cannot
be subdivided without difficulty:
it is the intent of the United States, pursuant to 21 U.S.C.
§ 853 (p)
and 28 U.S.C. § 2461(c), to seek forfeiture of any
other property of the defendant up to the value of the above
forfeitable property.
(Title 18, United States Code, Section 1594; Title 21,
United States Code, Section 853 (p); and
Title 28, United States Code, Section 2461.)
Furts f. m
EOFFRI
BERMAN
United States Attorney
:
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Form No. USA-338-274 (Ed. 9-25-58)
UNITED STATES DISTRICT COURI
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
JEFFREY EPSTEIN,
Defendant.
INDICIMENT
(18 U.S.C. SS 371, 1591 (a), (b) (2),
and 2)
GEOFFREY S. BERMAN
United States Attorney
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EXHIBIT B
2017.08.02
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AO 93 (SDNY Rev. 01/17) Scarch and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
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
District of
New York
(identify the person or deseribe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identif the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
7.20.19
/ in the daytime 6:00 a.m. to 10 p.m.
inless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the proper
ken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at th
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
• Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. _
• I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) Ofor
days (not to exceed 30).
Juntil, the facts justifying, the later specific date of
Date and time issued:
7-6-19 10:14a.M.
sentens
Judge's signature
City and state: New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
CONFIDENTIAL
rinted name and file SDNY_GM_00000396
EFTA_00114480
EFTA01263066

AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
| Date and time warrant executed:
Copy of warrant and inventory left with:
Case No.:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
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EFTA_00114481
EFTA01263067

ATTACHMENT A
I. Premises to be Searched-Subject Premises
The premises to be searched (the "Subject Premises") are described as a nearly
19,000 square foot 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
1. This warrant authorizes executing agents to photograph, video record and otherwise
locument the full interior of the Subject Premises, including any items, furnishings, or possessions
therein.
2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of
minors) and 371 (sex traflicking conspiracy) (the "Subject Offenses") described as follows:
a. Evidence concerning occupancy or ownership of the Subject Premises,
including utility and telephone bills, mail envelopes, addressed correspondence,
diaries, statements, identification documents, address books, telephone
directories, and photographs of its occupants).
b. Evidence concerning the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2017.08.02
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EXHIBIT C
2017.08.02
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A093 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
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
District of
New York
(identify the person or describe the property lo be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
lo 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 affidavits), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before
July 7, 2019
(not to exceed 14 days)
• in the daytime 6:00 a.m. to 10 p.m.
I at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
• Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
• 1 find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) for
days (not to exceed 30).
Duntil, the facts justifyiag, the later specific date o
Date and time issued: 7:7-19 2:03a.M.
bottle
Judge's signature
City and state:
New York, NY
Hon. Barbara Moses, U.S. Magistrate Judge
Printed nome and title
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•-
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Date and time warrant executed:
Case No.:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Copy of warrant and inventory left with:
Certification
1 declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Erecuting officer's signature
Prined name and title
CONFIDENTIAL
SDNY_GM_00000401
EFTA_00114485
EFTA01263071

ATTACHMENT A
I. Premises to be Searched— Subject Premises
1.
The premises to be searched (the "Subject Premises") are described as a multi-story
single-family residence located at
1, 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
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
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vi. A binder labeled "PB Girls" and any other documents or
communications with or regarding victims or potential victims of the
Subject Offenses.
2
2017.08.02
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EXHIBIT D
2017.08.02
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EFTA_00114488
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A093 (SDNY Rev, 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
Case No.
See Attachment A
)
)
)
SEARCH AND SEIZURE WARRANT
To:
Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the
Southern
District of
_New York
(identify the person or describe the property to be searched and give 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 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,
• in the daytime 6:00 a.m. to 10 p.m.
• at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
• Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
• I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) Ofor
days (not to exceed 30).
Ountil, the facts justifying, the later specific date of
Date and time issued: 7-7-19 11:33P.M.
signature
City and state: New York, NY
EFTA_00114489
EFTA01263075

AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Date and time warrant executed:
Case No.:
Inventory made in the presence of:
Inventory of the property taken and name of any person(s) seized:
Copy of warrant and inventory left with:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
CONFIDENTIAL
SDNY_GM_00000406
EFTA_00114490
EFTA01263076

