EFTA01262829.pdf

AO 106 (SDNY Rev. 01/17) Application for a Search Warrant UNITED STATES DISTRICT COURT for the Southern District of New York In the Matter of the Search of n7F An (Briefly describe the property to be searched or identify the person by name and address) See Attached Affidavit and its Attachment A )) ) ) Case °' 1 APPLICATION FOR A SEARCH AND SEIZURE WARRANT 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 (idewt& the person or describe the property to be searched and give its location): located in the Southern District of New York , there is now concealed (identify the person or describe the property to be seized): See Attached Affidavit and its Attachment A The bas„ s for the search under Fed. R. Crim. P. 41(c) is (check one or more): L ,:ontraband, fruits of crime, or other items illegally possessed; vidence of a crime; 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 U.S.C. §§ 1591 and Sex trafficking of minors; sex trafficking conspiracy 371 The application is based on these facts: See Attached Affidavit and its Attachment A Continued on the attached sheet. O Delayed notice of days (give exact ending date if more than 30 days: ) is requested under I8 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. dpplicant1 signature ____ Spec's! Agen .Print . Sworn to before me and signed in my presence. Date: 07/07/2019 Judge's signature City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judge Printed name and tide tt :2V ri k eEntalL4g000072 CONFID EFTA_00 114156 EFTA01262829 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 1 t.t--1110 3571 In the Matter of the Application of the United TO BE FILED UNDER SEAL States Of America for a Search and Seizure Warrant for Compact Discs marked with FBI Agent Affidavit in Support of evidence numbers 15, 16, 17, 18, and 22, Seized Application for Search and Seizure from 9 East 71" Street, New York, NY on or Warrant about July 7, 2019, and Any Files or Media Stored Therein SOUTHERN DISTRICT OF NEW YORK) ss.: being duly sworn, deposes and says: I. Introduction A. Affiant 1. I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since 2012. As such, I am a "federal law enforcement officer' within the meaning of Federal Rule of Criminal Procedure 41(aX2XC), that is, a government agent engaged in enforcing the criminal laws and duly authorized by the Attorney General to request a search warrant. I have been employed by the FBI for three and a half years, and I am currently assigned to investigate violations of criminal law relating to the sexual exploitation of children. 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 been involved in search warrants for 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 the storage media specified below (the "Subject Devices") for the purpose of seizing the items and information described in Attachment A. This affidavit is based upon my personal knowledge; my review of documents and other evidence; and my conversations with other law enforcement personnel. Because this 1 2017.08.02 SDNY_GM_00000073 CONFIDENTIAL EFTA_00114157 EFTA01262830 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 ofmy 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 Devices 3. The Subject Devices are particularly described as compact discs stored in containers marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence of JEFFREY EPSTEIN located at 9 East 71st Street, New York, New York (the "Epstein Residence"), on or about July 7, 2019. C. The Target Subject and the Subject Offenses 4. The Target Subject of this investigation is JEFFREY EPSTEIN. 5. For the reasons detailed below, I believe that there is probable cause to believe that the Subject Devices contain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Section 1591 (sex trafficking of minors); Title 18, United States Code, and Section 371 (sex trafficking conspiracyXthe "Subject Offenses") by the Target Subject. 11. Probable Cause 6. On or about July 2, 2019, a grand jury in this District returned an Indictment charging JEFFREY EPSTEIN with violations of Title 18, United States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 371 (sex trafficking conspiracy). A copy of the Indictment is attached hereto as Exhibit A and is incorporated by reference. The Indictment and Victim-I 7. 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 2 2017.08.02 SDNY_GM_00000074 CONFIDENTIAL EFTA_00114158 EFTA01262831 possessed and controlled the Epstein Residence, which is described in Exhibit A as "the New York Residence." 8. 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 Epstein Residence. In particular, and as alleged in the Indictment, when a victim arrived at the Epstein Residence, she would be escorted to a room inside the Epstein Residence 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. 9. As set forth in paragraphs 12 through 13 ofExhibit 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. 3 2017.08.02 SONY_GM_00000075 CONFIDENTIAL EFTA_00114159 EFTA01262832  10. 