EFTA00153059

III. Procedures for Searching ESI 
A. Review of ESI 
61. 
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 Device for information responsive to the 
warrant. 
62. 
In conducting this review, law enforcement may use various techniques to 
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such 
techniques may include, for example: 
• 
surveying directories or folders and the individual files they contain (analogous to 
looking at the outside of a file cabinet for the markings it contains and opening a drawer 
believed to contain pertinent files); 
• 
conducting a file-by-file review by "opening" or reading the first few "pages" of such 
files in order to determine their precise contents (analogous to performing a cursory 
examination of each document in a file cabinet to determine its relevance); 
• 
"scanning" storage areas to discover and possibly recover recently deleted data; 
scanning storage areas for deliberately hidden files; and 
• 
performing electronic keyword searches through all electronic storage areas to 
determine the existence and location of search terms related to the subject matter of the 
investigation. (Keyword searches alone are typically inadequate to detect all 
information subject to seizure. 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.) 
63. 
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 Device to locate all data responsive to the warrant. 
41 
2017.08.02 
EFTA00153099

B. Return of the Subject Devices 
64. 
If the Government determines that the Subject Devices are no longer necessary to 
retrieve and preserve the data on the device, and that the Subject Devices are not subject to seizure 
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return the Subject 
Device, 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 
65. 
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. 
66. 
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. 
sworn via telephone 
Task Force Officer 
Federal Bureau of Investigation 
Sworn to before me on 
June 26, 2020 at 9:11 am 
80 to 
orttio le;"" 
HON. GABRIEL W. GORENSTEIN 
UNITED STATES MAGISTRATE JUDGE 
42 
2017.08.02 
EFTA00153100

Attachment A 
I. Devices Subject to Search and Seizure 
The devices that are the subject of this search and seizure warrant (the "Subject Devices") 
are described as follows: 
Two of the Subject Devices were seized from JEFFREY EPSTEIN's person during the 
course of his arrest by the FBI on or about July 6, 2020 (the "Arrest Subject Devices"). The Arrest 
Subject Devices are particularly described as follows: 
a. A silver iPad with serial number DLXQGM3KGMW3 ("Subject Device-1"); and 
b. A black iPhone with IMEI number 357201093322785 ("Subject Device-2"). 
33 of the Subject Devices were recovered from a search of JEFFREY EPSTEIN's private 
residence located at 9 East 71st Street, New York, New York, which took place on July 11, 2019 
(the "New York Subject Devices"). The New York Subject Devices are particularly described as 
follows: 
a. Two black hard drives, which were seized by Special Agent 
from a 
blue suitcase on or about July 11, 2019 ("Subject Device-3"); 
b. An Apple desktop computer, which was seized from in a cardboard box along the 
right wall of a room on the first floor of the New York Residence, and which has 
been assigned internal FBI barcode number E65 15034 ("Subject Device-4"); 
c. A silver iPad, which was seized from a shelf in the right corner of a room on the 
third floor of the New York Residence under a television, and which has been 
assigned internal FBI barcode number E65 15033 ("Subject Device-5"); 
d. A gray Apple iPad, which was seized from under a sink in a room on the third floor 
of the New York Residence, and which has been assigned internal FBI barcode 
number E65 15032 ("Subject Device-6"); 
e. A gray Apple iPad, which was seized from under a sink in a room on the third floor 
of the New York Residence, and which has been assigned internal FBI barcode 
number E6515031 ("Subject Device-7"); 
f. A Sony Vaio laptop, which was seized from inside a desk drawer in the drawing 
room on the second floor of the New York Residence, and which has been assigned 
internal FBI barcode number E65 15026 ("Subject Device-8"); 
A Dell Precision Tower 5810, which was seized from a storage area in the basement 
of the New York Residence, and which has been assigned internal FBI barcode 
number E65 15025 ("Subject Device-9"); 
2017.08.02 
EFTA00153101

