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FBI VOL00009
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photographs include MAXWELL clothed with other clothed females who appear to be
approximately between the ages of 16 and 22.
29.
Among the photographs on the Seized Discs, the Reviewing Agents identified
partially-nude photographs of a young girl, labeled with an associated name that matched a
particular individual ("Individual-1"). After identifying those photographs, the Government was
advised by Individual-1's counsel that Individual-1 recalls the month and year during which she
believes those partially-nude photographs were taken, and also the location where they were taken,
and that she was 17 years old at the time.
30.
Following the initiation of the FBI's review of the Seized Discs, on or about July
II, 2019, the Honorable Henry B. Pitman, United States Magistrate Judge, signed another search
warrant authorizing another search of the New York Residence and specifically authorizing the
seizure and search of electronic devices and storage media inside the New York Residence for
evidence of the Original Subject Offenses (the "Fourth Search Warrant"). The Fourth Search
Warrant is attached as Exhibit F and incorporated by reference herein.
31.
Later on July 11, 2019, the Search Team executed the Fourth Search Warrant at the
New York Residence. Based on my conversations with members of the Search Team, I have
learned the following, among other things, regarding the execution of the Fourth Search Warrant:
a.
During the July 11, 2019 execution of the Fourth Search Warrant inside the
New York Residence, the Search Team found that the Safe described above was empty and, in
particular, that the collection of discs and hard drives described in paragraphs 24(c)-(f), above, that
the Search Team had not seized during its prior search of the New York Residence on July 7, 2019,
had been removed.
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FI
b.
After discovering that the Safe was empty, the Search Team spoke with an
employee who worked at the New York Residence (the "Employee"). During that conversation,
the Employee told the Search Team that after the completion of the prior search on July 7, 2019,
the Employee had been instructed by a third party ("the Third Party") to take the contents of the
Safe out of the New York Residence and deliver those items to the Third Party. The Employee
further told the Search Team that after receiving that instruction, the Employee packed the contents
of the Safe into two suitcases and delivered those suitcases to the Third Party. The Employee
provided the Search Team with the Third Party's contact information.
c.
The Search Team then contacted the Third Party. During the ensuing
conversation, the Third Party confirmed receipt of two suitcases from the Employee but also told
the Search Team that the Third Party had not opened the suitcases or touched or tampered with
their contents. The Third Party also agreed to deliver the two suitcases to the Search Team.
d.
Later on July 11, 2019, and consistent with the conversation described
above, the Third Party met the Search Team outside of the New York Residence and provided
them with the two suitcases described above, one of which was blue and one of which was black.
Consistent with standard law enforcement protocol, the Search Team conducted an inventory of
both suitcases before taking custody of them. While taking an inventory of the blue suitcase, the
Search Team discovered, among other items, Subject Device-3. These items, including Subject
Item-3, appeared to be the same items observed in the Safe by the Search Team during the July 7,
2019 search of the New York Residence.
32.
