EFTA00171911.pdf

AO 106 (SDNY Rev. 01/17) Applictejon %r a Search Warrant UNITED STAPES DISTRICT COURT for the kA In the Matter of the Search of (Briefly describe :improperly to be searched or identify the person ,b,y name and addreis) 1 tt-i Case No. - c MPGy ITh --1 A blur.IP ivn t t-4/01 ifila 14°•SSMICAS sa).-Its po slluts 1'94 LAI, se-EW Na.Sr& ¶Alliwit\ to\ Spe,,Igh ik,4 k4.11.\ ihakme le 91.E fti: taa,Gt.‘3y,Gras;‘,4 bairolt,-, `eozAs soul 66 at 17.-.44666_ istritt ei-, aPs, &tut, fW, N tlittej 1141/4re ra) a) tittle Irod isiki MA, fivr• th klegzsocse; I, c4, sem . r Akk ,, it ifilLIcf%TaTfity.414,k SEARCH. AND SEIZURE, WARRANT U.. a its sea& t.utgi (nAp,z I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under penalty of perjury that I have reason to believe that on the following person or property (idennfr the person or describe the property to be searched and give its location): located in the .(Sbletall District of Ne-AA) y O( _ , there is now concealed (identify the person or describe the property to be seized): See Attached Affidavit and its Attachment A The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): irevidence of a crime; O contraband, fruits of crime, or other items illegally possessed; 0 'property designed for use, intended for use, or used in committing a crime; O a person to be arrested or a person who is unlawfully restrained. The search is related to a violation of: Code Section(s) Offense Description(s) 18 USC 1511 + 311 a- 4 il r itg1tiart OC minors sex 'ir &fel' n3 Conspiracy The application is based on these facts: See Attached Affidavit and its Attachment A tic Continued on the attached sheet. O Delayed notice of 30 days (give exact ending date if more than 30 days: ) is requested under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. Sworn to before me and signed in my presence. Date: Jul_ 1 5 2019 .001.041,e9tk- Judge's signature City and state: New York, NY HON. KEVIN NATHANIEL rox UsPed Otehesitesiiistrataislul:o —1 - Southern District of Now York U8AO 004321 EFTA_00022231 EFTA00171911  r% \ il l-- All el* ot: UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK In the Matter of the Application of the United TO BE FILED UNDER SEAL States Of America for a Search and Seizure Warrant for (1) a black iPhone with IMEI number Agent Affidavit in Support of 357201093322785, (2) a silver iPad with serial Application for Search and Seizure number DLXQGM3KGMW3, (3) two black Warrant binders with CDs, (4) two black hard drives, (5) a box of CDs, and (6) two binders with various CDs SOUTHERN DISTRICT OF NEW YORK) ss.: being duly sworn, deposes and says: I. Introduction A. Affiant I. I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since 2017. As such, I am a "federal law enforcement officer" within the meaning of Federal Rule of Criminal Procedure 41(a)(2XC), that is, a government agent engaged in enforcing the criminal laws and duly authorized by the Attorney General to request a search warrant. I am currently assigned to investigate violations of criminal law relating to the sexual exploitation of children. As part of my responsibilities, I have participated in numerous investigations and prosecutions of crimes against children, including the sex trafficking of minors, and have participated in the execution of search warrants involving electronic evidence. 2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal Rules of Criminal Procedure for a warrant to search certain electronic devices, compact disks and related electronic media specified below (the "Subject Items') for the items and information described in Attachment A. This affidavit is based upon my personal knowledge; my review of documents and other evidence; my conversations with other law enforcement personnel; and my I 2017.08.02 USAO_004322 EFTA_00022232 EFTA00171912 training, experience and advice received concerning the use of computers in criminal activity and the forensic analysis of electronically stored information (`BSI"). Because this affidavit is being submitted for the limited purpose of establishing probable cause, it does not include all the facts that I have learned during the course of my investigation. Where the contents of documents and the actions, statements, and conversations of others are reported herein, they are reported in substance and in part, except where otherwise indicated. B. The Subject Items 3. The Subject Items are particularly described as follows': A black iPhone with IMEI number 357201093322785, which was seized . from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-1"). b. A silver iPad with serial number DLXQGM3KGMW3, which was seized from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-2"). c. Two black binders with CDs, which were about July 11, 2019 ("Subject Item-3"). d. Two black hard drives, which were seizedkfrom a blue suitcase on or about July 11, 2019 ("Subject Item-4"). e. A box of CDs, which was seized from a blue suitcase on or about July 11 2019 ("Subject Item-5"). f. Two binders with various CDs, which were se' from a black suitcase on or about July 11, 2019 ("Subject Item-6"). 1 To the extent that the Subject Items contain any SD cards or other removable storage media, the description of each such item encompasses those SD cards and other media. 