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FBI VOL00009

EFTA00164646

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AO 106 (SDNY Rev. 01117) Application for a Search Warrant 
ee 
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 'demi), the person by name and address) 
See Attached Affidavit and its Attachment A 
a 
caseIL.991/1.4ACimB) 
6 4 3 9 
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 (ident0 the person or describe the 
property to be searched and give.fts 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. 4I(c) is (check one or more): 
dente of a crime; 
O coiktraband, fruits of crime, or other items illegally possessed; 
Cl property designed for use,intended for use, or used in committing a crime; 
Cl 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) 
, there is now concealed (identify the 
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 
Id Continued on the attached sheet. 
Cl 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:  
Printed name and title 
..hjs —signature 
City and state:  New York, NY 
Hon. Henry Pitman, U.S. Magistrate Judge 
) is requested 
Printed name and title 
EFTA00164646
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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 the Premises Known and Described 
as 9 East•71st Street, New York, New York and 
Any Closed Containers/Items Contained Therein 
SOUTHERN DISTRICT OF NEW YORK) ss.: 
1 9MAG 
21-
TO BE FILED UNDER SEAL 
Agent Affidavit in Support of 
Application for Search and Seizure 
Warrant 
being duly sworn, deposes and says: 
I. Introduction 
A. Affiant 
1. 
I have been a Special Agent with the Federal Bureau of Investigation ("FBI") since 
2017. As such, I am a "federal law enforcement officer" 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 approximately two 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 physical premises. 
2. 
I make this Affidavit in support of an application pursuant to Rule 41 of the Federal 
Rules of Criminal Procedure for a second warrant to search the premises specified below (the 
"Subject Premises") 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 Premises 
3. 
The Subject Premises are particularly 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. As detailed further herein, the Subject Premises is believed to be owned, 
possessed, and controlled by JEFFREY EPSTEIN, a target subject of this investigation. A 
photograph of the front entrance to the Subject Premises is included below: 
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 Premises contain evidence, fruits, and instrumentalities of violations of Title 18, United 
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States Code, Section 1591 (sex trafficking of minors); and Title 18, United States Code, Section 
371 (sex trafficking conspiracy) (the "Subject Offenses") by the Target Subject. 
IL Probable Cause and the First Warrant 
A. Probable Cause Regarding the Target Subject's Commission of the 
Subject Offenses 
6. 
On or about July 2, 2019, a grand jury in this District returned an Indictment 
charging JEFFREY EPSTEIN with the Subject Offenses. A copy of the Indictment is attached 
hereto as Exhibit A and is incorporated by reference. 
B. Probable Cause Justifying Search of the Subject Premises 
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 
possessed and controlled the Subject Premises, 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 Subject Premises. In particular, and as alleged in the Indictment, when a 
victim arrived at the Subject Premises, she would be escorted to a room inside the Subject Premises 
with a massage table, where she would perform a massage on EPSTEIN.. The victims, who were 
as young as 14 years of age, were told by EPSTEIN or other individuals to partially or fully undress 
before beginning the "massage." During the encounter, EPSTEIN would escalate the nature and 
scope of physical contact with his victim to include, among other things, sex acts such as groping 
and direct and indirect contact with the victims' genitals. EPSTEIN typically would also 
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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 12Ihrough 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 EPS1'ETN, 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. 
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.' 
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 Subject Premises. This sexual abuse all occurred when Victim-I was 
under the age of 18. 
b. During that same period, Victim-1 observed multiple floors of the Subject Premises 
and numerous individual rooms within the Subject Premises. Victim-1 has provided detailed 
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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descriptions of certain aspects of the interior of the Subject Premises, including Victim-1's 
memory of specific details regarding the layout, furnishings, decorations, and floor pattern of 
various areas within the Subject Premises. 
The July 6.2019 Search Warrant of the Subject Premises 
11. 
On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate 
Judge, signed a search warrant authorizing a search of the Subject Premises. The search warrant 
is attached as Exhibit B and incorporated by. reference herein. 
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. 
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, I have learned the 
following: 
a. The Search Team observed a number of computing devices, including computers 
and tablet devices, throughout the Subject Premises. The Search Team did not seize any devices 
from the Subject Premises. 
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b. Inside a safe in a closet on the third floor, the Search team discovered and seized, 
among other items, several binders containing sleeves of compact discs, most of which are labeled 
with handwriting. In total, the binders contain dozens of compact discs. One disc is marked 
"Younga." 