On or about July 14, 2019, the Honorable Kevin Nathaniel Fox, United States
Magistrate Judge, signed a search warrant authorizing the search of Subject Device-1, Subject
Device-2, and Subject Device-3 for evidence of the Original Subject Offenses (the "Fifth Search
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Warrant"). The Fifth Search Warrant is attached as Exhibit G and incorporated by reference herein. 33. Based on my personal participation in the searches of the New York Residence, as well as my conversations with other law enforcement agents who participated in those same searches, and my review of documents prepared by other law enforcement agents who participated in those same searches, I have learned that during the July 11, 2019 search of the New York Residence: a. Subject Device-4 was recovered from in a cardboard box along the right wall of a room on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515034. b. Subject Device-5 was recovered from a shelf in the right corner of a room on the third floor of the New York Residence under a television, and has been assigned internal FBI barcode number E651503. c. Subject Device-6 was recovered from under a sink in a room on the third floor of the New York Residence, and has been assigned internal FBI barcode number E6515032. d. Subject Device-7 was recovered from under a sink in a room on the third floor of the New York Residence, and has been assigned internal FBI barcode number E6515031. e. Subject Device-8 was recovered from inside a desk drawer in the drawing room on the second floor of the New York Residence, and has been assigned internal FBI barcode number E6515026. 23 2017.08.02 EFTA00153081
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f. Subject Device-9 was recovered from a storage area in the basement of the New York Residence, and has been assigned internal FBI barcode number E6515025. g. Subject Device-10 was recovered from a storage area in the basement of the New York Residence, and has been assigned internal FBI barcode number E6515024. h. Subject Device-11 was recovered from a storage area in the basement of the New York Residence, and has been assigned internal FBI barcode number E6515023. i. Subject Device-12 was recovered from a drawer inside a room on the sixth floor of the New York Residence, and has been assigned internal FBI barcode number E6515022. j. Subject Device-13 was recovered from a desk inside a room on the sixth floor of the New York Residence, and has been assigned internal FBI barcode number E6515021. k. Subject Device-14 was recovered from a shoebox on top of a desk in a room on the fifth floor of the New York Residence, and has been assigned internal FBI barcode number E6515020. 1. Subject Device-15 was recovered from the lower left shelf of a white wooden cabinet in a room on the fifth floor of the New York Residence, and has been assigned internal FBI barcode number E6515019. m. Subject Device-16 was recovered from on top of a desk inside the drawing room on the second floor of the New York residence, and has been assigned internal FBI barcode number E6515018. 24 2017.08.02 EFTA00153082
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n. Subject Device-17 was recovered from on top of a desk in a room on the fifth floor of the New York Residence, and has been assigned internal FBI barcode number E6515017. o. Subject Device-18 was recovered from a cabinet on the back wall of a storage closet on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515016. p. Subject Device-19 was recovered from a cabinet on the back wall of a storage closet on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515015. q. Subject Device-20 was recovered from a cabinet on the back wall of a storage closet on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515014. r. Subject Device-21 was recovered from a cabinet on the back wall of a storage closet on the first floor of the New York Residence, and which has been assigned internal FBI barcode number E6515013. s. Subject Device-22 was recovered from a cabinet on the back wall of a storage closet on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515012. t. Subject Device-23 was recovered from a small tray on the floor of the dining room on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515011. 25 2017.08.02 EFTA00153083
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u. Subject Device-24 was recovered from a small tray on the floor of the dining room on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515010. v. Subject Device-25 was recovered from a drawer inside a table in the dining room on the First Floor of the New York Residence, and has been assigned internal FBI barcode number E6515008. w. Subject Device-26 was recovered from a desk in a room on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515007. x. Subject Device-27 was recovered from a desk in a room on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515006. y. Subject Device-28 was recovered from a desk in a room on the first floor of the New York Residence, and which has been assigned internal FBI barcode number E6515005. z. Subject Device-29 was recovered from a desk in a room on the first floor of the New York Residence, and which has been assigned internal FBI barcode number E6515004. aa. Subject Device-30 was recovered from a desk in a room on the first floor of the New York Residence, and which has been assigned internal FBI barcode number E6515003. 26 2017.08.02 EFTA00153084
