This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →
FBI VOL00009
EFTA00247231
59 pages
Pages 1–20
/ 59
Page 1 / 59
payment of co-conspirators and victims; and (4) store exploitative photographs for future sexual gratification. 37. Computer files or remnants of such files can be recovered months or even years after they have been created or saved on an electronic device such as the Subject Devices. Even when such files have been deleted, they can often be recovered, depending on how the hard drive has subsequently been used, months or years later with forensics tools. Thus, the ability to retrieve from information from the Subject Devices depends less on when the information was first created or saved than on a particular user's device configuration, storage capacity, and computer habits. 38. Based on the foregoing, I respectfully submit there is probable cause to believe that evidence of the Target Subjects' commission of the Subject Offenses is likely to be found on the Subject Devices. Procedures for Searching ESI A. Review of ESI 39. Law enforcement personnel (who may include, in addition to law enforcement officers and agents, attorneys for the government, attorney support staff, agency personnel assisting the government in this investigation, and outside technical experts under government control) will review the ESI contained on the Subject Device for information responsive to the warrant. 40. In conducting this review, law enforcement may use various techniques to determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such techniques may include, for example: • surveying directories or folders and the individual files they contain (analogous to looking at the outside of a file cabinet for the markings it contains and opening a drawer believed to contain pertinent files); 21 2017.08.02 EFTA00247231
Page 2 / 59
• conducting a file-by-file review by "opening" or reading the first few "pages" of such files in order to determine their precise contents (analogous to performing a cursory examination of each document in a file cabinet to determine its relevance); • "scanning" storage areas to discover and possibly recover recently deleted data; scanning storage areas for deliberately hidden files; and • performing electronic keyword searches through all electronic storage areas to determine the existence and location of search terms related to the subject matter of the investigation. (Keyword searches alone are typically inadequate to detect all information subject to seizure. For one thing, keyword searches work only for text data, yet many types of files, such as images and videos, do not store data as searchable text. Moreover, even as to text data, there may be information properly subject to seizure but that is not captured by a keyword search because the information does not contain the keywords being searched.) 41. Law enforcement personnel will make reasonable efforts to restrict their search to data falling within the categories of evidence specified in the warrant. Depending on the circumstances, however, law enforcement may need to conduct a complete review of all the BSI from the Subject Device to 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, (ii) a fruit of the criminal activity, (iii) contraband, (iv) otherwise unlawfully possessed, or (v) evidence of the Subject Offenses. IV. Conclusion and Ancillary Provisions 43. Based on the foregoing, I respectfully request the court to issue a warrant to seize the items and information specified in Attachment A to this affidavit and to the Search and Seizure Warrant. 22 2017.08.02 EFTA00247232
Page 3 / 59
44. 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. Sworn to before me on Septe ern, 2019 S L. COTT STATES MAGISTRATE JUDGE Federal Bureau of Investigation 23 2017.08.02 EFTA00247233
Page 4 / 59
Attachment A
I. Devices Subject to Search and Seizure
The devices that are the subject of this search and seizure warrant (the "Subject Devices")
are described as follows:
The Subject Devices were all recovered from a search of a private island in the U.S. Virgin
Islands, known as Little Saint James, which is an approximately 75 acre island located
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands
Residence") on or about August 12, 2019. The Virgin Islands Residence consists of multiple
structures, including a main residence as well as several other smaller structures on the island,
including a pool house, sheds, a beach house, an office, and multiple cabanas. The Subject Devices •
are particularly described as follows:
a. A gray Mac desktop computer labeled "kitchen mac," which was recovered from a
desk in the main residence on the island ("Subject Device-1");
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89111772QT,
which was recovered from a desk in the main residence on the island ("Subject
Device-2");
c. A silver MacBook Pro bearing serial number c02qmOgugwdp, which was
recovered from a desk in the main residence on the island ("Subject Device-3");
d. A silver Wad model A1567 bearing serial number dmpq125ng5ypy, which was
recovered from a desk in the main residence ("Subject Device-4");
e. A silver Wad model A1567 bearing serial number dmpqL1rmg5y, which was
recovered from a desk in the main residence ("Subject Device-5");
f. A silver Mac desktop computer bearing serial number cO2nmlmOfy14, which was
recovered from a desk in the pool house on the island ("Subject Device-C);
g. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-7");
h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a
shed on the island ("Subject Device-8");
i. An HP laptop bearing serial number cnd81368v5, which was recovered from a desk
in a shed on the island ("Subject Device-9");
J. A silver Mac desktop computer, which was recovered from a desk in a cabana on
the island ("Subject Device-10");
2017.08.02
EFTA00247234
Page 5 / 59
k. A silver Macbook desktop computer, which was recovered from a desk in a cabana
on the island ("Subject Device-I I");
1. A Dell Inspiron Tower computer model DI9M 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");
n. A Unfi video bearing mac ID 18291 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 MDCQ3220187, which
was recovered from a shed on the island ("Subject Device-16");
q. A Panasonic KX TDE100 computer bearing serial number 1OC-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 MJCQ824A1R, 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
2017.08.02
EFTA00247235
Page 6 / 59
z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID
1843kb4fbe4d30c69-dcrgni9, 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:
1.
Evidence concerning the identity or location of the owner(s) or user(s) of the
Subject Devices
2.