ATTACHMENT A
I. The Subject Devices to Be Searched
The Subject Devices are particularly described as compact discs stored in containers
marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence located at l
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 of regarding victims or potential victims
of the Subject Offenses;
2. Any photographs of victims or potential victims of the Subject Offenses;
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);
Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usernames and passwords, user profiles, e-mail contacts, and photographs;
6.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
B. Review of ESI
Law enforcement personnel (including, in addition to law enforcement officers and agents,
and depending on the nature of the ESI and the status of the investigation and related proceedings,
attorneys for the government, attorney support staff, agency personnel assisting the government in
this investigation, and outside technical experts under government control) will create a forensic
image of the Subject Devices (if practicable) and review the ESI contained therein for information
responsive to the warrant.
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
2017.08.02
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• surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
• conducting a file-by-file review by "opening" or reading the first few "pages" of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance):
• "scanning" storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation; and
reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section
II.A of this Attachment. However, law enforcement personnel are authorized to conduct a
complete review of all the ESI from seized devices or storage media if necessary to evaluate its
contents and to locate all data responsive to the warrant.
• Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
contain the keywords being searched.
• 2017.08.02
2.
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EXHIBIT E
2017.08.02
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AO 93 (Rev. 11/13) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
District of Virgin Islands
In the Matter of the Search of
caseNo. Mag: 2019-0060
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
(identify the person or describe the property to be searched and give its location):
Premises Known and Described as LITTLE SAINT JAMES ISLAND, U.S. VIRGIN ISLANDS, and Any Buildings or Other
Structures Contained Thereon, and Any Locked or Closed Containers/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 (identify the person or describe the property to be seized):
See Attachments A, B Peat al
YOU ARE COMMANDED to execute this warrant on or before
August 24, 2019
(not to exceed 14 days)
• in the daytime 6:00 a.m. to 10:00 p.m.
I at any time in the day or night because good 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 Honorable Ruth Miller
(United States Magistrate Judge)
• Pursuant to 18 U.S.C. § 3103a(b), I find that immediate notification may have an adverse result listed in 18 U.S.C.
§ 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose
property, will be searched or seized (check the appropriate box)
• for
30
days (not to exceed 30) • until, the facts justifying, the later specific date of
Date and time issued: august /iz0k 1:l0a
est Mill
Judge's signature
City and state:
St. Thomas, VI
Ruth Miller, United States Magistrate Judge
Printed name and title
SDNY_GM_00000410
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AO 93. (Rev. 11/13) Search and Sciztre Warrent (Page 2)
Return
Case No.:
| Date and time warrant executed:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Copy of warrant and inventory left with:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the
designated judge.
Date:
Executing officer's signature
Pristed name and title
CONFIDENTIAL
SDNY_GM_00000411
EFTA_00114495
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
slands known as Little Saint James, any buildings or other structures contained thereon, and an
losed containers/items contained therein. Little Saint James is an approximately 75 acre islan
located approximately four (4) miles off the southeast coast of St, Thomas. The Subject Premises
is depicted in the following photograph:
The Subject Premises contains multiple structures, including but not limited to:
On the northeast end of the Subject Premises, there is a single story structure next
a.
to a pool.
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.
2017.08.02
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e.
the coastline.
A second larger structure ("Residence Two) is set between the Main Residence and
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.
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.
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.
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.
L.
(Helipad Buildings").
Next to the helicopter landing pad are two small structures with blue roofs
m.
On the west side of the Subject Premises on the coast is an approximately two-level
structure with a blue roof ("Residence Five").
I. 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:
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses ot 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 Oftenses.
2017.08.02
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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.
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.
ny 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)
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.
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.
Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or soffware manuals or other information
concerning the configuration of the seized or copied computer devices or storage media.
Any evidence concerning the identities of locations of those persons with access to,
control over, ot ownership of the seized or copied computer devices or storage media.
11.
Any evidence concerning the ownership of the Subject Premises, and any maps or
other geographical guides to the Subject Premises.
2017.08.02
CONFIDENTIAL
SDNY_GM_00000414
EPTA_00114498
EFTA01263084