EFTA00100427

AO 106 (SONY Rev. 0117) Application fora Search Warrant 
UNITED STATES DISTRICT COURT 
for the 
Southern District of New York 
In the Matter of the Search of 
) 
(Briefly describe the property to be searched 
) 
or identify the person by name and address) 
) 
Case No. 
See Attached Affidavit and its Attachment A 
) 
) 
) 
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 (identify 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 properly to be seized): 
See Attached Affidavit and its Attachment A 
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): 
ftvidence of a crime; 
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 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:  
under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. 
Sworn to before me and signed in my presence. 
Date: 
07/07/2019 
City and state: New York, NY 
) is requested 
Applicant's signature 
Special Agent 
Printed name and title 
FBI 
Judge's signature 
Hon. Barbara Moses, U.S. Magistrate Judge 
Printed name and title 
EFTA00100427

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
In the Matter of the Application of the United 
States Of America for a Search and Seizure 
Warrant for Compact Discs marked with FBI 
evidence numbers 15, 16, 17, 18, and 22, Seized 
from 9 East 71' Street, New York, NY on or 
about July 7, 2019, and Any Files or Media 
Stored Therein 
TO BE FILED UNDER SEAL 
Agent Affidavit in Support of 
Application for Search and Seizure 
Warrant 
SOUTHERN DISTRICT OF NEW YORK) ss.: 
being duly sworn, deposes and says: 
1. 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 office?' within the meaning of Federal Rule of 
Criminal Procedure 41(a)(2)(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 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 
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affidavit is being submitted for the limited purpose of establishing probable cause, it does not 
include all the facts that I have learned during the course of my investigation. Where the contents 
of documents and the actions, statements, and conversations of others are reported herein, they are 
reported in substance and in part, except where otherwise indicated. 
B. The Subject 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 conspiracy)(the "Subject Offenses") by the Target Subject. 
II. 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-1 
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 
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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 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. 
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10. 
One of the victims identified in paragraph 22 of Exhibit A is Victim-1. As part of 
the FBI's investigation of EPSTEIN, other law enforcement officers have interviewed Victim-1.1
I know from my conversations with other law enforcement officers who have interviewed Victim-
1, 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-1 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-1 observed that a bathroom in the residence contained what 
appeared to be a bust of a human torso (the "Torso"). Victim-1 believed that the Torso was 
possibly a type of sex toy. 
d. In addition, Victim-1 recalled observing what appeared to be a taxidermied dog in 
a living space in the Epstein Residence. 
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-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. 
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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-1 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; I 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-
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Prelaya and LaLasa." Another disc is marked "Nudes 00-24." Another is marked "Misc. Nudes." 
Yet another is marked "Girl Pics Nude." Some discs contain the word "Zorro" or "LSJ." For 
example, one disc is marked "Dana Zorro Pies." 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. However, given that these discs were contained in a safe, where based 
on my training and experience I know that contraband is often stored, and given that these discs 
were stored together with discs referencing girls and nudes, I submit that there is probable cause 
that all of the discs in the binders seized by the Search Team contain evidence of the Subject 
Offenses. 2
b. In the drawer of a dresser in a room on the Fifth floor of the Epstein residence, the 
Search team discovered, among other items, a shoebox (the "Shoebox") containing numerous 
compact discs. The majority of the discs are labeled, in handwriting, with female names. One 
disc is marked "Thai Massage." Another disc is marked "Blonde Girl Photo Shoot." Yet another 
disc is marked "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 my training and experience, 
appear to be teenagers. In that same drawer, the Search Team discovered a folder marked, in 
2 During the search, the Search Team left behind binders that contained discs, where the majority 
of the discs were labeled in a manner that did not appear to refer to girls or nudes. Accordingly, 
this application does not seek authorization to search those compact discs, which were left at the 
Epstein Residence. 
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handwriting, "Sue," which contained photographs, including nude and sexually suggestive 
photographs of a young girl who, based on my training and experience appears to be younger than 
18. The folder contains 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 "Sue at LIS 6/03" (the 
"Sue Disc"), which was seized by the Search Team. Given that the labels of the compact discs in 
the Shoebox reference "massage," "girls," and the name of a girl, and the fact that discs in the 
Shoebox and the Sue Disc were seized from a dresser that also contained nude and sexually 
suggestive photographs of a young girl, I respectfully submit that there is probable cause to believe 
that the discs seized from the Shoebox and the Sue Disc contain evidence of the Subject Offenses. 
c. In a closet on the Fifth Floor of the Epstein 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 marked 
"nudes 00-24." Another is labeled "Photographer--Mackla `03" The remaining discs contain titles 
that include female names. All of the foregoing discs were seized by the Search Team. Given that 
one of these discs is marked "nudes" and that the discs were stored in a box marked "women/old 
photos," and given the other evidence seized from the Epstein Residence, I submit that there is 
probable cause that the discs contain evidence of the Subject Offenses. 
d. 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 my training and experience, some of the young 
3 The Search Team did not seize the remaining binders. 
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girls appear to be teenagers, some of whom appear to be under the age of 18. The Seized Binders 
also include photographs of what appear to be family functions, events, and travel. However, 
given that the discs in the Seized Binders were stored together with photographs of nude or 
partially nude young girls, I submit that there is probable cause that all of the discs in the Seized 
Binders contain evidence of the Subject Offenses! 
e. The compact discs seized by the Search Team and described in paragraphs 15(a)-(d) 
are the Subject Devices, and are currently stored within the Southern District of New York in 
containers marked with FBI evidence numbers 15, 16, 17, 18, and 22. 
16. 
The Second Warrant expressly authorized the search and seizure for "any other 
documents of communications with or regarding victims of potential victims of the Subject 
Offenses." Accordingly, the Second Warrant authorizes the search of the Subject Devices because, 
based on their markings, there was probable cause to believe they included discs that appear to 
contain documents regarding underage girls who may be victims of the Subject 
Offenses. However, law enforcement has not yet reviewed the Subject Devices. In an abundance 
of caution, therefore, I respectfully request that the Court issue a warrant to seize and search the 
items and information specified in Attachment A to this affidavit and to the Search and Seizure 
Warrant. 
17. 
Based on the foregoing, I respectfully submit that there is probable cause to believe 
that the Subject Devices contain evidence of the Subject Offenses. 
4 During the search, the Search Team left behind binders that contained discs, where the majority 
of the discs were labeled in a manner that did not appear to refer to girls or nudes. Accordingly, 
this application does not seek authorization to search those compact discs, which were left at the 
Epstein Residence. 
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111. Procedures for Searching ESI 
A. Review of ESI 
18. 
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. 
19. 
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 investigations; and 
• 
reviewing metadata, system information, configuration files, registry data, and any 
other information reflecting how, when, and by whom the computer was used. 
5 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. 
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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 of ESI 
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. 
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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. 
Special Agent 
Federal Bureau of Investigation 
Sworn to before me on 
July 7, 2019 
THE HONORABLE BARBARA MOSES 
UNITED STATES MAGISTRATE JUDGE 
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ATTACHMENT A 
I. 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: 
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. 
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 
usernames 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: 
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• 
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 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. 
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. 
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EXHIBIT A 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
x 
UNITED 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, 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 
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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 
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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. 
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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 to 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 
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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 
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