📄 Extracted Text (13,739 words)
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
• 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
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.
Federal Bureau of Investigation
Sworn to before me on
Septe ern, 2019
S L. COTT
STATES MAGISTRATE JUDGE
23
2017.08.02
EFTA00247233
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
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
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
EXHIBIT A
2017.08.02
EFTA00247237
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
SEALED
UNITED'STATES OF AMERICA INDICTMENT
19 Cr.
JEFFREY EPSTEIN,
Defendant.
CRIM 490 '
x
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
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
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
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
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
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
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
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
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
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
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
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
•.
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
Form No. USA-33s-274 (Ed. 9- 25-58)
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
UNITED STATES OF AMERICA
v.
JEFFREY EPSTEIN,
Defendant.
'INDICTMENT
(18 U.S.C. S§ 371, 1591(a), (b)(2),
and 2)
GEOFFREY S. BERMAN
rney
Forepe on
14.
EFTA00247251
EXHIBIT B
201748.02
EFTA00247252
AO 93 (SONY Rev. 01/17) Search and Seizure Warreot
UNITED STATES DISTRICT COURT
for the
Southern District ofNew York
In the Matter ofthe Search of
(Briefly describe the property to be searched
or identify theperson byname and address) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
• To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
(Identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (ian* the person or describe the property
to be settee): .
See Attachment A
The search and seizure are related to violation(s) of (insertstatutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the perion or
prupertY.
YOU ARE COMMANDED to execute this warrant on or before .1- • #1-0
(not to tweed 14 days)
go
in the daytime 6:00 a.m. to 10 p.m. O at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court
0 Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court
USWbraids
O I find that immediate notificationmay have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box) Ofor days (not to exceed 30).
°until, the facts justifying, e specific date of
Date and time issued: lr - 6. 6 1 to.vst ek. iA •
' Judge's signature
City and state: New York NY Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00247253
AO 93 (SDNY Rev. 01/17) Search and Seizure %mut (Par 2)
Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
•
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court
Date:
Executing officer's signature
Printedname and title
EFTA00247254
ATTACHMENT A
I. Premises to be Searched—Subject Premises
1. 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:
H. 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 cecupant(s).
b. Evidence concerning the layout, furnishings, decorations, and floor pattern of
the Subject Premises, including photographs and blueprints of the Subject
Premises.
2)17 08.02
EFTA00247255
EXHIBIT C
EFTA00247256
•
AO Oh (SONY lin C I/I ')Starch and Scturt Wiarno
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
To: Arty authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
(identify the person or describe the property to be searchedand gibe its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal tdenn)5. the person or describe the Properly
:o he seneeh:
See Attachment A
The search and seizure are related to violation(s) of /insert SI311d017 CII 0110/2S).
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit' s). or any recorded testimony. establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before July 7, 2019
Inot to exceed i4 cklys)
O in the daytime 6:00 a.m. to 10 p.m. 2( at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises. the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
o Upon its return, this warrant and inventory should be tiled under seal by the Clerk of the Court.
USA!) Initials
O I find that immediate notification may have an adverse result listed in IS 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 boy) Ofor days (not to exceed 30)
Ountil, the facts justify' later specific date
Date and time issued: - let c-5-Aa.ti
Judge's eignaure
City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge
Printed name and title
EFTA00247257
AO93 (SDNY Rcr. 01117)Scatch and Sc ware Warrant (Page 2i
Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:
Inventory made in the presence of:
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date: ___
Executing officer's signature
hinted name and title
EFTA00247258
ATTACHMENT A
I. Premises to be Searched—Subject Premises
I. The premises to be searched (the "Subject Premises") are 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. A photograph of the front entrance to the Subject Premises
is included below:
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title IS. United States Code, Sections 1591 (sex trafficking of minors) and 371
(scx trafficking conspiracy) (the "Subject Offenses") described as follows:
i. Any and all taxidermied dogs.
ii. Any and all massage tables and massage paraphernalia.
iii. Any and all busts or three-dimensional representations of female human
torsos.
iv. Any and all photos or representations depicting nude or partially nude
women located in the Massage Room, as defined herein.
v. Any and all sex toys and sex paraphernalia located in the Massage
Room, as defined herein.
EFTA00247259
vi. A binder labeled "PB Girls" and any other documents or
communications with or regarding victims or potential victims of the
Subject Offenses.
2
2017.0t02
EFTA00247260
EXHIBIT D
2017.08.02
EFTA00247261
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
or identify thetheperson by name and address) Case No.
See Attachment A
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
(identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) ofNun statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before July 21, 2019
(not to exceed 14 days)
O in the daytime 6:00 a.m. to 10 p.m. le at any time in the day or night as I find reasonable cause has been
established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
O Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
• USW Initials
O I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched Of seized (check the appropriate box) Ofor days (not to exceed 30).
Ountil, die facts justifying, the later specific date of
Date and time issued: 14'R
s
ℹ️ Document Details
SHA-256
47306f268b29886abce75110d05793d146955a8ccfa3004396ea8105ccfd1b03
Bates Number
EFTA00247231
Dataset
DataSet-9
Document Type
document
Pages
59
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