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 have interviewed Victim-I.1 I know from my conversations with other law enforcement officers who have interviewed Victim- I, that 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 Epstein Residence. This sexual abuse all occurred when Victim-1 was under the age of 18. b. During that same period, Victim-1 observed multiple floors of the Epstein Residence and numerous individual rooms within the Epstein Residence. Victim-I has provided detailed descriptions of certain aspects of the interior of the Epstein Residence, including Victim- l's memory of specific details regarding the layout, furnishings, decorations, and floor pattern of various areas within the Epstein Residence. c. In particular, Victim-I observed that a bathroom in the residence contained what appeared to be a bust of a human torso (the "Torso"). Victim-I believed that the Torso was possibly a type of sex toy. d. In addition, Victim-I recalled observing what appeared to be a taxidermied dog in a living space in the Epstein Residence. I In meetings with the Government, 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-I 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. 4 2017.08.02 SDNY_GM_00000076 CONFIDENTIAL EFTA_00114160 EFTA01262833  e. Victim-1 recalled that EPSTEIN typically abused her in a room she described as a "massage room," (the "Massage Room"), which contained a massage table, and was decorated with artwork depicting naked women, hung on walls that appeared to be adorned with fabric. f. Victim-I has not been in the Epstein Residence since approximately 2005. The July 6.2019 Search Warrant of the Epstein Residence 11. On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the Epstein Residence (the "First Warrant"). 12. At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the "Search Team") commenced executing the search warrant at the Epstein Residence; 1 joined the Search Team thereafter. 13. Based on the Search Team's observations during an initial search of the Epstein Residence, at approximately 7 p.m., the Search Team stopped the search and froze the scene in order to seek a new search warrant. 14. On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate Judge, signed a search warrant authorizing a search of the Epstein Residence (the "Second Warrant"). The search warrant is attached as Exhibit B, 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. 15. Based on my conversations with members of the search team, and my participation in the search, I have learned the following: a. Inside a safe in a closet on the third floor, the Search team discovered, 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 marked "Young- 5 2017.08.02 SDNY_GM_00000077 CONFIDENTIAL EFTA_00114161 EFTA01262834  ther is marked "Misc. Nudes." -and_" Another disc is marked "Nudes 00-24." Ano or "LSJ." For e." Some discs contain the word "Zorro" Yet another is marked "Girl Pics Nud law enforcement Pies." Based on my conversations with example, one disc is marked Bono investigation, I belie ve the name "Zorro" refers to Zorro agents who have participated in this e Saint James, ico, and the name LSJ refers to Littl Ranch, EPSTEIN's property in New Mex that include Islands. The majority ofthe discs contain titles EPSTEIN's property in the U.S. Virgin that appear ers seized by the Search Team have titles female names. Some of the discs in the bind safe, where based given that these discs were contained in a to refer to trips or vacations. However, discs that contraba nd is often stored, and given that these on my training and experience I know probable cause girls and nudes, I submit that there is were stored together with discs referencing the Subject ed by the Search Team contain evidence of that all of the discs in the binders seiz Offenses. 2 the Fifth floor of the Epstein residence, the b. In the drawer of a dresser in a room on numerous s, a shoebox (the "Shoebox") containing Search team discovered, among other item ale names. One s are labeled, in handwriting, with fem compact discs. The majority of the disc Yet another disc is marked "Blonde Girl Photo Shoot." disc is marked "Thai Massage." Another ed by ked "Mis c. Girl s Nud e/Di nne r--S cien tists." The discs in the Shoebox were seiz disc is mar overed loose that same dresser, the Search Team disc the Search Team. In another drawer of experience, phot ogra phs dep ictin g you ng, nude females who, based on my training and pola roid marked, in er, the Search Team discovered a folder appear to be teenagers. In that same draw s, where the majority 2 During the search, the Search Team left behind binders that contained disc Accordingly, disc s were labe led in a man ner that did not appear to refer to girls or nudes. of the left at the licat ion does not seek auth oriza tion to search those compact discs, which were this app Epstein Residence. 