EFTA01262965.pdf

AO 106 (SONY Rev. 01/17) Application for a Starch Warrant UNITED STATES DISTRICT COURT for the Southern District of New Yol MAU 8 5 7 8 In the Matter of the Search of (Briefly describe the property to be searched or Wntiog the person by name andaddress) Case No. Six binders with various CDs APPLICATION FOR A SEARCH AND SEIZURE WARRANT 1, 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 °den* the person or describe the property to be searched andgive its location): located in the Southern District of New York , there is now concealed Nen* the person or describe the property to be seize42: See Attached Affidavit and its Attachment A The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): X Cl evidence of a crime; O contraband, fruits of crime, or other items illegally possessed; O 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 1591 Sex Trafficking of Minors 18 USC 371 Sex Trafficking Conspiracy The application is based on these facts: See Attached Affidavit and its Attachment A Continued.on the attached sheet Cl 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 theattached skeet) fr e ApptIUMIS ngticersoe Task Force Officer FBI Primed name and title Sworn to before me and signed in my presence. Date: Juagessignalure City and state: New York, NY Hon. Cott, United States Magistrate Judge Printedname and We SDNY_GM_00000295 CONFIDENTIAL EFTA_00114379 EFTA01262965  .1.9.MAG 8578 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 six binders with various CDs Agent Affidavit in Support of Application for Search and Seizure Warrant SOUTHERN DISTRICT OF NEW YORK) ss.: MI= being duly sworn, deposes and says: I. Introduction A. Affiant 1. I have been a Task Force Officer with the Federal Bureau of Investigation ("FBI") since 2017. As such, I am a "federal law enforcement office?' within the meaning of Federal Rule of Criminal Procedure 41(aX2)(C), that is, a government agent engaged in enforcing the criminal laws and duly authorized by the Attorney General to request a search warrant. I am also a detective with the New York Police Department rNYPD") and have been employed by the NYPD for approximately thirteen years. I am currently assigned to investigate violations of criminal law relating to the sexual exploitation of children as part of an FBI Task Force. I have gained expertise in this area through classroom training and daily work related to these types of investigations. As part of my responsibilities, I have been involved in the investigation of sex trafficking cases, and have participated in the execution of search warrants for electronic devices and electronic storage media. 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 I 2017.08.02 SONY_GM_000002.96 CONFIDENTIAL EFTA_00114380 EFTA01262966 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 training, experience and advice received concerning the use of computers in criminal activity and the forensic analysis of electronically stored information ("ESP"). 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 pad, except where otherwise indicated. B. The Subject Items 3. The Subject Items are particularly described as follows': a. Two blue binders with CDs, which were seized by Special Agent. from a blue suitcase on or about July 11, 2019 ("Subject Item-1"). b. Three blue binders with various CDs and one clear binder with a green spine with various CDs, all four of which were seized by Special Agent from a black suitcase on or about July 11, 2019 ("Subject Item-2"). 4. The Subject Items are all presently located in the Southern District of New York. C. The Target Subjects and the Subject Offenses 5. For the reasons detailed below, I believe that there is probable cause to believe that the Subject Device contains evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the " To the extent that the Subject Items contain any removable storage media, including CDs, the description of each such item encompasses those other media. 2 2017.08.02 SDNY_GM_00000297 CONFIDENTIAL EFTA_00114381 EFTA01262967 "Subject Offenses"). The Target Subjects of this investigation are known and unknown co- conspirators of JEFFREY EPSTEIN, including but not limited to IL Probable Cause A. Probable Cause Regarding the Commission of the Subject Offenses 6. On or about July 2, 2019, a grand jury in this District returned an Indictment charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached hereto as Exhibit A and is incorporated by reference. EPSTEIN was arrested pursuant to the Indictment on or about July. 6, 2019, and had been detained pending trial at the Metropolitan Correctional Center ("MCC") in New York, New York. 7. On or about August 10, 2019, the Bureau of Prisons confirmed that JEFFREY EPSTEIN had been found unresponsive in his cell at the MCC that morning, and was pronounced dead shortly thereafter. 