EFTA00171870.pdf

AO 106 (SDNY Rev. 01/17) Application for a Search Wanam UNITED STATES DISTRICT COURT for the Southern District of New York In the Matter of the Search of (Brieflydescribe the proper°, to be searched or ielentifr the person by name and address) See Attached Affidavit and its Attachment A cant aitht,6439 APPLICATION FOR A SEARCH AND SEIZURE WARRANT 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 (idemi)" the person or describe the property to be searched and give.its location): located in the Southern District of person or describe the property to be seized): See Attached Affidavit and its Attachment A New York The for the search under Fed. R. Crim. P. 41(c) is (check one or more): idence of a crime; • cor‘traband, 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: , there is now concealed (identify thethe Code Section(s) Offense Description(s) 18 U.S.C. §§ 1591 & 371 Sex trafficking of minors; sex trafficking conspiracy The application is based on these facts: See Attached Affidavit and its Attachment A ar Continued on the attached sheet. O Delayed notice of 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. Applicant's signature Special Agent FBI Printed name and title Sworn to before me and signed in my presence. Date: 7-- ---1 .1 is str atum City and state: New York, NY Hen. Henry Pitman, U.S. Magistrate Judge Printed name and title USAO_004280 EFTA_00022190 EFTA00171870 EXHIBIT A 12 2017.08.02 USA0_004292 EF1,00022202 EFTA00171882 UNITED"STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK VOITEE'STATES OF AMERICA JEFFREY EPSTEIN, Defendant. x SEALED INDICTMENT 19 Cr. 19 CRIM 490 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, segually exploited and• abused dozens of minor girls' at his homes in Manhattan, New • ; York] and Palm Beach, Florida, among other locations. 2. Ip.partioular, 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 vidtIMS hundreds of dollars in Cash, Wireovezi and in order to ntaintaib and increase his supply of v'ictims, EPSTEIN also paid certain of his victims to recruit additional girls to be similarly Abused by EPSTEIN. In USA0_004293 EFTA_00022203 EFTA00171883 this way, EPSTEIN created a vast network of underage victims for him to sexually exploit in. locations including New York and Palm Beach. 3. The victims described herein were as young as 14 years old at the time they were abused by JEFFREY EPSTEIN, the defendant, and were, for various reasons, often particularly vulnerable to exploitation. EPSTEIN intentionally sought out minors and knew that many of his victims were in fact under the 'age of 18, including because, in some instances, minor victims expressly told him their age. 4. In creating and maintaining this network of minor victims in Multiple states to sexually abuse and exploit, JEFFREY EPSTEIN, the defendant, worked and conspired with others, including employees and associates who facilitated his conduct by, among other things, contacting victims and scheduling their sexual encounters with EPSTEIN at the New York Residence and at the Palm Beach Residence. FACTUAL BACKGROUND 5. During all time periods charged in this Indictment, JEFFREY EPSTEIN, the defendant, was a financier with multiple residences in the continental United States, including the New York Residence and the Palm Beach Residence. 6. Beginning in at least 2002, JEFFREY EPSTEIN, the defendant, enticed and recruited, and caused to be enticed and • 2 USAO 004294 EFTA 00022204 EFTA00171884 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 perforMsd nude or partially 'nude, would become increasingly Sexual in nature, and would typically include one or more set acts. EPSTEIN paid his victims hundreds of dollars in dash for each encounter. Moreover; EPSTEIN abtiveLy enocuraged certain of his victims to recruit additional girls to be similarly sexually abused. EPSTEI.N incentivized his victims to become recruiters by paying these victim-recruiters hundreds of dollars for each girl that they brought t0 EPSTEIN. In so doing, .EPSTEIN maintained a steady supply 0 'nem victims to eXpldit. The New York Residence 8. At all times relevant to this indictment, JEFFREY EPSTEIN,• the defendant, iosseased and controlled a multi-story pritate residence on. the Uppet EaSt Side of Manhattan, New York, 4'0„ the ■ York ResidendS: Between at least in or about 2002 and in of about 2005, EPSTEIN abused numerous minor victims at the New York Residence by cat4ing these victims to be recruited to engage in paid sex acts With him. 3 USAO_004295 EFTA_00022205 EFTA00171885 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." 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 victim's genitals. EPSTEIN typically would also masturbate during these sexualized encounters, ask victims td touch him while he masturbated, and touch victims' genitals with his hands or with sex toys. 10. In connection with each sexual encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of dollars in cash for each encounter. 