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 "LSI." For example, one disc is marked _Zorro Pics." Based on my conversations with 
law enforcement agents who have participated in this investigation, I believe the name "Zorro" 
refers to Zorro Ranch, EPSTEIN's property in New Mexico, and the name LSJ refers to Little 
Saint James, EPSTEIN's property in the U.S. Virgin Islands. The majority of the discs contain 
titles that include female names. Some of the discs in the binders seized by the Search Team have 
titles that appear to refer to trips or vacations.2
c. In the drawer of a dresser in a room on the Fifth floor of the Epstein residence, the 
Search team discovered and seized, 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. Girl's Nude/Dinner—Scientists." The discs in the Shoebox were 
seized by the Search Team. In another drawer of that same dresser, the Search Team discovered 
loose polaroid photographs depicting young, nude females who, based on the training and 
experience of law enforcement officers who observed them, appear to be teenagers. In that same 
drawer, the Search Team discovered a folder marked, in handwriting, 
which contained 
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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photographs, including nude and sexually suggestive photographs of a young girl who, based on 
the training and experience of law enforcement officers who observed them, appears to be younger 
than 18. The folder 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 'Mat US 6/03" 
(the MDisc"), which was seized by the Search Team. 
d. 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 "Photographera `03" The remaining discs contain titles 
that include female names. All of the foregoing discs were seized by the Search Team. 
e. In that same closet, the Search Team discovered numerous black binders containing 
what appear to be print outs of digital photographs (with file names underneath) and compact discs. 
The Search Team seized approximately ten binders (the "Seized Binders") 3 which appeared to 
contain, among other photographs, photographs of nude or partially nude young girls, some of 
which are in sexually suggestive poses. Based on the training and experience of law enforcement 
officers who observed them, some of the young 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.4
3 The Search Team did not seize the remaining binders. 
During the search, the Search Team took a narrowly tailored approach to the warrant, and 
accordingly left behind binders that contained discs where the majority of the discs were labeled 
in a manner thrit did not appear to refer to girls or nudes. However, given the materials discovered 
on the discs seized from the Subject Premises, as discussed below, this application seeks a warrant 
to seize any and all computing devices and media storage devices, including but not limited to 
materials that the Search Team did not seize during the execution of the Second Warrant. 
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F. The compact discs seized by the Search Team and described in paragraphs 15(a)-(d) 
are currently stored within the Southern District of New York in containers' marked with FBI 
evidence numbers 15, 16, 17, 18, and 22 (the "Seized Discs"). 
16. 
On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate 
Judge, signed a search warrant to search and seize electronic media stored on the Seized Discs (the 
"Compact Disc Search Warrant"). The search warrant is attached as Exhibit C, and incorporated 
by reference herein. 
17. 
Based on my conversations with law enforcement agents who have reviewed the 
Seized Discs pursuant to the Compact Disc Search Warrant (the "Reviewing Agents"), I have 
learned the following: 
a. The discs contain approximately thousands of nude or partially nude photographs 
of girls or young women, many of which are in sexually suggestive poses. Based on my 
conversations with the Reviewing Agents, who have particular training and experience relating to 
child erotica and visual depictions of children in child exploitation cases, I have learned that the 
Reviewing Agents believe that many of the nude or partially nude images they have reviewed 
appear to depict girls under the age of 18. Moreover, many of the photographs appear to be labeled 
with file names that suggest the photographs depict these girls at properties associated with 
JEFFREY EPSTEIN. For example, some file names are marked "Zorro" or "LSJ." 
b. Among the photographs on the Seized Discs, the Reviewing Agents identified 
partially-nude photographs of a young girl, labeled with an associated name that matched a 
particular individual ("Individual-1"). After identifying those photographs, the Government Was 
advised by Individual-Ps counsel that Individual-1 recalls the month and year during which she 
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believes those partially-nude photographs were taken, and also the location where they were taken, 
and that she was 17 years old at the time. 
18. 
Based on my training and experience, given that media storage devices seized from 
the Subject Premises appear to contain nude and semi-nude images of underage girls, and because 
there is probable cause to believe that Epstein engaged in sex trafficking of underage girls, there 
is probable cause to believe that computers and other storage media in the Subject Premises—i.e., 
the same residence in which the Seized Discs were located—will contain evidence of the Subject 
Offenses. In my training and experience, individuals who store nude and/or sexually suggestive 
photographs of minors on compact discs or other external storage devices typically access those 
images from computers and other electronic devices in order to view those images, and individuals 
who store such materials on compact discs typically store similar files on other computing devices 
and storage devices. 