2 2017.08.02 USAO_004323 EFTA_00022233 EFTA00171913  4. Based on my training, experience, and research, I know that Subject Item-1 and Subject Item-2 both have capabilities that allow them to serve as a wireless telephone, digital camera, portable media player, OPS navigation device, and PDA. 5. The Subject Items are all presently lonted in the Southern District of New York. C. The Target Subject and the Subject Offenses 6. The Target Subject of this investigation is JEFFREY EPSTEIN. 7. For the reasons detailed below, I respectfully submit that there is probable cause to believe that the Subject Items contain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject. II. Probable Cause A. Probable Cause Regarding the Target Subject's Commission of the Subject Offenses 8. On or about July 2, 2019, a grand jury in this District returned an Indictment charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached hereto as Exhibit A and is incorporated by reference. 9. That same day, the Honorable Barbara Moses, United States Magistrate Judge, signed an arrest warrant for JEFFREY EPSTEIN. A copy of the Arrest Warrant is attached hereto as Exhibit B and is incorporated by reference. B. Probable Cause Justifying Search of the Subject Items The Indictment and Victim-1 10. As set forth in Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN sexually abused multiple minor girls in the Southern District of NeW York and elsewhere. During that time and continuing to the present, EPSTEIN 2017.08.02 USAO_004324 EFTA_00022234 EFTA00171914  possessed and controlled a multi-story, single-family residence located at 9 East 71st Street, New York, New York, which is described in Exhibit A as "the New York Residence." 11. As further set forth in paragraphs 8 through 10 of Exhibit A, from at least in or about 2002, up to and including at least in or about 2005, EPSTEIN sexually abused numerous minor victims at the New York Residence. In particular, and as alleged in the Indictment, when a victim arrived at the New York Residence, she would be escorted to a room inside the Subject Premises with a massage table, where she would perform a massage on EPSTEIN. The victims, who were as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and scope of physical contact with his victim to include, among other things, sex acts such as groping and direct and indirect contact with the victims' genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims to touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. Following each encounter, EPSTEIN or one of his employees or associates paid the victim in cash. 12. As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to recruit additional minor girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victim- recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were underage, including because certain victims told him their age. 13. One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of the FBI's investigation of EPSTEIN, other law enforcement officers and I have interviewed 4 2017.08.02 USAO_004325 EFTA_00022235 EFTA00171915 Victim-1. 2 During those interviews, Victim-1 has provided the following information, in substance and in part: a. Between approximately 2002 and 2005, EPSTEIN sexually abused Victim-1 on multiple occasions in the New York Residence. This sexual abuse all occurred when Victim-1 was under the age of 18. The July 6. 2019 Seizure of Subject Item-1 and Subiect Item-2 14. I know from my personal participation in this investigation and my conversations with other law enforcement agents that on July 6, 2019, JEFFREY EPSTEIN was aboard a private Iscct jet that flew from France and landed at approximately 5:30 ■ in Teterboro Airport in Bergen4lit New Jersey. Upon his arrival at Teterboro Airport, and as part of his re-entry into the United States, EPSTEIN was searched by agents of U.S. Customs and Border Protection ("CBP"), who found both Subject Item-1 and Subject Item-2 in EPSTEIN's possession. The CBP agents then provided Subject Item-1 and Subject Item-2 to Special Agents of the FBI who also placed EPSTEIN under arrest. The FBI subsequently transported Subject Item-1 and Subject Item-2 to FBI offices located in the Southern District of New York, where they are currently located. 2 In meetin with the Govemmen Victim-1 has disclosed She SO C OS Victim-1 has also disclosed Victim-1 Information prom .y proven re a e an n corro .y epcn• ent evidence, including documents and records obtained during the investigation and the accounts of other victims whom Victim-1 has never met. 5 2017.08.02 USAO_004326 EFTA_00022236 EFTA00171916  The July 6. 2019 and July 7, 2019 Search Warrants for the New York Residence 15. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the New York Residence. The search warrant is attached as Exhibit C and incorporated by reference herein. 16. At approximately 6 ■. on or about July 6, 2019, law enforcement officers (the "Search Team") commenced executing the search warrant at the New York Residence. 