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bb. Subject Device-3I was recovered from a desk in a room on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515002. cc. Subject Device-32 was recovered from inside a book shelf cabinet in an oval study on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515001. dd. Subject Device-33 was recovered from inside a bookshelf cabinet in an oval study on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6515000. ee. Subject Device-34 was recovered from inside a bookshelf cabinet in an oval study on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6433827. ff. Subject Device-35 was recovered from a desk in an oval study on the first floor of the New York Residence, and has been assigned internal FBI barcode number E6433828. Search of the Virgin Islands Residence 34. 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 appears that an entity named "L.S.J., LLC" 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. 27 2017.08.02 EFTA00153085
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35. 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. 36. Based on my participation in this investigation, I have reason to believe that EPSTEIN and his co-conspirators committed and/or maintained evidence of the Original and Additional 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, as described above, compact discs seized from the New York Residence contain approximately thousands of nude or partially nude photographs of girls or young women, many of which are in sexually suggestive poses. Certain of these images appear to have been taken at a tropical location, and/or were labeled "LSJ" 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 "U" which are the initials of a Target Subject of the ongoing investigation. As set forth below, I and other law enforcement agents have interviewed Individual-I,4 who has In or about November 2019, Individual-1 filed a civil lawsuit against EPSTEIN's estate seeking damages for the conduct described in this affidavit. Information provided by Individual-1 has been corroborated by independent evidence, including other witness statements and travel records, and has proven reliable. 28 2017.08.02 EFTA00153086
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reported that photographed her at the Virgin Islands Residence. Accordingly, I believe that a portion of these photos may have been taken by 37. Further, based on my conversations with law enforcement agents who have conducted an initial review of the Seized Discs, I have learned the following: a. Many of the photographs appear to be labeled with file names that include "LSJ," which I believe stands for Little St. James, which is the name of the Virgin Islands Residence. b. As discussed above, photographs seized from the New York Residence appear to depict nude or partially nude young girls, and a portion of those photos appear to have been taken at the Virgin Islands Residence, based on the fact that (i) some of the photos appear to have been taken in a tropical location, and (ii) some of the file names of the photographs and/or the labels on the discs containing the files of nude or partially nude young girls in a tropical location are marked "LSJ," i.e., the Virgin Islands Residence. c. Among the photographs seized from the New York Residence, the Reviewing Agents identified partially-nude photographs of a young girl, labeled with the name of 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. 38. 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 29 depict Individual-1. I have also spoken with another law enforcement agent who 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 29 2017.08.02 EFTA00153087
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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.
39.
In or about August 2019, I and another law enforcement officer interviewed an
individual ("Individual-21 who regularly performed work for JEFFREY EPSTEIN as a contractor
at the Virgin Islands Residence from approximately 1999 to 2005 or 2006. Individual-2 reported
that, on several occasions, Individual-2 observed photographs of what appeared to be nude or
partially nude young girls in several locations throughout the main residence of the Virgin Islands
Residence. Individual-2 recalled a photograph depicting
and two girls, all three
of whom were topless; Individual-2 estimated that the two girls in the photograph appeared to be
approximately 15 or 16 years old. Individual-2 knew
to be EPSTEIN's assistant at that
time.
40.
Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN,
I have learned that
traveled to the U.S. Virgin Islands at least approximately
once a month between October 2001 and November of 2005. These records do not include any
travel
may have taken on commercial airlines.
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41.
In or about October 2019, I and another law enforcement officer interviewed
another individual ("Individual-3")5 who travelled at JEFFREY EPSTEIN's invitation to the
Virgin Islands Residence on multiple occasions in or about 2006 and 2007 when Individual-3 was
approximately 21 years old. Individual-3 reported that EPSTEIN sexually assaulted Individual-3
on multiple occasions at the Virgin Islands Residence. Individual-3 also reported that during at
least some of her visits to the Virgin Islands Residence, GHISLAINE MAXWELL was present at
the Virgin Islands Residence. On multiple occasions at the Virgin Islands residence, MAXWELL
instructed Individual-3 and other young women to engage in sex acts with EPSTEIN. Among
other things, MAXWELL provided Individual-3 and other young women with specific instructions
regarding how to perform oral sex on EPSTEIN. MAXWELL told Individual-3 that Individual-3
was only at the Virgin Islands Residence to sexually please EPSTEIN. Individual-3 further
reported that some of the sex acts she engaged in with EPSTEIN involved other females who
appeared young and may have been under the age of 18, but whose age Individual-3 did not know.
42.
