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| AO 106 (SDNY Rev. 01/17) Application for a Search Warrant | |
| In the Matter of the Search of | |
| arty lo be searche | |
| Bridentify the persoproper and saddes | |
| See Attached Affidavit and its Attachment A | |
| UNITED STATES DISTRICT COURT | |
| for the | |
| Southern District of New York | |
| I 9MAN | |
| Case No. | |
| 6572 | |
| 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): | |
| V evidence of a crime; | |
| • contraband, fruits of crime, or other items illegally possessed; | |
| • property designed for use, intended for use, 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) | |
| 18 U.S.C. SS 1591 and | |
| Offense Description(s) | |
| Sex trafficking of minors; sex trafficking conspiracy | |
| 371 | |
| The application is based on these facts: | |
| See Attached Affidavit and its Attachment A | |
| • Continued on the attached sheet. | |
| • Delayed notice of | |
| days (give exact ending date if more than 30 days: | |
| under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. | |
| ) is requested | |
| Applic | |
| Special Agent | |
| Printed name and title | |
| FBI | |
| Sworn to before me and signed in my presence. | |
| Date: | |
| 7-7-19 | |
| City and state: New York, NY | |
| Judge's sign | |
| Hon. Barbara Moses, U.S. Magistrate Judge | |
| Printed name and title | |
| EPTA_00114190 | |
| EFTA01262863 | |
| 1. 9MAG | |
| UNITED STATES DISTRICT COURT | |
| SOUTHERN DISTRICT OF NEW YORK | |
| In the Matter of the Application of the United | |
| States Of America for a Search and Seizure | |
| Warrant for the Premises Known and Described | |
| as 9 East 71st Street, New York, New York and | |
| Any Closed Containers/Items Contained Therein | |
| R572 | |
| TO BE FILED UNDER SEAL | |
| Agent Affidavit in Support of | |
| Application for Search and Seizure | |
| Warrant | |
| SOUTHERN DISTRICT OF NEW YORK) ss.: | |
| being duly sworn, deposes and says: | |
| I. Introduction | |
| A. Affiant | |
| 1. | |
| I have been a Special Agent with the Federal Bureau of Investigation ("FBI"*) since | |
| 2012. 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 have been | |
| employed by the FBI for three and a half years, and I am currently assigned to investigate violations | |
| of criminal law relating to the sexual exploitation of children. 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 been | |
| involved in search warrants for physical premises. | |
| 2. | |
| I make this Affidavit in support of an application pursuant to Rule 41 of the Federal | |
| Rules of Criminal Procedure for a second warrant to search the premises specified below (the | |
| "Subject Premises") for the purpose of seizing the items and information described in | |
| Attachment A. This affidavit is based upon my personal knowledge; my review of documents and | |
| other evidence; and my conversations with other law enforcement personnel. Because this | |
| 2017.08.02 | |
| 1 | |
| CONFIDENTIAL | |
| SDNY_GM_00000107 | |
| EFTA_00114191 | |
| EFTA01262864 | |
| 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 Premises | |
| The Subject Premises are particularly described as a multi-story, single-family | |
| residence located at 9 East 71st Street, New York, New York, and include all locked and closed | |
| containers found therein. As detailed further herein, the Subject Premises is believed to be owned, | |
| possessed and controlled by JEFFREY EPSTEIN, a target subject of this investigation. A | |
| photograph of the front entrance to the Subject Premises is included below: | |
| 4. | |
| C. The Target Subjeet and the Subject Offenses | |
| The Target Subject of this investigation is JEFFREY EPSTEIN. | |
| 5. | |
| For the reasons detailed below, I believe that there is probable cause to believe that | |
| the Subject Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United | |
| 2017.08.02 | |
| 2 | |
| CONFIDENTIAL | |
| SDNY_GM_00000108 | |
| EFTA_00114192 | |
| EFTA01262865 | |
| States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section | |