h. A Seagate Barracuda 7200 hard drive, which was seized from a storage area in the 
basement of the New York Residence, and which has been assigned internal FBI 
barcode number E65 15024 ("Subject Device-10"); 
i. A MSI PC Computer, which was seized from a storage area in the basement of the 
New York Residence, and which has been assigned internal FBI barcode number 
E65 15023 ("Subject Device-11"); 
A Sony Camera with a black case, which was seized from in a drawer inside a room 
on the sixth floor of the New York Residence, and which has been assigned internal 
FBI barcode number E65 15022 ("Subject Device-12"); 
k. A gray Apple desktop computer, which was seized from a desk inside a room on 
the sixth floor of the New York Residence, and which has been assigned internal 
FBI barcode number E6515021 ("Subject Device-13"); 
I. A Seagate Backup Plus portable drive, which was seized from a shoebox on top of 
a desk in a room on the fifth floor of the New York Residence, and which has been 
assigned internal FBI barcode number E65 15020 ("Subject Device-14"); 
m. A white Apple iPhone 5, which was seized from the lower left shelf of a white 
wooden cabinet in a mom on the fifth floor of the New York Residence, and which 
has been assigned internal FBI barcode number E6515019 ("Subject Device-15"); 
n. An Apple desktop computer, which was seized from on top of a desk inside the 
drawing room on the second floor of the New York residence, and which has been 
assigned internal FBI barcode number E6515018 ("Subject Device-16"); 
o. An Apple desktop computer, which was seized from on top of a desk in a room on 
the fifth floor of the New York Residence, and which has been assigned internal 
FBI barcode number E6515017 ("Subject Device-17"); 
A SPIEF 2014 silver USB, which was seized from a cabinet on the back wall of a 
storage closet on the first floor of the New York Residence, and which has been 
assigned internal FBI barcode number E65 15016 ("Subject Device-18"); 
q. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage 
closet on the first floor of the New York Residence, and which has been assigned 
internal FBI barcode number E6515015 ("Subject Device-19"); 
r. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage 
closet on the first floor of the New York Residence, and which has been assigned 
internal FBI barcode number E65 15014 ("Subject Device-20"); 
2 
2017.08.02 
EFTA00153102

s. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage 
closet on the first floor of the New York Residence, and which has been assigned 
internal FBI barcode number E6515013 ("Subject Device-21"); 
t. A Cruzer Guide USB, which was seized from a cabinet on the back wall of a storage 
closet on the first floor of the New York Residence, and which has been assigned 
internal FBI barcode number E6515012 ("Subject Device-22"); 
u. A blue EMTEC USB, which was seized from a small tray on the floor of the dining 
room on the first floor of the New York Residence, and which has been assigned 
internal FBI barcode number E651501 I ("Subject Device-23"); 
v. An EMTEC USB, which was seized from a small tray on the floor of the dining 
room on the first floor of the New York Residence, and which has been assigned 
internal FBI barcode number E6515010 ("Subject Device-24"); 
w. A silicone power micro SD adaptor, which was seized from a drawer inside a table 
in the dining room on the First Floor of the New York Residence, and which has 
been assigned internal FBI barcode number E65 15008 ("Subject Device-25"); 
x. A DELL Machine, which was seized from a desk in a room on the first floor of the 
New York Residence, and which has been assigned internal FBI barcode number 
E6515007 ("Subject Device-26"); 
y. A Cube 9000 Siteserver, which was seized from a desk in a room on the first floor 
of the New York Residence, and which has been assigned internal FBI barcode 
number E65 15006 ("Subject Device-27"); 
z. An HP Compaq Machine, which was seized from a desk in a room on the first floor 
of the New York Residence, and which has been assigned internal FBI barcode 
number E65 15005 ("Subject Device-28"); 
aa. A Mentor Media USB, which was seized from a desk in a room on the first floor of 
the New York Residence, and which has been assigned internal FBI barcode 
number E65 15004 ("Subject Device-29"); 
bb. A Data Traveler USB, which was seized from a desk in a room on the first floor of 
the New York Residence, and which has been assigned internal FBI barcode 
number E65 15003 ("Subject Device-30"); 
cc. A Data Traveler USB, which was seized from a desk in a room on the first floor of 
the New York Residence, and which has been assigned internal FBI barcode 
number E65 15002 ("Subject Device-31"); 
3 
2017.08.02 
EFTA00153103