Based on my review of flight logs from a private jet owned by JEFFREY EPSTEIN
for the years 1998 through 2006, I have learned that GHISLAINE MAXWELL travelled to the
U.S. Virgin Islands at least approximately four times in 1998, eleven times in 1999, five times in
2000, eight times in 2001, seven times in 2002, five times in 2003, two times in 2004, one time in
2005, and one time in 2006. These records do not include any travel MAXWELL may have taken
on commercial airlines.
5 In or about August 2020, Individual-3 filed a civil lawsuit against EPSTEIN's estate seeking
damages for the conduct described in this affidavit. Information provided by Individual-3 has been
corroborated by independent evidence, including other witness statements and travel records, and
has proven reliable.
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43. For all of these reasons, I am aware that and GHISLAINE MAXWELL have both spent significant time at the Virgin Islands Residence, among JEFFREY EPSTEIN's various other properties, and that evidence of their involvement, and potentially the involvement of other co-conspirators, in the Subject Offenses 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. 44. 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 for fruits, evidence and instrumentalities of the Original Subject Offenses (the "Sixth Search Warrant"). The Sixth Search Warrant is attached as Exhibit H, and incorporated by reference herein. The next day, other law enforcement agents and I executed the Virgin Islands Warrant at the Virgin Islands Residence. 45. 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-36 was recovered from a desk in the main residence on the island. b. Subject Device-37 was recovered from a desk in the main residence on the island. c. Subject Device-38 was recovered from a desk in the main residence on the island. 32 2017.08.02 EFTA00153090
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d. Subject Device-49 was recovered from a desk in the main residence on the island. e. Subject Device-40 was recovered from a desk in the main residence on the island. f Subject Device-41 was recovered from a desk in the pool house on the island. g. Subject Device-42 was recovered from a desk in a cabana on the island. h. Subject Device-43 was recovered from a box on the floor near a desk in a shed on the island. i. Subject Device-44 was recovered from a desk in a shed on the island. j. Subject Device-45 was recovered from a desk in a cabana on the island. k. Subject Device-46 was recovered from a desk in a cabana on the island. 1. Subject Device-47 was recovered from a desk in the beach house on the island. m. Subject Device-48 was recovered from a desk in the beach house on the island. n. Subject Device-49 was recovered from a server rack inside a shed on the island. o. Subject Device-50 was recovered from a server rack inside a shed in on the island. p. Subject Device-51 was recovered from a shed on the island. q. Subject Device-52 was found on a server rack in a shed on the island. r. Subject Device-53 was found on a server rack in a shed on the island. s. Subject Device-54 was recovered from a desk in a cabana on the island. t. Subject Device-55 was recovered from the maintenance office on the island. u. Subject Device-56 was recovered from the maintenance office on the island. v. Subject Device-57 was recovered from the maintenance office on the island. w. Subject Device-58 was recovered the maintenance office on the island. x. Subject Device-59 was recovered the maintenance office on the island. 3/- Subject Device-60 was recovered the maintenance office on the island. 33 2017.08.02 EFTA00153091
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z. Subject Device-61 was found on a server rack in a shed on the island. aa. Subject Device-62 was recovered on a file cabinet next to a desk in a cabana on the island. 46. On or about September 12, 2019, the Honorable James L. Cott, United States Magistrate Judge, signed a warrant authorizing the search of Subject Device-37 through Subject Device-63 for fruits, evidence, and instrumentalities of the Original Subject Offenses (the "Seventh Search Warrant"). The Seventh Search Warrant is attached as Exhibit I, and incorporated by reference herein. The Initial Search of the Subject Devices 47. I know from my personal involvement in this investigation, as well as my conversations with other law enforcement agents, that pursuant to the Fourth Search Warrant, the Fifth Search Warrant, and the Seventh Search Warrant—which, collectively, authorized the search of all of the Subject Devices for evidence of the Original Subject Offenses—the FBI has undertaken a multi-step process to review all of the data from all of the Subject Devices. First, the FBI extracted data from all of the Subject Devices. This process involved multiple months of work by technical specialists at the FBI to access the data on the devices and convert the data into a reviewable format. Second, at the request of attorneys for JEFFREY EPSTEIN, the United States Attorney's Office for the Southern District of New York has conducted a privilege review of the extracted data as it has been received from the FBI. Third, as data has been cleared through the privilege review, it has then been reviewed by the case team. That review has involved both the examination of individual documents and the application of search terms for particular keywords through the data. 34 2017.08.02 EFTA00153092
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48.