| 371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject. | |
| II. Probable Cause and the First Warrant | |
| A. Probable Cause Regarding the Target Subject's Commission of the | |
| Subject Offenses | |
| 6. | |
| On or about July 2, 2019, a grand jury in this District returned an Indictment | |
| charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached | |
| hereto as Exhibit A and is incorporated by reference. | |
| B. Probable Cause Justifying Search of the Subject Premises | |
| The Indictment and Victim-l | |
| 7. | |
| As set forth in Exhibit A, from at least in or about 2002, up to and including at least | |
| in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern | |
| District of New York and elsewhere. During that time and continuing to the present, EPSTEIN | |
| possessed and controlled the Subject Premises, which is described in Exhibit A as "the New York | |
| Residence." | |
| 8. | |
| As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or | |
| about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous | |
| minor victims at the Subject Premises. In particular, and as alleged in the Indictment, when a | |
| victim arrived at the Subject Premises, she would be escorted to a room inside the Subject Premises | |
| with a massage table, where she would perform a massage on EPSTEIN. | |
| 2017.08.02 | |
| 3 | |
| CONFIDENTIAL | |
| SDNY_GM_00000109 | |
| EFTA_00114193 | |
| EFTA01262866 | |
| •. Following each encounter, EPSTEIN | |
| or one of his employees or associates paid the victim in cash. | |
| 9. | |
| As set forth in paragraphs 12 through 13 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. | |
| 10. | |
| One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of | |
| the FBI's investigation of EPSTEIN, other law enforcement officers have interviewed Victim-1.' | |
| 1 know from my conversations with other law enforcement officers who have interviewed Victim- | |
| 1, that Victim-l has provided the following information, in substance and in part: | |
| a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-l on | |
| multiple occasions in the Subject Premises. 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 Subject Premises | |
| and numerous individual rooms within the Subject Premises. Victim-1 has provided detailed | |
| ' 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. Vietim-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. | |
| 2017.08.02 | |
| CONFIDENTIAL | |
| SDNY_GM_00000110 | |
| EFTA_00114194 | |
| EFTA01262867 | |
| • | |
| descriptions of certain aspects of the interior of the Subject Premises, including Victim-l's | |
| memory of specific details regarding the layout, furnishings, decorations, and floor pattern of | |
| various areas within the Subject Premises. | |
| c. In particular, Victim-1 observed that a bathroom in the residence contained what | |
| appeared to be a bust of a human torso (the "Torso"). Victim-1 believed that the Torso was | |
| possibly a type of sex toy. | |
| d. In addition, Victim-1 recalled observing what appeared to be a taxidermied dog in | |
| a living space in the Subject Premises. | |
| e. Victim-1 recalled that EPSTEIN typically abused her in a room she described as a | |
| "massage room," (the "Massage Room"), which contained a massage table, and was decorated | |
| with artwork depicting naked women, hung on walls that appeared to be adorned with fabric. | |
| f. Victim-1 has not been in the Subject Premises since approximately 2005. | |
| The July 6. 2019 Search Warrant of the Subject Premises | |
| 11. | |
| On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate | |
| Judge, signed a search warrant authorizing a search of the Subject Premises. The search warrant | |
| is attached as Exhibit B and incorporated by reference herein. | |
| 12. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the | |
| "Search Team"') commenced executing the search warrant at the Subject Premises; I joined the | |
| Search Team thereafter. While inside the Subject Premises, I observed the following, among other | |
| things: | |
| a. | |