17. Based on the Search Team's observations during an initial search of the New York Residence, at approximately 7M., the Search Team stopped the search and froze the scene in order to seek a new search warrant. 18. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a second search warrant authorizing a search of the New York Residence (the "Second Warrant"). The Second Warrant is attached as Exhibit D, and incorporated by reference herein. At approximately 2:30 II., the Search Team resumed the search, and commenced searching pursuant to the Second Warrant 19. Based on my conversations with members of the Search Team, I have learned the following: a. The Search Team observed a number of computing devices, including computers and tablet devices, throughout the New York Residence. b. Inside a safe in a closet on the third floor (the "Safe"), the Search Team discovered and seized, among other items, several binders containing sleeves of compact discs, most of which are labeled with handwriting. In total, the binders contain dozens of compact discs. One disc is labeled Another disc is labeled "Nudes 00-24." Another is labeled "Misc. Nudes." Yet another is labeled "Girl Pies Nude." Some discs contain the word 6 2017.08.02 USAO_004327 EFTA_00022237 EFTA00171917  "Zorro" or "LSJ." For example, one disc is marked "Dana Zorro Pics." Based on my conversations with law enforcement agents who have participated in this investigation, I believe the name "Zorro" refers to Zorro Ranch, EPSTEIN's property in New Mexico, and the name LSJ refers to Little Saint James, EPSTEIN's property in the U.S. Virgin Islands. The majority of the discs contain titles that include female names. Some of the discs in the binders seized by the Search Team have titles that appear to refer to trips or vacations. c. During the search, the Search Team did not seize at that time certain binders of discs located in the Safe, where the majority of the discs in the binder were labeled in a manner that did not appear to refer to girls or nudes. The Search Team also did not seize at that time several unlabeled hard drives, which were also located in the Safe. As detailed below, those additional binders of discs are among the subjects of this application. d. In addition to the Safe, in the drawer of a dresser in a room on the Fifth floor of the New York Residence, the Search team discovered and seized, among other items, a shoebox (the "Shoebox") which contained numerous compact discs. The majority of the discs are labeled, in handwriting, with female names. One disc is labeled "Thai Massage." Another disc is labeled "Blonde Girl Photo Shoot." Yet another disc is labeled "Misc. Girls Nude/Dinner—Scientists." The discs in the Shoebox were seized by the Search Team. In another drawer of that same dresser, the Search Team discovered loose polaroid photographs depicting young, nude females who, based on the training and experience of law enforcement officers who observed them, appear to be teenagers. In that same drawer, the Search Team discovered a folder marked, in handwriting, =which contained photographs, including nude and sexually suggestive photographi of a young girl who, based on the training and experience of law enforcement officers who observed them, appears to be younger than 18. The folder also contained other nude photographs of young 7 2017.08.02 USAO_004328 EFTA_00022238 EFTA00171918 girls who appear to be teenagers, based on my training and experience. Inside the folder is a compact disc marked Mat L.TS 6/03" (the Wise"), which was seized by the Search Team. e. In a closet on the Fifth Floor of the New York Residence, the Search Team discovered, among othcr items, a box marked "women/old photos." The box contained, among other items, approximately seven compact discs, which are labeled with hand-written titles. One disc is labeled "nudes 00-24." Another is labeled "Photographer-Ell `03" The remaining discs contain tiles that include female names. All of the foregoing discs were seized by the Search Team. f. In that same closet, the Search Team discovered numerous black binders containing what appear to be print outs of digital photographs (with file names underneath) and compact discs. The Search Team seized approximately ten binders (the "Seized Binders")3 which appeared to contain, among other photographs, photographs of nude or partially nude young girls, some of which are in sexually suggestive poses. Based on the training and experience of law enforcement officers who observed them, at least some of the young girls depicted in the photographs appear to be teenagers, including some who appear to be under the age of 18. The Seized Binders also include photographs of what appear to be personal functions, events, and travel. g. The compact discs seized by the Search Team and described in paragraphs are currently stored within the Southern District of New York in containers marked for identification with FBI evidence numbers 15, 16, 17, 18, and 22 (the "Seized Discs"). The July 7, 2019 Search Warrant for the Seized Discs 20. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a third search warrant to search and seize electronic media stored on the Seized Discs 3 The Search Team did not seize the remaining binders. 