11. JEFFREY EPSTEIN, the defendant, knew that many of his New York victims were underage, including because certain victims told him their age. Further, once these minor victims were recruited, many were abused by EPSTEIN on multiple subsequent occasions at the New York Residence. EPSTEIN sometimes personally contacted victims to schedule appointments at the New York Residence. In other instances, EPSTEIN directed 4 USA' 004296 EFTA_00022206 EFTA00171886 employees and associates, including a New York-based employee ("Employee-1"), to communicate with victims via phone to arrange for these victims to return to the New York Residence for additional sexual encounters with EPSTEIN. 12. Additionally, and to further facilitate his ability to abuse minor girls in New York, JEFFREY EPSTEIN, the defendant, asked and enticed certain of his victims to recruit additional girls to perform "massages" and similarly engage in sex acts with EPSTEIN. When a victim would recruit another girl for EPSTEIN, he paid both the victim-recruiter and the new victim hundreds of dollars in cash. Through these victim- recruiters, EPSTEIN gained access to and was able to abuse dozens of additional minor girls. 13. In particular, certain recruiters brought dozens of additional minor girls to the New York Residence to give massages to and engage in sex acts with JEFFREY EPSTEIN, the defendant. EPSTEIN encouraged victims to recruit additional girls by offering to pay these victim-recruiters for every additional girl they brought to EPSTEIN. When a victim- recruiter accompanied a new minor victim to the New York Residence, both the victim-recruiter and the new minor victim were paid hundreds of dollars by EPSTEIN for each encounter. In addition, certain victim-recruiters routinely scheduled these 5 USAO 004297 EFTA_00022207 EFTA00171887 encounters through Employee-1, who sometimes asked the recruiters to bring a specific minor girl fog EPSTEIN. The Palm Beach Residence • 14. In addition to recruiting and abusing minor girls in New York, JEFFREY EPSTEIN, the defendant, created a similar network of minor girls to victimize in Palm. Beach, Florida, where EPSTEIN owned, possessed and controlled another large residence, i.e., the Palm Beach Residence. EPSTEIN frequently traveled from New York to Palm Beach by private jet, before which an eeployee or associate would ensure that minor victims were 'Satiable for'encounters upon his arrival in Florida. 15. At the Palm Beach Residence( JEFFREY EPSTEIN, the defendant, engaged in a similar course of abudive conduct. When a victim initially arrived at the Palm Beach Residence, she would be escorted to a room, sometimes by an eMployee of EPSTEIN's, including, at times, two assistants (*EMplOyee-2" and* "Employee-3") who, as described herein, were also responsible for scheduling sexual encounters with minor victims. Once inaidd, the victim would provide a nude or •semianude massage for EPSTEIN, who Would himself typically be naked. During these encounters, EPSTEIN would escalate the nature and scope of the physical contact to include sex acts Such as grOping'and direct and indireet with the victim's genitals' EPSTEIN would alsp typically masturbate during these encounters, ask victims 6 I USAO_004298 • EFTA _00022208 EFTA00171888 to tough him while he masturbated, and touch 'victims' genitals with his hands or with sex toys\ 10. In connection with each sexual. encounter, JEFFREY EPSTEIN, the defendant, or one of his employees or associates, paid the victim in cash. Victims typically were paid hundreds of &alert for each encounter. 17. JEFFREY EPSTEIN, the defendant, knew that certain of hit victims were underage, including because certain victims •• told him their age.' In addition, as with New York-based victims, many Florida victims, once recruited, were abused by JEFFREY EPSTEIN, the defendant, oh Multiple additional. occasions. 18. JEFFREY.EPSTEIN, the defendant, who during the relevant time period was frequently in New York, would arrange for avioyee-2 ox other emPloYeee to contact victiMs by phone in .advance of EP0TEIN's travel to Florida to ensure appointments were scheduled 'for when he arrived. II particular, in certain instances, Employee-2 placed phone calls to minor victims ih lor10# to schedule encounters at the Palm Beach Residence. At the time Of certain of those phone calls, ITSTEIN and Employee-'2 were ih New York, New York. Additionally, certain of the individuals at the Palm Stiaeh Residence were contacted by phone by Employee-,3 to schedule these encounters. 