8. Notwithstanding EPSTEIN's death, the sex trafficking investigation that led to his indictment remains ongoing. In particular, Count One of the Indictment alleged that EPSTEIN conspired with others to traffic minors, and further identified three individuals who worked for EPSTEIN (identified in Exhibit A as "Employee-1", "Employee-2," and "Employee-3") and facilitated EPSTEIN's abuse of minor girls by, among other things, arranging victims' encounters with EPSTEIN and paying victims after these encounters. The individual identified in Exhibit A as "Employee-2" is a Target Subject of this investigation. 9. On or about November 28, 2018, the Miami Herald began publishing a series of articles relating to the defendant, his sexual misconduct with minors, and a previous investigation into his conduct in Florida from in or about 2005 through 2008. The article included information about s role in EPSTEIN's sexual abuse of minors. Based on my participation in this investigation, I have learned that bank records obtained by the Government appear to show 3 2017.08.02 SDNY_GM_00000298 CONFIDENTIAL EFTA_00114382 EFTA01262968 that just days later, on or about December 3, 2018, the defendant wired $250,000 from a trust account to MM. This course of action, and in particular its timing, suggests that EPSTEIN was attempting to influence IIME, who might have been able to provide information against him in light of the recently re-emerging allegations. 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 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. 4 2017.08.02 SDNY_GM_00000299 CONFIDENTIAL EFTA_00114383 EFTA01262969  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-I. As part of the FBI's investigation of EPSTEIN, other law enforcement officers and I have interviewed Victim-1.2 During those interviews, Victim-1 has said, in substance and in part, that EPSTEIN sexually abused Victim-1 on multiple occasions between approximately 2002 and 2005 in the New York Residence. This sexual abuse all occurred when Victim-I was under the age of 18. The July 6.2019 and July 7. 2019 Search Warrants for the New York Residence 14. 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 B and incorporated by reference herein. 15. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the "Search Team") commenced executing the search warrant at the New York Residence. 2 1n meetings with the Govenunent, Victim-1 has disclosed that, approximately a decade ago, she committed marriage fraud in order to obtain a green card and, subsequently, U.S. citizenship. She has also disclosed personal substance abuse, primarily involving the abuse of prescription drugs, during various periods between the early 2000s and 2019. Victim-1 has also disclosed having worked for approximately a year at a "happy-ending" massage parlor, performing paid sex acts. Victim-1 is currently pursuing a civil damages claim against EPSTEIN for his sexual abuse of her. Information provided by Victim-1 has proven reliable and has been corroborated by independent evidence, including documents and records obtained during the investigation and the accounts of other victims whom Victim-1 has never met. 5 2017.08.02 SONY_GM_00000300 CONFIDENTIAL EFTA_00114384 EFTA01262970  16. Based on the Search Team's observations during an initial search of the New York Residence, at approximately 7 p.m., the Search Team stopped the search and froze the scene in order to seek a new search warrant. 17. 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 C, and incorporated by reference herein. At approximately 2:30 a.m., the Search Team resumed the search, and commenced searching pursuant to the Second Warrant. 18. 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 "Young— " Another disc is labeled "Nudes 00-24." Another is labeled "Misc. Nudes." Yet another is labeled "Girl Pics Nude." Some discs contain the word "Zorro" or "LSJ." For example, one disc is marked "M 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. 6 2017.08.02 SDNY_GM_00000301 CONFIDENTIAL EFTA_00114385 EFTA01262971  c. At the time of the search, the Search Team did not seize 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, .s" which contained photographs, including nude and sexually suggestive photographs 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 girls who appear to be teenagers, based on my training and experience. Inside the folder is a compact disc marked at US 6/03" (the Disc"), 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 other 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—_ `03" The remaining 7 2017.08.02 SONY GM_00000302 CONFIDENTIAL EFTA_00114386 EFTA01262972 discs contain titles that include female names. All of the foregoing discs were seized by the Search Team. £ 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 16(a)-(d) 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 19. 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 (the "Third Search Warrant"). The Third Warrant is attached as Exhibit D, and incorporated by reference herein. 20. 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: 3 The Search Team did not seize the remaining binders. 