2017.08.02 USAO_004329 EFTA_00022239 EFTA00171919 (the "Third Search Warrant"). The Third Warrant is attached as Exhibit E, and incorporated by reference herein. 21. Based on my conversations with law enforcement agents who have reviewed the Seized Discs pursuant to the Third Search Warrant (the "Reviewing Agents"), I have learned the following: a. The discs contain approximately thousands of nude or partially nude photographs of girls or young women, many of which are in sexually suggestive poses. Based on my conversations with the Reviewing Agents, who have particular training and experience relating to child erotica and visual depictions of children in child exploitation cases, I have learned that the Reviewing Agents believe that many of the nude or partially nude images they have reviewed appear to depict girls under the age of 18. Moreover, many of the photographs appear to be labeled with file names that suggest the photographs depict these girls at properties associated with JEFFREY EPSTEIN. For example, some file names are labeled "Zorro" or "LSJ." b. 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-I 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. The July 11, 2019 Search Warrant for All Electronic Devices and Storage Media in the New York Residence 22. Following the initiation of the FBI's review of the Seized Discs, on or about July 11, 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 2017.08.02 USAO_004330 EFTA_00022240 EFTA00171920 seizure and search of electronic devices and storage media inside the New York Residence (the "Fourth Warrant"). The Fourth Warrant is attached as Exhibit F and incorporated by reference herein. 23. Later on July 11, 2019, the Search Team executed the Fourth Warrant at the New York Residence. 24. Based on my conversations with members of the Search Team, I have learned the following, among other things, regarding the execution of the Fourth Warrant: a. During the July 11, 2019 execution of the Fourth 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 paragraph 19b, above, that the Search Team had not seized during its prior search of the New York Residence on July 7, 2019, had been removed. 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 10 2017.08.02 USAO_004331 EFTA_00022241 EFTA00171921  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 Sf.e3. .sc tritess•with the two suitcases described above, one of which was blue and one of which was black. 0\ onsistent with standard law enforcement protocol, the Search.Team conducted an inventory of th suitcases before taking custody of them. While taking an inventory of the blue suitcase, the Search Team discovered, among other items, Subject Item-3, Subject Item-4, and Subject Item-5. While taking an inventory of the black suitcase, the Search Team discovered, among other items, Subject Item-6. These items, i.e., Subject Items -3, -4, -5, and -6, 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. The 2018 Payments 25. Based on my participation in this investigation, my review of open source materials, and my review of financial records, I have further learned the following: a. On or about November 28, 2018, the Miami Herald began publishing a series of articles related to JEFFREY EPSTEIN, his sex trafficking of minor girls, and the circumstances of a non-prosecution agreement ("NPA") he previously negotiated with the Southern District of Florida. Among other things, the NPA identified several individuals as EPSTEIN's co-conspirators in the sex trafficking of minor girls. b. Records obtained by the Government from a financial institution ("Institution-1") appear to show that just two days after the Miami Herald began publishing its series, on or about November 30, 2018, the defendant wired $100,000 from a trust account he 11 2017.08.02 USA0_004332 EFTA_00022242 EFTA00171922 controlled to an individual named as a possible co-conspirator in the NPA. The same records from Institution-1 appear to show that just three days after that, on or about December 3, 2018, the defendant wired $250,000 from the same trust account to another individual named as a possible co-conspirator in the NPA and also identified as one of the defendant's employees in the Indictment. Neither of these payments appears to be recurring or repeating during the approximately five years of bank records presently available. c. This course of action, and in particular its timing, suggests the defendant was still in communication with and attempting to further influence co-conspirators who might provide information against him in light of the recently re-emerging allegations. Request to Search the Subiect Items 26. Based on my training and experience and participation in this investigation, I respectfully submit that there is probable cause to believe that the Subject Items will contain and/or constitute additional fruits, evidence and instrumentalities of the Subject Offenses. As an initial matter, all of the Subject Items were initially found in the same Safe in which EPSTEIN was storing discs and other media already reviewed and which contain hundreds of not thousands of nude and suggestive images of young females, some of whom appear to be under 18. Given as much, and because there is probable cause to believe that Epstein engaged in sex trafficking of underage girls, there is probable cause to believe that the additional storage media in EPSTEIN's possession and control—Le., the Subject Items—will contain evidence of the Subject Offenses. Moreover, that efforts were made to remove Subject Items -3, -4, -5, and -6 from the New York Residence after the initial search only further reinforces the probable cause to believe that those Subject Items contain and constitute fruits, evidence and instrumentalities of the Subject Offenses. 