| Inside a closet within the entryway to a bathroom in the Subject Premises, I | |
| observed what appear to be two busts of female human torsos, from their upper pelvis to the neck. | |
| In addition, inside the bathroom, I observed a third bust, which appears to depict a female body | |
| 2017.08.02 | |
| 5 | |
| CONFIDENTIAL | |
| SDNY_GM_00000111 | |
| EFTA_00114195 | |
| EFTA01262868 | |
| from the ribcage to the clavicle (collectively, (the "Busts"). The Busts do not appear to be designed | |
| for use as sex toys, and appear instead to be artwork. Nevertheless, based on my conversations | |
| with law enforcement officers who have interviewed Victim-1, I have learned that the Busts appear | |
| to be generally consistent with Victim-l's description of observing the Torso in EPSTEIN's | |
| bathroom in the Subject Premises. Accordingly, there is probable cause to believe that the Busts | |
| are corroborating evidence of Victim-1's description of the Subject Premises. | |
| b. | |
| Inside the Subject Premises, I observed a room that, based on my conversations | |
| with law enforcement officers who have interviewed Victim-1, appears to be consistent with | |
| Victim-l's descriptions of the Massage Room. The room contained a table covered with a sheet, | |
| and appears to be a massage table. The walls appear 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. Based on my training and experience investigating crimes involving the sexual | |
| exploitation of children, the girl appears to be approximately 15 to 20 years old. | |
| C. | |
| Inside the Subject Premises, inside a closet adjacent to a bathroom, I observed a | |
| shelf that appears to contain several black binders, with labels on the spine of each binder. In | |
| particular, one of the binders is marked with a series of labels, one of which reads: "PB Girls." | |
| Given that the Indictment charges EPSTEIN with participating in a conspiracy to engage in sex | |
| trafficking of minor girls in both Palm Beach, Florida and New York, I believe that "PB Girls" | |
| may refer to minor victims in Palm Beach, Florida. | |
| d. | |
| Inside the Subject Premises, in what appears to be EPSTEIN's office, on or about | |
| the second floor of the Subject Premises, I observed what appears to be a taxidermied dog (the | |
| "Dog"). Based on my conversations with law enforcement officers who have interviewed | |
| 2017.08.02 | |
| 6 | |
| CONFIDENTIAL | |
| SDNY_GM_00000112 | |
| EFTA_00114196 | |
| EFTA01262869 | |
| Victim-1, the Dog appears to be consistent with Victim-I's description of observing a taxidermied | |
| dog in the Subject Premises. | |
| e. | |
| Inside the Subject Premises, I observed in plain view several sheets of stationary, | |
| with letterhead marked "Jeffrey Epstein." | |
| 13. | |
| After observing the foregoing items, the Search Team stopped the search and froze | |
| the scene in order to seek a new search warrant. | |
| III. Conclusion and Ancillary Provisions | |
| 14. | |
| Based on the foregoing, given that several items described by Victim-1 as being | |
| present in the Subject Premises in 2005 appear to be currently in the Subject Premises, | |
| I respectfully submit there is probable cause to believe that evidence of the Subject Offenses, and | |
| in particular the items described in Attachment A, will be located within the Subject Premises and | |
| therefore request the court to issue a warrant to seize the items and information specified in | |
| Attachment A to this affidavit and to the Search and Seizure Warrant. | |
| 15. | |
| The Search Team is currently at the Subject Premises, securing the location, and | |
| would anticipate executing the requested search warrant immediately. However, given the late | |
| hour, it is anticipated that the Search Team would commence executing the search warrant after | |
| 2017.08.02 | |
| 7 | |
| CONFIDENTIAL | |
| SDNY_GM_00000113 | |
| EFTA_00114197 | |
| EFTA01262870 | |
| 10 p.m. In view of the foregoing circumstances, I respectfully submit that the present | |
| circumstances demonstrate good cause to execute the warrant after 10 p.m. | |