8 2017.08.02 SONY_GM_00000303 CONFIDENTIAL EFTA_00114387 EFTA01262973  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-I's counsel that Individual-1 recalls the month and year during which she believes those partially-nude photographs were taken, and also the location where they were taken, and that she was 17 years old at the time.' 21. In addition, I have learned that some of the file names are marked a which are the initials of As set forth below, I have interviewed an individual who has reported that photographed her. Accordingly, I believe that a portion of these photos may have been taken by A preliminary review of the metadata from these photographs has been inconclusive. In particular, some of the photographs of Individual-1 contain metadata suggesting the photographs were taken on a date when Individual-1 would have been 18 years old. Other photographs of Individual-1, which appear based on Individual-1's appearance and surroundings to have been taken around the same time, contain metadata suggesting the photographs were taken on a date when Individual-1 would have been 15 years old. 9 2017.08.02 SDNY_GM_00000304 CONFIDENTIAL EFTA_00114388 EFTA01262974  22. Among the photographs seized from the New York Residence, the Reviewing Agents identified partially-nude photographs of a young girl, labeled with the name of a particular individual ("Individual-1"). In or about August 2019, I participated in an interview of Individual- 1, with her counsel present. Based on my personal observations, I believe that the photographs described in Paragraph 20(b) depict Individual-1. 1 have also spoken with another law enforcement agent who interviewed Individual-I on a separate occasion in or about July 2019, with her counsel present. During the course of these interviews, Individual-1 stated, in sum an substance that she met EPSTEIN in 2003 when she was approximately 17, and that she travelled to several of EPSTEIN's properties before she turned 18. EPSTEIN paid for the trips, and would give Individual-1 money and gifts while she traveled with him. During these trips, EPSTEIN sexually abused and assaulted Individual-1 on approximately four different occasions, all of which occurred before she turned 18. Individual-1 reported that EPSTEIN raped her during two of these incidents. Individual-1 further reported that, when she was approximately 17, asked to photograph her, and did in fact photograph Individual-1. I e July 11. 2019 Search Warrant for All Electronic Devices and Storage Media in the New York Residence 23. 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 seizure and search of all electronic devices and storage media inside the New York Residence (the "Fourth Warrant"). The Fourth Warrant is attached as Exhibit E and incorporated by reference herein. 24. Later on July 1I, 2019, the Search Team executed the Fourth Warrant at the New York Residence. 10 2017.08.02 SONY_GM_00000305 CONFIDENTIAL EFTA_00114389 EFTA01262975  25. 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 16(b), 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 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 Special Agent with the two suitcases described above, one of which was blue and one of which was black. Consistent with standard law enforcement protocol, the Search Team 11 2017.08.02 SONY_GM_00000306 CONFIDENTIAL EFTA_00114390 EFTA01262976 conducted an inventory of both suitcases before taking custody of them. While taking an inventory of the blue suitcase, the Search Team discovered, among other items, Subject Item-1. While taking an inventory of the black suitcase, the Search Team discovered, among other items, Subject Item- 2. These items, i.e., Subject Items -1, and -2, 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 July 15, 2019 Search Warrant for Certain Items Located Inside the Blue and Black Suitcases 26. On or about July 15, 2019, the Honorable Kevin Nathaniel Fox, United States Magistrate Judge, signed a search warrant authorizing the search of several items, including items recovered from the black and blue suitcases seized by Special Agent on or about July 11, 2019 (the "Fifth Warrant"). The Fifth Warrant is attached as Exhibit F and incorporated by reference herein. 27. In support of the Government's requist for the Fifth Warrant, a Special Agent of the FBI submitted an affidavit in which she described some of the contents of the black and blue suitcases seized by Special Agent on or about July 11, 2019. Before submitting that affidavit, that agent had not personally reviewed the contents of those suitcases; rather, those descriptions were based on her conversations with other FBI agents who had seized the suitcases. Based on those conversations with other agents, she requested that the Fifth Warrant authorize the search of, among other items, (a) two black binders with CDs, which were seized by Special Agent from a blue suitcase on or about July 11, 2019, and (b) two binders with various CDs, which were seized by Special Agent from a black suitcase on or about July 11, 2019. The Fifth Warrant authorized the search of those specific items. 