Evidence concerning the identi
or location of, and communications with, co?
conspirators of Jeffrey Epstein, including
3.
Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
4.
Documents or records reflecting payments to victims and/or co-conspirators
including but not limited to bank and financial records, spreadsheets, ledgers, account listings,
check and wire records, and documents reflecting cash withdrawals.
5.
Any photographs of victims or potential victims of the Subject Offenses.
6.
Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger.
7.
Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to 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
usemames and passwords, user profiles, e-mail contacts, and photographs.
8.
Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
If the Government determines that any of the Subject Devices is no longer necessary to retrieve
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject
Device, upon request.
3
2017.08.02
EFTA00247236
Page 7 / 59
EXHIBIT A 2017.08.02 EFTA00247237
Page 8 / 59
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED'STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x SEALED INDICTMENT 19 Cr. CRIM 490 ' coONT ONE (Sex Trafficking Conspiraby) The Grand Jury °barges: OVERVIEW 1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and . abused dozens of minor girls at his homes in'Manhattan, New . York, and Palm Beach, Florida, among other locations. 2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defendant, enticed and' recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residende") 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, EpSTEIE also paid certain of hip victims to recruit additional girls to be similarly' abused by EPSTEIN. In EFTA00247238
Page 9 / 59
this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in locations including New York and Palm Beach. 3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the 'age of 18, including because, in some instances, minor victims expressly told him their age. • 4. In creating and maintaining this network of minor victims in multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his • conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence. FACTUAL BACKGROUND 5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant,'was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence. 6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and .caused to be enticed and . • 2 EFTA00247239
Page 10 / 59
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 Pala Beach Residence. 7: In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar wayq. victims were initially recruited to provide "massages' to EPSTEIN, which would be perforted 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 resideade 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. EFTA00247240
Page 11 / 59
9. When 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 EPSTEIN typically would also 10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, riaid the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter. 11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Fuither, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed EFTA00247241
Page 12 / 59
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 additionil
girls by offering to pay these victim-recruiters for every
additional girl they brought to EPSTEIN. When a victim-
recruiter accompanied a new minor victim to the New York
Residence, both the victim-recruiter and the new minor victim
were paid hundreds of dollars by EPSTEIN for each encounter. In
addition, certain victim-recruiters routinely scheduled these
5
EFTA00247242
Page 13 / 59
encounters through Employee-3., who sometimes asked the
recruiters tp bring a specific minor girl for EPSTEIN.
The Palm Beath 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 é nude ar.semi-nude massage for
EPSTEIN, who would himself typically be naked. During those
encounter's, 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 Victimre genitals. EPSTEIN would
also typically masturbate during these encounters, Ask victims
6
EFTA00247243
Page 14 / 59
to touch him while he masturbated, and touch Victims' genitals with his hands of with sex toys. • 16. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim-in cash. Victims typically were paid hundreds of dollars for each encounter. 17. JEFFREY EPSTEIN, the defendant, knew that certain of his victims were underage, including because certain victims told him their age. In additiOn, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, on multiple additional occasions. 18. JEFFREY EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for Employee-2 or other employees to contact victims by phone in advance-of EPETEXO's. travel to Florida to ensure appCintments 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. EFTA00247244
Page 15 / 59
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 (b). 21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a 8 EFTA00247245
Page 16 / 59
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 tim 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 EFTA00247246
Page 17 / 59
9 a telephone call to Minot 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 sexSots 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 Viotim-2 in order to schedule an appointment for Minor Victim-2 to engage in paid sex acts with EPSTEIN. f. In or about 2005, Mirior 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 Minot Victim-3 how old she was, and Minor Victim-3'answered truthfully. 10 EFTA00247247
Page 18 / 59
r1/2 • g. In or about 2005, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN. h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with' EPSTEIN. (Title 18, United States Code, Section 371.) . COUNT TWO (Sex Trafficking) The Grand Jury further charges: 23. The allegations contained in paragraphs'l through 19 and 22 of this Indictment are repeated and realleged as if fully set forth within. 24. from at least in or about 2002, up to. and including in or about 2005, in the Southern District of New York, JEFFREY EPSTEIN, the'defendAnt, willfully and knowingly, in and affecting interstate and foreign commerce, did recruit, entice, harbor, transport, provide, and obtain by any means a person, knowing that the person had not attained the•age of 18 years and would be caused to engage in a commercial sex act, and did aid and abet the same, to wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous 11 EFTA00247248
Page 19 / 59
individuals•whd were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York. (Title 18, United States Code, Sections 1591(a), (b)(2), and 2.) FORFEITURE ALLEGATIONS 25. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property: a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc. 12 EFTA00247249
Page 20 / 59
•. Substitute Asset Provision 26. If any of the above-described forfeitable property, as a result of any act or omission of. the defendant: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third person; (c) has been placed beyond the jurisdiction of the Court; (d), has been substantially diminished in value; or (e) has been commingled with other property which cannot be subdivided without difficulty; it is the intent of the United States, pursuant to 21 U.S.C. 853(p) and 28 U.S.C. S 2461(c), to seek forfeitgre 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.) 4, lu GEOFFR_TY S. BERMAN United states Attorney 13 EFTA00247250
Pages 1–20
/ 59