dd. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet 
in an oval study on the first floor of the New York Residence, and which has been 
assigned internal FBI barcode number E65 15001 ("Subject Device-32"); 
ee. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet 
in an oval study on the first floor of the New York Residence, and which has been 
assigned internal FBI barcode number E65 15000 ("Subject Device-33"); 
ff. A "Seagate Path 100" hard drive, which was seized from inside a book shelf cabinet 
in an oval study on the first floor of the New York Residence, and which has been 
assigned internal FBI barcode number E6433827 ("Subject Device-34"); and 
gg. A silver Apple desktop computer, which was seized from a desk in an oval study 
on the first floor of the New York Residence, and which has been assigned internal 
FBI barcode number E6433828 ("Subject Device-35"). 
27 of the Subject Devices were recovered from a search of a private island in the U.S. 
Virgin Islands, known as Little Saint James, which is an approximately 75 acre island located 
approximately four miles off the southeast coast of St. Thomas Island (the "Virgin Islands 
Residence") on or about August 12, 2019 (the "Virgin Islands Subject Devices"). The Virgin 
Islands Residence consists of multiple structures, including a main residence as well as several 
other smaller structures on the island, including a pool house, sheds, a beach house, an office, and 
multiple cabanas. The Virgin Islands Subject Devices are particularly described as follows: 
a. A gray Mac desktop computer labeled "kitchen mac," which was recovered from a desk 
in the main residence on the island ("Subject Device-36"); 
b. A silver Mac laptop labeled "JE big laptop," bearing serial number W89111772QT, 
which was recovered from a desk in the main residence on the island ("Subject Device-
37"); 
c. A silver MacBook Pro bearing serial number c02qmOgugwdp, which was recovered 
from a desk in the main residence on the island ("Subject Device-38"); 
d. A silver iPad model A1567 bearing serial number dmpq125ng5ypy, which was 
recovered from a desk in the main residence ("Subject Device-39"); 
e. A silver iPad model A1567 bearing serial number dmpqL1rrng5y, which was recovered 
from a desk in the main residence ("Subject Device-40"); 
f. A silver Mac desktop computer bearing serial number cO2nm1m0fy14, which was 
recovered from a desk in the pool house on the island ("Subject Device-41"); 
A silver Mac desktop computer, which was recovered from a desk in a cabana on the 
island ("Subject Device-42"); 
4 
2017.08.02 
EFTA00153104

h. A Toshiba Laptop, which was recovered from a box on the floor near a desk in a shed 
on the island ("Subject Device-43"); 
i. An HP laptop bearing serial number cnd81368v5, which was recovered from a desk in 
a shed on the island ("Subject Device-44"); 
A silver Mac desktop computer, which was recovered from a desk in a cabana on the 
island ("Subject Device-45"); 
k. A silver Macbook desktop computer, which was recovered from a desk in a cabana on 
the island ("Subject Device-46"); 
I. A Dell Inspiron Tower computer model D19M QCNFA335, which was recovered from 
a desk in the beach house on the island ("Subject Device-47"); 
m. A silver Mac desktop computer model A1311 bearing serial number W804736DDAS, 
which was recovered from a desk in the beach house on the island ("Subject Device-
48"); 
n. A Unfi video bearing mac ID 1829f b4fbe426ea90, which was recovered from a server 
rack inside a shed on the island ("Subject Device-49"); 
o. A Unifi Server bearing mac ID 1735K 788A20463234-8uuu9f, which was recovered 
from a server rack inside a shed in on the island ("Subject Device-50"); 
An HP server with four 500 GB drives, bearing serial number MXQ3220187, which 
was recovered from a shed on the island ("Subject Device-51"); 
q. A Panasonic IOC TDE100 computer bearing serial number 1OC-TDa0104 
9LCCD005398, which was found on a server rack in a shed on the island ("Subject 
Device-52"); 
r. A 6 bay with 146 GB drives bearing serial number MXQ824A1R, which was found on 
a server rack in a shed on the island ("Subject Device-53"); 
s. A silver Mac desktop computer, which was recovered from a desk in a cabana on the 
island ("Subject Device-54"); 
t. An HP desktop tower model 260-A010, bearing serial number cnv7160050, which was 
recovered from the maintenance office on the island ("Subject Device-55"); 
u. An HP tower model 260-A010, bearing serial number cnv716004y, which was 
recovered from the maintenance office on the island ("Subject Device-56"); 
v. A Mac desktop computer model A1312, bearing serial number w89524czspj, which 
was recovered from the maintenance office on the island ("Subject Device-57"); 
5 
2017.08.02 
EFTA00153105