7 USAO_004299 EFTA_00022209 EFTA00171889 19. Moreover, as in New York, to ensure a steady stream of minor victims, JEFFREY EPSTEIN, the defendant, asked and enticed certain victims in Florida to recruit other girls to engage in sex acts. EPSTEIN paid hundreds of dollars to victim- recruiters for each additional girl they brought to the Palm Beach Residence. STATUTORY ALLEGATIONS 20. From at least in or about 2002, up to and including in or about 2005, in the Southern District of New York and elsewhere, JEFFREY EPSTEIN, the defendant, and others known and unknown, willfully and knowingly did combine, conspire, confederate, and agree together and with each other to commit an offense against the United States, to wit, sex trafficking of minors, in violation of Title 18, United States Code, Section. 1591(a) and (b). 21. It was a part and object of the conspiracy that JEFFREY EPSTEIN, the defendant, and others known and unknown, would and did, in and affecting interstate and foreign commerce, recruit, entice, harbor, transport, provide, and obtain, by any means a person, and to benefit, financially and by receiving anything of value, from participation in a venture which has engaged in any such act, knowing that the person had not attained the age of 18 years and would be caused to engage in a 8 USAO 004300 EFTA_00022210 EFTA00171890 commercial sex act, in violation of Title 18, United States Code, Sections 1591(a) and (b)(2). Overt Acts 22. In furtherance of the conspiracy and to effect the illegal object thereof, the following overt acts, among others, were committed in the Southern District of New York and elsewhere: a. In or about 2004, JEFFREY EPSTEIN, the defendant, enticed and recruited multiple minor victims, including minor victims identified herein as Minor Victim-1, Minor Victim-2, and Minor Victim-3, to engage in sex acts with EPSTEIN at his residences in Manhattan, New York, and Palm Beach, Florida, after which he provided them with hundreds of dollars in cash for each encounter. b. In or about 2002, Minor Victim-1 was recruited to engage in sex, acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the New York Residence over a period of years and was paid hundreds of dollars for each encounter. EPSTEIN also encouraged and enticed Minor Victim-1 to recruit other girls to engage in paid sex acts, which she did. EPSTEIN asked Minor. Victim-1 how old she was, and Minor Victim-1 answered truthfully. c. In or about 2004, Employee-1, located in the Southern District of New York, and on behalf of EPSTEIN, placed 9 USAO 004301 EFTA_00022211 EFTA00171891 a telephone call to Minor Victim-1.in order to schedule an appointment for Minor Victim-I. to engage inpaid sex acts with EPSTEIN. d. In or about 2004, Minor Victim-2 was recruited to engage in sex, acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the Palm Beach Residence over a period of years and was paid hundreds of dollars after each encounter. EPSTEIN also encouraged and enticed Minor Victim-2 to recruit other girls to engage in paid sex acts, which she did. e, In or about 200,5, EmplOyee2, iodated in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to Minor Victim-2 in order toacheddle an appointment for Minor Viptim-2 to engage in paid sex acts with EPSTEIN. 1. In or about ISO, Minor Victim-3 was • recruited to engage in sex acts with EPSTEIN and was repeatedly sexually abused by EPSTEIN at the PillBeach gesidenoe over a period of years and was paid hundreds of dollars for eaoh encounter. .EPSTEIN alSo encouraged and enticed.Miner Victim-3 to recruit other girls t4 engage in paid sex acts, which she did. EPSTEIN asked Minoritibtik-3 how old-She was, and Minor Victim-3 answered truthfully. 10 USAO_004302 EFFA_00022212 EFTA00171892 g. In or about 2005,, Employee-2, located in the Southern District of New York, and on behalf of EPSTEIN, placed a telephone call to.Minor Victim-3 in Florida in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with EPSTEIN. h. In or about 2004, Employee-3 placed a telephone call to Minor Victim-3 in order to schedule an appointment for Minor Victim-3 to engage in paid sex acts with' EPSTEIN. • (Title 18, United States Code, Section 371.) COUNT TWO (Sex Trafficking) The Grand Jury further charges: 23. The allegations contained in paragraphs'l through 19 and 22 of thiO Indictment are repeated and realleged as if fully set forth within. 24. From at least in or about gm, up to*and including in or about 2005, in the Southern DiStrict of New York, JEFFREY EPSTEIN, the'defendant, willfully and knowingly, in and affecting interstate ■ foreign commerce, did recruit, entice, harbor, transport,, provide, and obtain by any means a person, knoWing that the person had not attained the•age of 18 years and would be caused to engage in a commercial sex act, and' did aid and abet the same, to Wit, EPSTEIN recruited, enticed, harbored, transported, provided, and obtained numerous 11 USAO_004303 • EFTA_00022213 EFTA00171893 individuals•who were less than 18 years old, including but not limited to Minor Victim-1, as described above, and who were then caused to engage in at least one commercial