28. After the Fifth Warrant was issued, other law enforcement agents retrieved some of the items listed in the Fifth Warrant from the blue and black suitcases, which were and remain 12 2017.08.02 SDNY_GM_00000307 CONFIDENTIAL EFTA_00114391 EFTA01262977 in FBI custody in the Southern District of New York. Those other agents initiated searches of certain items inside the two suitcases, including of Subject Item-1. 29. Subsequently, I personally inspected the contents of these suitcases, and realized that there had been a misconummication about the color and quantity of the binders of CDs in each suitcase. In particular, the blue suitcase in fact contained two blue binders with CDs (defined herein as Subject Item-1), not two black binders. Additionally, the black suitcase in fact contained a total of four binders with CDs, three of which are blue and one of which is clear with a green spine, (defined herein as Subject Item-2), not two binders. 30. In light of these discrepancies, the FBI ceased its search of Subject Item-1 and never initiated a search of Subject Item-2. Accordingly, I now respectfully request a warrant authorizing a search of the binders that are in fact located inside the two suitcases, which have been identified as Subject Item-1 and Subject Item-2 herein. Ilecwest to Search the Subiect Items 31. 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 originally 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 and his co-conspirators, including 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 13 2017.08.02 SONY GM_00000308 CONFIDENTIAL EFTA_00114392 EFTA01262978 Subject Items -1 and -2 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. 32. 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. 33. 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 Items. III. Procedures for Searching ESI A. Review of ESI 34. 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. 35. 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: 14 2017.08.02 SONY_GM_00000309 CONFIDENTIAL EFTA_00114393 EFTA01262979  • 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 investigations; and • reviewing metadata, system information, configuration files, registry data, and any other information reflecting how, when, and by whom the computer was used. 36. 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 37. If the Government determines that the Subject Items are no longer necracary to retrieve and preserve the data on the Subject Items, and that the Subject Items are not subject to seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return the. Subject Items, 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 s 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. 15 2017.03.02 SONY_GM_00000310 CONFIDENTIAL EFTA_00114394 EFTA01262980 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 38. 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. 39. 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. Task Force Officer Federal Bureau of Investigation Sworn to before me on September 2019 16 • 2017.08.02 SONY_GM_00080311 CONFIDENTIAL EFTA_00114395 EFTA01262981  Attachment A L Items Subject to Search and Seizure The Subject Items are particularly described as follows: a. Two blue binders with CD; which were seized by Special Agent from a blue suitcase on or about July 11, 2019 ("Subject Item-I"). b. Three blue binders with various CDs and one clear binder with a green spine with various CDs, all four of which were seized by Special Agent from a black suitcase on or about July 11, 2019 ("Subject Item-2"). 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, configuration files, saved usernames and passwords, user profiles, e-mail contacts, and photographs; 5. My 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). To the extent that the Subject Items contain any removable storage media, including CDs, the description of each such item encompasses those other media. 2017.08.02 SDNY_GM_00000312 CONFIDENTIAL EFTA_00114396 EFTA01262982  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 metadata, 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 ESI 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 SDNY_GM_00000313 CONFIDENTIAL EFTA_00114397 EFTA01262983  EXHIBIT A CONFIDENTIAL EFTA,I16398 EFTA01262984  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x SEALED UNITED STATES OF AMERICA INDICTMENT 19 Cr. JEFFREY EPSTEIN, Defendant. 1.9 GRIM 490 x COUNT ONE (Sex Trafficking Conspiracy) The Grand Jury charges: OVERVIEW 1. As set forth herein, over the course of many years, JEFFREY EPSTEIN, the defendant, sexually exploited and . abused dozens .of .minor girli 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 SDNY_GM_00000315 CONFIDENTIAL EFTA_00114399 EFTA01262985  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