19. 
According to recent media reporting, Epstein has hosted one or more individuals at 
the Subject Premises as recently as a few months ago, as of July 2019, and one individual has been 
quoted in recent reporting stating that the individual was present with Epstein in the Subject 
Premises during that time. Additionally, according to international flight records that I have 
reviewed, a private jet owned and utilized by Epstein has traveled to the tri-state area at least in or 
about April 2019, May 2019, June 2019, and July 2019. Accordingly, there is probable cause to 
believe that Epstein recently has been present at the Subject Premises. 
III. Procedures for Searching ESI 
A. Review of ESI 
20. 
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 
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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 BSI contained therein 
for information responsive to the warrant. 
21. 
In conducting this review, law enforcement personnel may use various techniques 
to determine which files or other BSI 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. 
22. 
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 EST from seized devices or storage media to evaluate its contents and to locate all data 
responsive to the warrant. 
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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B. Return of ESI 
23. 
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(e), 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 
24. 
Based on the foregoing, given that media storage devices seized from the Subject 
Premises appear to contain evidence of the Subject Offenses, 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 Premises 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. 
Special Agent 
Federal Bureau of Investigation 
Sworn to before me on 
July 11, 2019 
Sitienty,I,man 
THE HONORABLE HENRY B. PITMAN 
UNJTED.STATES WaISTRATE JUDGE 
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EXHIBIT A 
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UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED'STATES OF AMERICA 
JEFFREY EPSTEIN, 
Defendant. 
x 
SEALED 
INDICTMENT 
19 Cr. 
1 9 CRIM 4.90 
COURT ONE 
(Sex Tiraffioking Conspixty) 
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 girld at his homes in Manhattan, New 
Yorke and Pain peach, Florida, among other locations. 
2. 
ta•partiouiar, from at least in or about 2002, up 
to and including at least in or about200S, 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 Beabh Residence") to engage in Sex acts With 
him, after which he would give the victims hUndteds of dollars 
in cash, Moreover' and in Order to maintain and increase his 
supply of 'victims, EPSTEIN. elao,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: 
IA both New York and Florida, JEFFREY EPSTEIN, 
the defendant, perpetuated. this abuse in similar ways. Victims 
wore initially recruited to provide "massages" to EPSTEIN, whidh 
would be perforthed 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 intentivized his victims 
to become recruiters by paying these victim-recruiters inandreds.
of dollars for each girl that they brought to EPSTEIN. In so 
doing, :EPSTEIN maintained a steady supply Or new victims to 
eXpleit. 
The New York Residence 
8. 
At all times relevant to this indictment, JEFFREY 
EPSTEIN, the defendant, possessed' and Controlled a multi-story 
pritate residence on the Upper EaSt Side of Manhattan, New York, 
the New York Resident*: BetWeen at least in or about 2002 
and in Or about 2005, Sp$TEIN abused numerous minor victims at 
the New York Residence by canSing these victims to be recruited 
to engage in paid sex acts With himL 
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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 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 
vidtims told him their age. Futther, 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 othet 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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encounters through Employee-1, wha 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 talmBeach, Florida, 
where EPSTEIN mined, possessed and controlled another large 
residence, i.e., the Palm Beach Residence. EPSTEIN frequently 
traveled from New York to Palm Beadh by private jet, before 
which an eMployee Or associate would ensure that minor victims 
were 'available for'endounters upon his arrival ih Florida. 
15. At the Palm Beach Residence, JEFFREY EPSTEIN, the 
defendant, engaged in a similar waxed of abusive conduct. 
When a victim initially arrived at the Palm Beach Residenne, She 
would be. escorted to a room, sometimes by an 44PloYee Pf 
EPSTEIN's, including, at times, two assistants ("EMployee-2" and' 
"Employee-31 who, as described herein, Were also responsible 
for scheduling sexual encounters with minor victims. Dupe 
inaidd, the victim would provide a nude or semi-nude massage for 
EPSTEIN, who Would himself typically be naked. During these 
enconnters,'EPSTEIN would escalate the nature and scope of the 
physical contain 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' • 
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to tough 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 YOrki *mild arrange 
for Employee-2-ox other employee$ to contact victims by phone in 
,advance of EPETEIN'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 Emplpyeer2 
were in New YOrki New York. Additionally, certain of the 
indiVidUais victimized at. the Palm.Beaah Residence were 
contacted by phone. by Employee-,8 to schedule these encounters. 
EFTA00164665
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