sex act in Manhattan, New York. . (Title 18, United. States Code, Sections 1591(a), (b)(2), and 2.) FORFEITURE ALLEGATIONS 25. As a result of committing the offense alleged in Count Two of this Indictment, JEFFREY EPSTEIN, the defendant, shall forfeit to the United States, pursuant to'Title 18, United States Code, Section 1594(c)(1), any property, real and personal, that was used or intended to be used to commit or to facilitate the commission of the offense alleged in Count Two, and any property, real or personal, constituting or derived from any proceeds obtained, directly or indirectly, as a result of the offense alleged in Count Two, or any property traceable to such property, and the following specific property: a. The lot or parcel of land, together with its buildings, appurtenances, improvements, fixtures, attachments and easements, located at 9 East 71st Street, New York, New York, with block number 1386 and lot number 10, owned by Maple, Inc. 12 USAO 004304 EFTA_00022214 EFTA00171894 Substitute Asset provision 26. /f any of the above-described forfeitable property, as a result of any act or omission of the defendant: (a) cannot be located upon the exercise of due diligence; (b) has been transferred or sold to, or deposited with, a third person; (o) had been placed beyond the jurisdiction of the Court; (d), has been substantially diminished in value; or (e) has been commingled with other property which cannot be subdivided without diffioOlty; it is the intent of the United Stated, pursuant to 21 .U.S:C. 5.85.9(p) and 28 U.S.C. f 2461(c)k to seek forfeiture of any other property of the defendant up to the value. of the above forfeitable property. (title 18, linited States Code, Seetiion 094; title 21, ohited States Code, Section 853(p)) and Title 28, United States Code, Section.2O1.) MOM . BEAMAN United States Attorney 13 USAO_004305 EFFA_00022215 EFTA00171895 Form No. USA-53a-274 (Ed. 9-25-58) UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK UNITED STATES OF AMERICA v. JEFFREY EPSTEIN, Defendant. 1NuxCTNENT (18 U.S.C. SS 371, 1591(a), (b)(2), and 2) GEOFFREY S. SE 81411N United Stites Attornipy 14 USAO 004306 ; EFFA_00022216 EFTA00171896 EXHIBIT B USAO_004307 EFTA_00022217 EFTA00171897 AO 93 (SONY Rcv. 01/17) Starch and Sou= %mule UNITED STATES DISTRICT COURT for the Southern District of New York In the Matter of the Search of Miley describe the properly to be searched or identtfr the person byname and crams) See Attachment A ) ) ) ) ) Case No. SEARCH AND SEIZURE WARRANT To: Any authorized law enforcement officer An application by a federal law enforcement officer or in attorney for the government requests the search of the following person or property located in the Southern District of New York Meng& the person or describe the property to be searched and gin its location): See Attachment A The person or property to be searched, described above, is believed to conceal (Idealjfy the penon or describe the popery to be seisecp: . See Attachment A The search and seizure are related to vlolation(s) of Thud statutory citations): Title 18, United States Code, Sections 371 and 1591 I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the potion or proPertY. YOU APE. COMMANDED to execute this warrant on or before 2.0 • tot (hot to exceed 14 dew) ' Pi in the daytime 6:00 a.m. to 10 p.m. 0 at any time in the day or night as I find reasonable mule has been established. Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom, or from whose preniises, the property was taken, or leave the copy and receipt at the place whore the property was taken. The officer executing this warrant, or an officer present dining the execution of the warrant, must prepare an inventory as required by law and promptly return this warrant end inventory to the Clerk of the Court, Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. MO Initials CI I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate box) Ofor days Not to exceed 30). °until, the facts Justifying, r specific date of Date and time issued: • (-.): S ek • IA' City and state: New York, NY Judge's signature Hon. Barbara Moses, U.S. Magistrate Judge Printed name and title USAO 004308 EFTA_00022218 EFTA00171898 AO 93 (SONY Rev. OW 7) Search and stivae Warrant (Pogo 2) Return Case No.: Date and time warrant executed: Copy of warrant and inventory left with: Inventory made In the presence of: Inventory of the property taken and name of any person(s) seized: Certification I declare under penalty of perjury that this inventory is correct end was returned along with the original warrant to the Court. Data: &ending offiteris signature Printed nano and alle USAO 004309 EFTA_00022219 EFTA00171899 ATTACHMENT A I. Premises to be Searched—Subject Premises L The premises to be searched (the "Subject Premises") are described as a nearly 19,000 square foot multi-story single-family residence