6 2017.08.02 SONY_GM_00000078 CONFIDENTIAL EFTA_00114162 EFTA01262835  nude and sexually suggestive handwriting, IR' which contained photographs, including ger than my training and experience appears to be youn photographs of a young girl who, based on agers, based phs of young girls who appear to be teen 18. The folder contains other nude photogra " (the er is a compact disc marked `11at US 6/03 on my training and experience. Inside the fold s in m. Given that the labels of the compact disc Disc"), which was seized by the Search Tea s in the and the name of a girl, and the fact that disc the Shoebox reference "massage," "girls," contained nude and sexually Shoebox and the Disc were seized from a dresser that also e to believe respectfully submit that there is probable caus suggestive photographs ofa young girl, I . n Disc contain evidence of the Subject Offenses that the discs seized from the Shoebox and the Residence, the Search Team discovered, c. In a closet on the Fifth Floor ofthe Epstein other items, /old photos." The box contained, among among other items, a box marked "women disc is marked h are labeled with hand-written titles. One approximately seven compact discs, whic apher-a03" The remaining discs contain titles "nudes 00-24." Another is labeled "Photogr n that g discs were seized by the Search Team. Give that include female names. All ofthe foregoin "women/old that the discs were stored in a box marked one of these discs is marked "nudes" and that there is ed from the Epstein Residence, I submit photos," and given the other evidence seiz ence of the Subject Offenses. probable cause that the discs contain evid overed numerous black binders containing d. In that same closet, the Search Team disc pact discs. ographs (with file names underneath) and com what appear to be print outs of digital phot h appeared to ten binders (the "Seized Binders")3 whic The Search Team seized approximately girls, some of ographs of nude or partially nude young contain, among other photographs, phot young ed on my training and experience, some of the which are in sexually suggestive poses. Bas 3 The Search Team did not seiz e the remaining binders. 7 2017.03.02 SONY GM_00000079 CONFIDENTIAL EFTA_00114163 EFTA01262836  Seized Binders m appear to be under the age of 18. The girls appear to be teenagers, some of who el. However, to be family functions, events, and trav also include photographs of what appear of nude or ers were stored together with photographs given that the discs in the Seized Bind the Seized ther e is probable cause that all of the discs in partially nude young girls, I submit that Offenses! Binders contain evidence of the Subject Team and described in paragraphs 15(a)-(d) e. The compact discs seized by the Search New York in y stored within the Southern District of are the Subject Devices, and are currentl bers 15, 16, 17, 18, and 22. containers marked with FBI evidence num d the search and seizure for "any other 16. The Second Wan-ant expressly authorize Subject rega rding victims of potential victims of the documents of communications with or because, rant authorizes the search ofthe Subject Devices Offenses." Accordingly, the Second War s that appear to able cause to believe they included disc based on their markings, there was prob the Subject girls who may be victims of contain documents regarding underage abundance . How eve r, law enfo rcem ent has not yet reviewed the Subject Devices. In an Offenses search the that the Court issue a warrant to seize and of caution, therefore, I respectfully request and Seizure s and info rma tion spe cifie d in Atta chm ent A to this affidavit and to the Search item Warrant. mit that there is probable cause to believe 17. Based on the foregoing, I respectfully sub of the Subject Offenses. that the Subject Devices contain evidence re the majority the sear ch, the Sea rch Tea m left behind binders that contained discs, whe • Dur ing ordingly, s were labe led in a man ner that did not appear to refer to girls or nudes. Acc of the disc were left at the to search those compact discs, which this application does not seek authorization Epstein Residence. 8 2017.08.02 SMY_GM_00000080 CONFIDENTIAL EFTA_00114164 EFTA01262837 III. Procedures for Searching ESI A. Review of ESI ement officers and 18. Law enforcement personnel (including, in addition to law enforc of the investigation and related agents, and depending on the nature of the ESI and the status staff, agency personnel assisting the proceedings, attorneys for the government, attorney support ts under government control) will government in this investigation, and outside technical exper and review the ESI contained therein create a forensic image of the Subject Devices (if practicable) for information responsive to the warrant. various techniques 19. In conducting this review, law enforcement personnel may use of the Subject Offenses. Such to determine which files or other ESI contain evidence or fruits techniques may include, for example: contain (analogous to • surveying directories or folders and the individual files they ns and opening a drawer looking at the outside of a fi le cabinet for the markings it contai believed to contain pertinent files); first few "pages" of such • conducting a file-by-file review by "opening" or reading the to performing a cursory files in order to determine their precise contents (analogous its relevance); examination of each document in a file cabinet to determine recove r recently deleted data