| Special Agent | |
| Federal Bureau of Investigation | |
| Sworn to before me on | |
| July 6. 2019 | |
| Istanths | |
| THE HONORABLE BARBARA MOSES | |
| UNITED STATES MAGISTRATE JUDGE | |
| Seppellable dechine | |
| nears (Facetine) | |
| 2017.08.02 | |
| 8 | |
| CONFIDENTIAL | |
| SDNY_GM_00000114 | |
| EFTA_00114198 | |
| EFTA01262871 | |
| EXHIBIT A | |
| 2017.08.02 | |
| 9 | |
| CONFIDENTIAL | |
| SDNY_GM_00000115 | |
| EPTA_00114199 | |
| EFTA01262872 | |
| UNITED STATES DISTRICT COURT | |
| SOUTHERN DISTRICT OF NEW YORK | |
| UNITED' STATES OF AMERICA | |
| V. | |
| JEFFREY EPSTEIN, | |
| Defendant. | |
| SEALED | |
| INDICIMENT | |
| 19 CI. | |
| 19 CRIM | |
| 490 | |
| -- * | |
| COUNT ONE | |
| (Sex Trafficking Conspiracy) | |
| The Grand Jury charges: | |
| OVERVIEW | |
| 1. | |
| As set forth herein, over the course of many | |
| years, JEFFREY EPSTEIN, the defendant, sexually exploited and | |
| • abused dozens of minor girls at his homes in Manhattan, New | |
| York, and Palm Beach, Florida, among other locations. | |
| 2. | |
| In particular, from at least in or about 2002, up | |
| to and including at least in or about 2005, JEFFREY EPSTEIN, the | |
| defendant, enticed and recruited, and caused to be enticed and | |
| recruited, minor girls to visit his mansion in Manhattah, | |
| New | |
| York (the "New York Residence") and his estate in Palm Beach; | |
| Florida (the "Palm Beach Residence") to engage in sex acts with | |
| him, after which he would give the victims hundreds of dollars | |
| in cash. Moreover, and in order to maintain and increase his | |
| supply of victims, EPSTEIN also paid certain of his victims to | |
| recruit additional girls to be similarly abused by EPSTEIN. In | |
| CONFIDENTIAL | |
| SDNY_GM_00000116 | |
| EFTA_00114200 | |
| EFTA01262873 | |
| 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. | |
| 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. | |
| 5. | |
| Beginning in at least 2002, JEFFREY EPSTEIN, the | |
| defendant, enticed and recruited, and caused to be enticed and | |
| CONFIDENTIAL | |
| SDNY_GM_00000117 | |
| EFTA_00114201 | |
| EFTA01262874 | |
| 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. | |
| 1: 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, EPSIEIN 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 Fast 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. | |
| CONFIDENTIAL | |
| SDNY_GM_00000118 | |
| EPTA_00114202 | |
| EFTA01262875 | |
| 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 | |
| EPSTEIN typically would also | |
| 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 | |
| SDNY_GM_00000119 | |
| CONFIDENTIAL | |
| EFTA_00114203 | |
| EFTA01262876 | |
| 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 | |
| CONFIDENTIAL | |
| SDNY_GM_00000120 | |
| EFTA_00114204 | |
| EFTA01262877 | |
| 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, JEFEREY 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, 1.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. | |
| CONFIDENTIAL | |
| SDNY_GM_00000121 | |
| EFTA_00114205 | |
| EFTA01262878 | |
| 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 victins were underage, including because certain victims | |
| told him their age. In addition, as with New York-based | |
| victims, many Florida victims, once recruited, were abused by | |
| JEFFREY EPSTEIN, the defendant, on multiple additional | |
| occasions. | |
| 18. JEFFREY EPSTEIN; the defendant, who during the | |
| relevant time period was frequently in New York, would arrange | |
| for Employee-2 or other employees to contact victims by phone in | |
| advance of EPSTEIN's travel to Florida to ensure appointments | |
| were scheduled for when he arrived. In particular, in certain | |
| instances, Employee-2 placed phone calls to minor victims in | |
| Florida to schedule encounters at the Palm Beach Residence. At | |
| the time of certain of those phone calls, EPSTEIN and Employee-2 | |
| were in New York, New York. Additionally, certain of the | |
| individuals victimized at the Palm Beach Residence were | |