located at 9 East 71st Street, New York, New York, and include all locked and closed containers found therein. A photograph of the front entrance to the Subject Premises is included below:• IL Items to Be Seized 1, This warrant authorizes executing agents to photograph, video record and otherwise document the full interior of the Subject Premises, including any items, furnishings, or possessions therein. • • 2. In addition, this warrant authorizes the seizure of certain evidence, fruits, and inatruthentalities of violations of Title 18, linked States Code, Sections 1591 (sex trafficking of minors) and .11 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: a. Evidence concerning occupancy or ownership the Stibject Premises, including utility and telephone bills, mall envelopes, cortespondence, diaries, statements, identification documents, address books, telephone directories, and photographs of its occupant(s). b. Evidence concerning the layout, furnishings, decorations,.and floor pattern of the Subject Premises, ineluding photographs and blueprints of the Subject Premises. 2017.08.02 USAO_004310 EFTA_00022220 EFTA00171900 EXHIBIT C 14 2017.08.02 USAO_004311 EFTA_00022221 EFTA00171901 A093 (SONY Rev. 01/17) Search end Seizure Wormed UNITED STATES DISTRICT COURT for the Southern District of New York In the Matter of the Search of (Brieflydescribe the property to be searched or identO, the person by name and address) See Attachment A Case No. SEARCH AND SEIZURE WARRANT To: Any authorized law enforcement officer An application by a federal law enforcement officer or an attorney for the government requests the search of the following person or property located in the Southern District of New York (rreeror the person or describe the property to be searched and give its location): See Attachment A The person or property to be searched, described above, Is believed to conceal (iden* the person or describe the property to be seized): See Attachment A The search and seizure arc related to violation(s) of (Insert statutory citations): Title 18, United Slates Code, Sections 371 and 1591 I find that the affidavit(s), or any recorded testimony, establish probable cause to search and Seize the person or property. YOU ARE COMMANDED to execute this warrant on or before July 7, 2019 (nor to exceed 14 dttys) O in the daytime 6:00 a.m. to 10 p.m. lir at any time in the day or night as I find reasonable cause has been established. Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the place whore the property was taken. 'rhe officer executing this warrant, or an officer present during the execution of the warrant, must prepare an inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court. O Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court. USW Initials O I find that immediate notification may have an adverse result listed in IS U.S.C. § 2705 (except for delay of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be searched or seized (check the appropriate box) Ofor days (not to exceed 30). Ountil, the facts justifyi later specific date o Date and time issued: e?‘•-c%a Judge's signature City and state: New York, NY Hon. Barbara Moses, U.S. Magistrate Judie Printed name and tide USAO 004312 EFTA_00022222 EFTA00171902 AO93 (SDNY Adv. 01 / I 7)Searelt and Seizure Woman, (Page 2) Return Case No.: Date and time warrant executed: Copy of warrant and inventory left with: Inventory made in the presence of : Inventory of the property taken and name of any person(s) seized: Certification I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant to the Court. Date: Executing officer's signature Printed name and tide USAO 004313 EFTA_00022223 EFTA00171903 ATTACHMENT A I. Premises to be Searched—Subject Premises I. The premises to be searched (the "Subject Premises") are described as a multi-story single-family residence located at 9 East 71st Street, New York, New York, and include all locked and closed containers found therein. A photograph of the front entrance to the Subject Premises is included below: II. Items to Be Seized A. Evidence, Fruits, and Instrumentalities of the Subject Offenses This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors) and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: i. Any and all taxidermied dogs. ii. Any and all massage tables and massage paraphernalia. iii. Any and all busts or three-dimensional representations of female human torsos. iv. Any and all photos or representations depicting nude or partially nude women located in the Massage Room, as defined herein. v. Any and all sex toys and sex paraphernalia located in the Massage Room, as defined herein. 2017.08.02 USAO 004314 EFTA_00022224 EFTA00171904 vi. A binder labeled "PB Girls" and any other documents or communications with or regarding victims or potential victims of the Subject Offenses. 2 2017.08.02 USAO_004315 EFTA_00022225 EFTA00171905