or • "scanning" storage areas to discover and possibly deliberately hidden files; and electronic storage areas to • performing electronic keyword searches through all to the subject matter of determine the existence and location of data potentially related the investigations; and files, registry data, and any • reviewing metadata, system information, configuration computer was used. other information reflecting how, when, and by whom the detect all relevant data. For one thing, 5 Keyword searches alone are typically inadequate to of files, such as images and videos, do keyword searches work only for text data, yet many types data, there may be information properly not store data as searchable text. Moreover, even as to text search because the information does not subject to seizure but that is not captured by a keyword contain the keywords being searched. 9 2017.08.02 SONY GM_00000081 CONFIDENTIAL EFTA_00114165 EFTA01262838  20. 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 personnel may need to conduct a complete review of all the ESI from seized devices or storage media to evaluate its contents and to locate all data responsive to the warrant. B. Return ofESI 21. If the Government determines that the electronic devices are no longer necessary to retrieve and preserve the data, and the devices themselves are not subject to seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return these 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 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 22. Based on the foregoing, I respectfully submit there is probable cause to believe that evidence of the Subject Offenses, and in particular the items described in Attachment A, will be located within the Subject Devices and therefore 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. 10 2017.08.02 SONY_GM_00000082 CONFIDENTIAL EFTA_00114166 EFTA01262839  23. The investigation is ongoing, and the investigative team anticipates beginning a search of the Subject Devices this evening, possibly after 10 p.m. In view of the circumstances, I submit that good cause exists to begin the search after 10 p.m. 4 special Agent Federal Bureau ofInvestigation Sworn to before me on July 7, 2019 VA THE HONORABLE BA SARA MOSES UNITED STATES MAGIS-IRATE JUDGE to m CC-cock-Lino) 11 201748.02 SONY_GM_00000083 CONFIDENTIAL EFTA_00114167 EFTA01262840  ATTACHMENT A L The Subject Devices to Be Searched The Subject Devices are particularly described as compact discs stored in containers marked with FBI evidence numbers 15, 16, 17, 18, and 22, seized from the residence located at 9 East 71st Street, New York, New York, on or about July 7, 2019. 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 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: I. 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. Motion pictures, films, videos, and other recordings of visual or written depictions of minors engaged in sexually explicit conduct, as defined in 18 U.S.C. § 2256(2); 5. 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; 6. 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). B. Review of ESI Law enforcement personnel (including, in addition to law enforcement officers and agents, and depending on the nature of the ESI and the status of the investigation and related proceedings, attorneys for the government, attorney support staff, agency personnel assisting the government in this investigation, and outside technical experts under government control) will create a forensic image of the Subject Devices (if practicable) and review the ESI contained therein for information responsive to the warrant. 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: 2017.08.02 SONY_GM_00000084 CONFIDENTIAL EFTA_00114168 EFTA01262841  • 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 investigation6; 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.A of this Attachment. However, law enforcement personnel arc 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. 6 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. 2 2017.08.02 SONY_GM_00000085 CONFIDENTIAL EFTA_00114169 EFTA01262842  EXHIBIT A 2017.06.02 CONFIDENTIAL SDNY-GM- EFTA,I14170 EFTA01262843  UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x SEALED UNITED• STATES OF AMERICA INDICTMENT 19 Cr. JEFFREY EPSTEIN, Defendant. 19 CRIM 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 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 SDNY_GM_00000087 CONFIDENTIAL EFIA_00114171 EFTA01262844 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 • SONY GM_00000088 CONFII3ENTIAL EFTA_00I 14172 EFTA01262845 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 Palm Beach Residence. 7. In both New York and Florida, JEFFREY EPSTEIN, the defendant, perpetuated this abuse in similar ways. Victims were initially recruited to provide "massages" to EPSTEIN, which would be performed 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 residence 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. , SDNY:GM_00000089 CONFIDENTIAL EFTA_00114173 EFTA01262846  9. When a 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."