w. A Lenovo tower machine type 90J0, bearing serial number mj07yg6u, which was 
recovered the maintenance office on the island ("Subject Device-58"); 
x. A Lenovo tower bearing serial number 153306g2umjxekgx, which was recovered the 
maintenance office on the island ("Subject Device-59"); 
y. An HP Tower bearing serial number CNV74213M3 570-P056, which was recovered 
the maintenance office on the island ("Subject Device-60"); 
z. A Unifi cloudkey with FCCID: SWX-UCCK IC 6545A-UCCK and Mac ID 
1843kb4fbe4d30c69-dcrgm9, which was found on a server rack in a shed on the island 
("Subject Device-61"); and 
aa. A red Nikon digital camera, which was recovered on a file cabinet next to a desk in a 
cabana on the island ("Subject Device-62"). 
II. Review of ESI on the Subject Devices 
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 Device for evidence, fruits, and 
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of 
minors), 2422 (transportation of minors), 2423 (enticement to travel), and 371 (conspiracy to 
commit sex trafficking, transportation of minors, and enticement to travel) (the "Subject 
Offenses"), for the period 1994 through August 8, 2019, described as follows: 
1. 
Evidence concerning the identity or location of the owner(s) or user(s) of the 
Subject Devices. 
2. 
Evidence concernin 
the identity or location of co-conspirators of JEFFREY 
EPSTEIN, including 
and GHISLAINE MAXWELL. 
3. 
Evidence concernin communications to, from, by, and/or among co-conspirators 
of JEFFREY EPSTEIN, including 
and GHISLAINE MAXWELL. 
4. 
Any documents or communications with or regarding victims or potential victims 
of the Subject Offenses. 
5. 
Documents or records reflecting payments to victims and/or co-conspirators 
including but not limited to bank and financial records, spreadsheets, ledgers, account listings, 
check and wire records, and documents reflecting cash withdrawals. 
6. 
Documents or records reflecting travel plans or arrangements for victims or 
potential victims of the Subject Offenses, or co-conspirators in those Subject Offenses, including 
6 
2017.08.02 
EFTA00153106

but not limited to itineraries, tickets, receipts, flight manifests, passport or identification 
information, and related records. 
7. 
Any photographs of victims or potential victims of the Subject Offenses. 
8. 
Any nude, partially nude, or sexually suggestive photographs of individuals who 
appear to be teenage girls, or younger. 
9. 
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. 
10. 
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). 
If the Government determines that any of the Subject Devices is no longer necessary to retrieve 
and preserve the data on the device, and that any of the Subject Devices is not subject to seizure 
pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return any such Subject 
Device, upon request. 
7 
2017.08.02 
EFTA00153107

EXHIBIT A 
EFTA00153108

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
x 
UNITED. STATES OF AMERICA 
JEFFREY EPSTEIN, 
Defendant. 
SEALED 
INDICTMENT 
19 Cr. 
1 9 UN 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 
EFTA00153109

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 
EFTA00153110

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. 
3 
EFTA00153111

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 
4 
EFTA00153112

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 
EFTA00153113

encounters through Employee-1, who sometimes asked the 
recruiters to bring a specific minor girl for 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 employee or associate would ensure that minor victims 
were available for encounters upon his arrival in Florida. 
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the 
defendant, engaged in a similar course of abusive 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 
inside, the victim would provide a nude or semi-nude 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 indirect contact with the victim's genitals. EPSTEIN would 
also typically masturbate during these encounters, ask victims 
6 
EFTA00153114

to touch him while he masturbated, and touch victims' genitals 
with his hands or with sex toys. 
16. 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 for each encounter. 
17. JEFFREY EPSTEIN, the defendant, knew that certain 
of his 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, on multiple additional 
occasions. 
18. JEFFREY EPSTEIN, the defendant, who during the 
relevant time period was frequently in New York, would arrange 
for Employee-2 or other employees to contact victims by phone in 
advance of EPSTEIN's travel to Florida to ensure appointments 
were scheduled for when he arrived. In particular, in certain 
instances, Employee-2 placed phone calls to minor victims in 
Florida to schedule encounters at the Palm Beach Residence. At 
the time of certain of those phone calls, EPSTEIN and Employee-2 
were in New York, New York. Additionally, certain of the 
individuals victimized at the Palm Beach Residence were 
contacted by phone by Employee-3 to schedule these encounters. 
7 
EFTA00153115

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 
EFTA00153116

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 An 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 
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a telephone call to Minor Victim-1 in order to schedule an 
appointment for Minor Victim-1 to engage in paid 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 2005, Employee-2, located in the 
Southern District of New York, and on behalf of EPSTEIN, placed 
a telephone call to Minor Victim-2 in order to schedule an 
appointment for Minor Victim-2 to engage in paid sex acts with 
EPSTEIN. 
f. 
In or about 2005, Minor Victim-3 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 for each 
encounter. EPSTEIN also encouraged and enticed Minor Victim-3 
to recruit other girls to engage in paid sex acts, which she 
did. EPSTEIN asked Minor Victim-3 how old she was, and Minor 
Victim-3 answered truthfully. 
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EFTA00153118