12 2017.08.02 USAO_004333 EFTA_00022243 EFTA00171923  27. With respect to Subject Item-1 and Subject Item-2, both are electronic devices capable of sending, receiving, and containing thousands of messages and images. Based on my training and experience, I am aware that individuals who store nude and/or sexually suggestive photographs of minors on compact discs or other external storage devices typically annws those images from computers and other electronic devices in order to view those images, and individuals who store such materials on compact discs typically store similar files on other computing devices and storage devices like Subject Item-1 and Subject Item-2. Further, in light of the payments to potential co-conspirators described in paragraph 25, above, I respectfully submit there is probable cause to believe that EPSTEIN still communicates with at least some of his co-conspirators about the Subject Offenses and that such communications may occur using Subject Item-1 and Subject Item-2. 28. I further know from my training and experience that 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 Items. Even when such files have been deleted, they can often be recovered, depending on how the device has subsequently been used, months or years later with forensics tools. Thus, the ability to retrieve from information from the Subject Items depends less on when the information was first created or saved than on a particular user's device configuration, storage capacity, and computer habits. 29. Based on the foregoing, I respectfully submit there is probable cause to believe that evidence of JEFFREY EPSTEIN's commission of the Subject Offences is likely to be found on the Subject steins.. 13 • 2017.08.02 USAO_004334 EFTA_00022244 EFTA00171924 IR. Procedures for Searching ESI A. Review of ESI `' 30. 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 Items for information responsive to the warrant 31. 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); • conducting a file-by-file review by "opening" or reading the first few "pages" of such files in order to determine their precise contents (analogous to performing a cursory examination of each document in a file cabinet to determine its relevance); • "scanning" storage areas to discover and possibly recover recently deleted data or deliberately hidden files; and • performing electronic keyword searches through all electronic storage areas to determine the existence and location of data potentially related to the subject matter of the investigation's; and • reviewing metadata, system information, configuration files, registry data, and any other information reflecting how, when, and by whom the computer was used. Keyword searches alone are typically inadequate to detect all relevant data. 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. 14 2017.08.02 USAO_004335 EFTA_00022245 EFTA00171925  32. Law enforcement personnel will make reasonable efforts to restrict their search to data falling within the categories of evidence specified in the warrant. Depending on the circumstances, however, law enforcement may need to conduct a complete review of all the ESI from the Subject Items to evaluate its contents and to locate all data responsive to the warrant. B. Return of the Subject Items 33. If the Government determines that•the Subject Items are no longer necessary to retrieve and preserve the data on the Subject Items, and that the Subject Items are not subject to seizure pursuant to F ule of Criminal Procedure 41(c), the Government will return the Subject Items,, 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. 15 2017.08.02 USAO_004336 EFTA_00022246 EFTA00171926 IV. Conclusion and Ancillary Provisions 34. 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. 35. 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. pecialP,gen • Federal Bureau of Investigation Sworn to before me on . 