I know from my personal involvement in this investigation, as well as my
conversations with other law enforcement agents, that during the third stage of the above-described
search process, the case team identified within the data extracted from the Subject Devices
electronic communications that involve GHISLAINE MAXWELL as either a sender or recipient,
but which do not include JEFFREY EPSTEIN as a sender or recipient. For example, I have
reviewed the following communications contained in the data extracted from the Subject Devices:
a. In an email sent to MAXWELL on or about February 7, 2004, an individual
("Individual-4") asked for details regarding the payments MAXWELL would provide to
Individual-4 in exchange for Individual-4 identifying "beautiful, talented young women ... to train
/ work with" EPSTEIN. Individual-4 further noted, "i have a couple of girls in mind, so let me
know what arrangement we will have, and i will do my best to help." Based on my training,
experience, and participation in this investigation, I believe that in this email Individual-4 was
discussing with MAXWELL the recruitment of young females to engage in sex acts with
EPSTEIN.
b. In an email sent to MAXWELL on or about August 16, 2002, an individual
("Individual-5") asked MAXWELL, "Have you found me some new inappropriate friends?"
Based on my training, experience, and participation in this investigation, I believe that in this email
Individual-5 was asking whether MAXWELL had found any young females to engage in sex acts
with Individual-5.
c. In an email sent to MAXWELL on or about February 28, 2002, Individual-5
discussed an upcoming trip that MAXWELL was helping to arrange for Individual-5. In that same
email, Individual-5 wrote, "As for girls well I leave that entirely to you and [another individual]!"
Based on my training, experience, and participation in this investigation, I believe that in this email
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Individual-5 was discussing MAXWELL's attempts to arrange for young females to engage in sex acts with Individual-5. d. In an email that MAXWELL sent to Individual-5 on March 3, 2002, MAXWELL informed Individual-5 that she was trying to arrange, "some 2 legged sight seeing (read intelligent pretty fun and from good families)" for Individual-5 on an upcoming trip. Based on my training, experience, and participation in this investigation, I believe that in this email MAXWELL was discussing her attempts to arrange for young females to engage in sex acts with Individual-5. 49. I further know from my personal involvement in this investigation, as well as my conversations with other law enforcement agents, that the ongoing investigation into JEFFREY EPSTEIN and his associates has revealed that on multiple occasions, and as recently as August 8, 2019, EPSTEIN changed his will to adjust bequests to his co-conspirators, including and GHISLAINE MAXWELL. Specifically, in February 2019, EPSTEIN's will bequeathed a $10,000,000 annuity to and forgave any loans EPSTEIN had made to . EPSTEIN's February 2019 will did not mention MAXWELL. On August 8, 2019, EPSTEIN amended his February 2019 will to, among other things, change the bequests to and MAXWELL. In particular, the August 2019 will bequeathed $10,000,000 to MAXWELL and forgave any loans EPSTEIN had made to bequest to 50. I further know from my personal involvement in this investigation that as the FBI's investigation continued, the case team uncovered new evidence regarding GHISLAINE MAXWELL's participation in the Additional Subject Offenses, some of which is detailed above. 51. In light of the MAXWELL communications observed in the data extracted from the Subject Devices, as well as the new evidence of MAXWELL's participation in the Subject 36 but no longer made any 2017.08.02 EFTA00153094
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Offenses obtained since EPSTEIN's death, I now seek, out of an abundance of caution, the requested warrant to broaden the scope of the search of the Subject Devices. In particular, and out of an abundance of caution, this application seeks to expand the scope of the search of the Subject Devices to include the Additional Subject Offenses, to specifically permit the search for documents relating to MAXWELL, and to permit a search of documents dated between the earliest known abuse of a minor victim in 1994 through Epstein's most recent revision of his will on August 8, 2019. B. Probable Cause Justifying Further Search of the Subject Devices for Evidence of the Additional Subject Offenses 52. Based