| contacted by phone by Employee-3 to schedule | |
| these encounters. | |
| CONFIDENTIAL | |
| - SDNY_GM_00000122 | |
| EFTA_00114206 | |
| EFTA01262879 | |
| 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 connit an | |
| offense against the United States, to wit, sex trafficking of | |
| minors, | |
| in violation of Title 18, United States Code, Section. | |
| 1591(a) and (b). | |
| 21. It was a part and object of the conspiracy that | |
| JEFFREY EPSTEIN, the defendant, and others known and unknown, | |
| would and did, in and affecting interstate and foreign commerce, | |
| recruit, entice, harbor, transport, provide, and obtain, by any | |
| means a person, and to benefit, financially and by receiving | |
| anything of value, from participation in a venture which has | |
| engaged in any such act, knowing that the person had not | |
| attained the age of 18 years and would be caused to engage in a | |
| CONFIDENTIAL | |
| SDNY_GM_00000123 | |
| EFTA_00114207 | |
| EFTA01262880 | |
| commercial sex act, in violation of Title 18, United States | |
| Code, Sections 1591 (a) and (b) (2). | |
| Overt Acts | |
| 22. In furtherance of the conspiracy and to effect | |
| the illegal object thereof, the following overt acts, among | |
| others, were committed in the Southern District of New York and | |
| elsewhere: | |
| a. | |
| In or about 2004, JEFFREY EPSTEIN, the | |
| defendant, enticed and recruited multiple minor victims, | |
| including minor victims identified herein as Minor Victim-1, | |
| Minor Victim-2, and Minor Victim-3, to engage in sex acts with | |
| EPSTEIN at his residences in Manhattan, New York, and Palm | |
| Beach, Florida, after which he provided them with hundreds of | |
| dollars in cash for each encounter. | |
| b. In or about 2002, Minor Victim-1 was | |
| recruited to engage in sex acts with EPSTEIN and was repeatedly | |
| sexually abused by EPSTEIN at the New York Residence | |
| over a | |
| period of years and was paid hundreds of dollars for each | |
| encounter. EPSTEIN also encouraged and enticed Minor Victim-1 | |
| to recruit other girls to engage in paid sex acts, which she | |
| did. EPSTEIN asked Minor Victim-1 how old she was, and Minor | |
| Victim-1 answered truthfully. | |
| C. | |
| In or about 2004, Employee-1, located in the | |
| Southern District of New York, and on behalf of EPSTEIN, placed | |
| CONFIDENTIAL | |
| SDNY_GM_00000124 | |
| EFTA_00114208 | |
| EFTA01262881 | |
| a telephone call to Minor Victim-1, in order to schedule an | |
| appointment for Minor Victim-1 to engage in paid sex acts with | |
| EPSTEIN. | |
| d. In or about 2004, Minor Victim-2 was | |
| recruited to engage in sex acts with EPSTEIN and was repeatedly | |
| sexually abused by EPSTEIN at the Palm Beach Residence over a | |
| period of years and was paid hundreds of dollars after each | |
| encounter, EPSTEIN also encouraged and enticed Minor Victim-2 | |
| to recruit other girls to engage in paid sex acts, which she | |
| did. | |
| e. In or about 2005, Employee-2, located in the | |
| Southern District of New York, and on behalf of EPSTEIN, placed | |
| a telephone call to Minor Victim-? 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. | |
| CONFIDENTIAL | |
| SDNY_GM_00000125 | |
| EFTA_00114209 | |
| EFTA01262882 | |
| g. In or about 2005, Employee-2, located in the | |
| Southern District of New York, and on behalf of EPSTEIN, placed | |
| a telephone call to Minor Victim-3 in Florida in order to | |
| schedule an appointment for Minor Victim-3 to engage in paid sex | |
| acts with EPSTEIN. | |
| h. In or about 2004, Employee-3 placed a | |
| telephone call to Minor Victim-3 in order to schedule an | |
| appointment for Minor Victim-3 to engage in paid sex acts with' | |
| EPSTEIN. | |
| (Title 18, United States Code, Section 371. J | |
| 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 conmerce, 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 | |
| SDNY_GM_00000126 | |
| EFTA_00114210 | |
| EFTA01262883 | |
| 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 Two, or any property traceable to | |