1 5 20191 July IS• 2019 HON., KEVIN NATHANIEL FOX STATES lvLAGISTRATE JUDGE 16 2017.08.02 USAO 004337 EFTA_00022247 EFTA00171927  Attachment A I. Items Subject to Search and Seizure The Subject Items are particularly described as follows': • A black iPhone with IMEI number 357201093322785, which was seized from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-1"). • A silver iPad with serial number DLXQGM3KOMW3, which was seized from JEFFREY EPSTEIN on or about July 6, 2019 ("Subject Item-2"). • Two black binders with CDs, which were seizedkom a blue sur July 11, 2019 ("Subject Item-3"). r kk‘ Adj • Two black hard drives, which were from a b ue suitcase on or about July 11 2019 ("Subject Item-4"). ' k)v,\ Soc-C-Itt4 /ben • A box of CDs, which was seizedkom a blue suite ("Subject Item-5'). \It* Two binders with various CDs, which were seized • a black suitcase on or a out July 11, 2019 ("Subject Item-6"): 13 5re.c14/ 1 IL Review of ESI on the Subject Items 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 Items 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. Any documents or communications with or regarding victims or potential victims of the Subject Offenses; 2. Any photographs of victims or potential victims of the Subject Offenses; 3. Any nude, partially nude, or sexually suggestive photographs of individuals who appear to be teenage girls, or younger; 4. Records, data, or other items that evidence ownership, control, or use of, or access to the Subject Items, including, but not limited to access history data, historical location data, To the extent that the Subject Items contain any SD cards or other removable storage media, the description of each such item encompasses those SD cards and other media. 2017.08.02 USAO_004338 EFTA_00022248 EFTA00171928 configuration files, saved usernames and passwords, user profiles, e-mail contacts, and photographs; 5. 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). As to Subject Item-1 and Subject Item-2, 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 further authorized to review the EST contained on Subject Item-1 and Subject Item-2 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. Any documents or communications with or regarding co-conspirators in the Subject Offenses. In conducting this review, law enforcement personnel may use various techniques to determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such techniques may include, for example: • surveying directories or folders and the individual files they contain (analogous to looking at the outside of a file cabinet for the markings it contains and opening a drawer believed to contain pertinent files); • conducting a file-by-file review by "opening" or reading the first few "pages" of such files in order to determine their precise contents (analogous to performing a cursory examination of each document in a file cabinet to determine its relevance); • "scanning" storage areas to discover and possibly recover recently deleted data or deliberately hidden files; and • performing electronic keyword searches through all electronic storage areas to determine the existence and location of data potentially related to the subject matter of the investigation; and • reviewing metarlfirn, system information, configuration files, registry data, and any other information reflecting how, when, and by whom the computer was used. Law enforcement personnel will make reasonable efforts to search only for files, documents, or other electronically stored information within the categories identified in Section II of this Attachment. However, law enforcement personnel are authorized to conduct a complete review of all the PSI from seized devices or storage media if necessary to evaluate its contents and to locate all data responsive to the warrant. 2 2017.08.02 USAO_004339 EFTA_00022249 EFTA00171929  EXHIBIT A .17.08.02 USAO_004340 EFTA_00022250 EFTA00171930 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x SEALED UNITED. STATES OF AMERICA INDICTMENT 19 Cr. JEFFREY EPSTEIN, Defendant. 19 CREW 4910 x COUNT ONE (Sex Trafficking Conspiraby) The Grand Jury charges: OVERVIEW 1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and• abused dozens of minor girls at his homes in Manhattan, New York, and Palm Beach, Florida, among other locations. 2. In particular, from at least in or about 2002, up to and including at least in or about 2005, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and recruited, minor girls to visit his mansion in Manhattan, New York (the "New York Residence") and his estate in Palm Beach, Florida (the "Palm Beach Residence") to engage in sex acts with him, after which he would give the victims hundreds of dollars in cash. Moreover, and in order to maintain and increase his supply of victims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly abused by EPSTEIN. In USAO 004341 EFTA_00022251 EFTA00171931  ork of underage victims for this way, EPSTEIN created a vast netw including New York and him to sexually exploit in. locations Palm Beach. g as 14 3. The victims described herein were as youn JEFFREY EPSTEIN, the years old at the time they were abused by ons, often particularly defendant, and were, for various reas vulnerable to exploitation. EPSTEIN intentionally sought out were in fact under the minors and knew that many of his victims instances, minor victims age of 18, including because, in some expressly told him their age. • of mino r 4. In creating and maintaining this network abuse and exploit, victims in multiple states to sexually and conspired with, JEFFREY EPSTEIN, the defendant, worked es who facilitated his others, including employees and associat ng victims and conduct by, among other things, contacti EPSTEIN at the New York scheduling their sexual encounters with e. Residence and at the Palm Beach Residenc FACTUAL BACKGROUND 5. During all time periods charged in this ndant, was a financier with Indictment, JEFFREY EPSTEIN, the defe