on my training, experience, and participation in this investigation, I believe that there is probable cause that evidence of the Additional Subject Offenses, such as photographs of EPSTEIN's victims and co-conspirators and communications involving EPSTEIN's co- conspirators, including GHISLAINE MAXWELL and will be found on the Subject Devices. In particular, information provided by Individual-1, who traveled across state lines at EPSTEIN's invitation and 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 Additional Subject Offenses at the Virgin Islands Residence. Similarly, information provided by Minor Victim-1, who similarly traveled across state lines at EPSTEIN's invitation with whom EPSTEIN engaged in sex acts at the New York Residence, as well as information provided by the other victims identified in the Indictment, confirms that EPSTEIN engaged in conduct relevant to the Additional Subject Offenses at the New York Residence. In addition, photographs on the Seized Discs recovered during the search of the New York Residence depict other young and partially nude girls photographed at multiple locations, including the Virgin Islands Residence, which suggests that EPSTEIN brought some girls to the Virgin Islands 37 2017.08.02 EFTA00153095
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Residence and that, consistent with the account provided by Individual-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, all of which would be relevant to the Additional Subject Offenses. Moreover, evidence of co-conspirators' presence at the New York Residence and/or the Virgin Islands Residence at times when victims were abused, including photographs, may also be found 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, including those of Devices. 53. Moreover, though the sexual abuse described in the Indictment occurred principally between approximately 2002 and 2005, and although the abuse described by Minor Victim-1 occurred principally between 1994 and 1997, as evidence recovered from the New York Residence including the Seized Discs makes clear, EPSTEIN continued to maintain substantial evidence of the Original and Additional 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. 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 Additional Subject Offenses, will similarly contain evidence of the Additional Subject Offenses. 54. In addition, I believe that evidence of the Additional Subject Offenses may be located on the Subject Devices because (i) the Virgin Islands Residence was the location of multiple photo shoots of young girls; (ii) the Virgin Islands Residence appears to have been, for the last several years and up until the time of his arrest, EPSTEIN's primary residence; and (iii) 38 and MAXWELL, will be located on the Subject 2017.08.02 EFTA00153096
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given its location, the Virgin Islands Residence is JEFFREY EPSTEIN's most private residence. Therefore, given that EPSTEIN has maintained evidence of the Original and Additional 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 and GHISLAINE MAXWELL, conspired to commit the Original and Additional Subject Offenses, evidence of EPSTEIN's involvement in trafficking, enticing, and transporting minors would also be relevant to the investigation of, and any future charges against, other members of the conspiracy, such as and MAXWELL. 55. 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 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. 56. Based on my training and experience in investigating individuals who engage in sex trafficking, enticement, and transportation of 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. 57. 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, 39 2017.08.02 EFTA00153097
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and individuals who store such materials on compact discs typically store similar files on other computing devices and storage devices. 58. Like individuals engaged in any other kind of activity, individuals who engage in sex trafficking, enticement, and transportation 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 payment of co-conspirators and victims; and (4) store exploitative photographs for future sexual gratification. 59. 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. 60. Based on the foregoing, I respectfully submit there is probable cause to believe that evidence of the Target Subjects' commission of the Additional Subject Offenses is likely to be found on the Subject Devices. 40 2017.08.02 EFTA00153098