| such property, and the following | |
| specific property: | |
| a. The lot or parcel of land, together with its | |
| buildings, appurtenances, improvements, fixtures, attachments | |
| and easements, located at 9 East İlst Street, New York, New | |
| York, with block number 1386 and lot number 10, owned by | |
| Maple, Inc. | |
| CONFIDENTIAL | |
| SDNY_GM_00000127 | |
| EFTA_00114211 | |
| EFTA01262884 | |
| 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; | |
| (e) has been placed beyond the jurisdiction of the Court; | |
| (d), has been substantially diminished in value; or | |
| (e) has been commingled with other property which cannot | |
| be subdivided without difficulty; | |
| it is the intent of the United States, pursuant to 21 U.S.C. | |
| § 853(p) and 28 U.S.C. S 2461(C), to seek forfeitute 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.) | |
| Crampas | |
| FOREPERSON | |
| GEOFFREY | |
| BERMAN | |
| United States Attorney | |
| CONFIDENTIAL | |
| SDNY_GM_00000128 | |
| EFTA_00114212 | |
| EFTA01262885 | |
| Form No. USA-33s-274 (Ed. 9-25-58) | |
| UNITED STATES DISTRICT COURT | |
| SOUTHERN DISTRICT OF NEW YORK | |
| UNITED STATES OF AMERICA | |
| v. | |
| JEFFREX EPSTEIN, | |
| Defendant. | |
| INDICTMENT | |
| (18 U.S.C. SS 371, 1591(a), (b) (2), | |
| and 2) | |
| GEOFFREY S. BERMAN | |
| United States Attorney | |
| Jennes | |
| CONFIDENTIAL | |
| SDNY_GM_00000129 | |
| EFTA_00114213 | |
| EFTA01262886 | |
| EXHIBIT B | |
| CONFIDENTIAL | |
| SDNY_GM_00000130 | |
| EPTA_00114214 | |
| EFTA01262887 | |
| AO 93 (SDNY Rev, 01/17) Search and Seizure Warrant | |
| In the Matter of the Search of | |
| friefly describe the property to be searche | |
| • Identify the person by name and addres | |
| See Attachment A | |
| UNITED STATES DISTRICT COURT | |
| for the | |
| Southern District of New York | |
| 1 GMAG | |
| Case No. | |
| 6582 | |
| 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 | |
| (identif 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 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 | |
| 7.20-19 | |
| A in the daytime 6:00 arm. to 10 p.m. O at any time in the day or night as T find re toad cause has been | |
| 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 ofticer 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) O for | |
| days (not to exceed 30). | |
| Duntil, the facts justifying, the later specific date of | |
| Date and time issued: | |
| 7.6.19 10:14 a.M. | |
| sextons | |
| Judge's signature | |
| City and state: New York, NY | |
| Hon. Barbara Moses, U.S. Magistrate Judge | |
| tame and title | |
| CONFIDENTIAL | |
| SDNY_GM_00000131 | |
| EFTA_00114215 | |
| EFTA01262888 | |
| AO 93 (SDNY Rev. 0I/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_00000132 | |
| EFTA_00114216 | |
| EFTA01262889 | |
| 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 9 East 71st Street, New York, | |
| New York, and include all locked and closed containers found therein. A photograph of the front | |
| entrance to the Subject Premises is included below: | |
| I. Items to Be Seized | |
| 1. This warrant authorizes executing agents to photograph, video record and otherwise | |
| document the full interior of the Subject Premises, including any items, furnishings, or possessions | |
| therein. | |
| 2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and | |
| instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of | |
| minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: | |
| a. Evidence concerning occupancy or ownership of the Subject Premises, | |
| including utility and telephone bills, mail envelopes, addressed correspondence, | |
| diaries, statements, identification documents, address books, telephone | |
| directories, and photographs of its occupant(s). | |
| b. Evidence concerning the layout, furnishings, decorations, and floor pattern of | |
| the Subject Premises, including photographs and blueprints of the Subject | |
| Premises. | |
| 2017.08.02 | |
| CONFIDENTIAL | |
| SDNY_GM_00000133 | |
| EFTA_00114217 | |
| EFTA01262890 |