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FBI VOL00009

EFTA00186590

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experience. Since this affidavit is being submitted for the limited purpose of securing a search 
warrant, I have not included each and every fact known to me concerning this investigation, but have 
set forth only those facts necessary to establish probable cause to believe that evidence, 
instrumentalities, and fruits of crimes, that is violations of Title 18, United States Code, Sections 
371, 1591, 2252, 2252A, 2422, and 2423 will be found within the CompactFlash memory cards, 
specifically the electronic information contained therein. 
The Statutes Involved 
4. 
The investigation involves possible violations of Title 18, United States Code, 
Sections 371, 1591, 2252, 2252A, 2422, and 2423, which provide as follows: 
a. 
18 U.S.C. § 371 makes it an offense for two or more persons to conspire to 
commit an offense against the United States; 
b. 
18 U.S.C. § 1591(a) makes it an offense for anyone to knowingly, in or 
affecting interstate commerce, recruit, entice, provide, or obtain by any means a person , knowing 
that the person has not attained the age of eighteen and will be caused to engage in a commercial sex 
act; 
c. 
18 U.S.C. §§ 2252 and 2252A prohibit the manufacture, possession, 
distribution, and receipt of child pornography; 
d. 
18 U.S.C. § 2422(6) prohibits the use of a facility of interstate commerce, 
including the telephone, to persuade, induce, or entice a minor to engage in prostitution or any sexual 
activity for which any person can be charged with a criminal offense; and 
e. 
18 U.S.C. § 2423(b) makes it an offense for anyone to travel in interstate 
commerce for the purpose of engaging in any illicit sexual conduct with another person. "Illicit 
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sexual conduct" includes a commercial sex act with a person under eighteen or other sexual conduct 
with a person under the age of sixteen. 
5. 
Section 2422(6) refers to activity "for which any person can be charged with a 
criminal offense." Pursuant to: 
a. 
Florida Statutes Section 794.05, a "person 24 years of age or older who 
engages in sexual activity with a person 16 or 17 years of age commits a felony of the second 
degree;" 
b. 
Florida Statutes Section 794.021, "ignorance of the age [of the victim] 
is no defense," and that neither "misrepresentation of age by [the victim] nor a bona fide 
belief that such person is over the specified age [shall] be a defense;" 
c. 
Florida Statutes Sections 800.04(5)(a) and 800.04(5Xc)(2), an adult 
"who intentionally touches in a lewd or lascivious manner the breasts, genitals, genital area, 
or buttocks, or the clothing covering them, of a person less than 16 years of age, or forces or 
entices a person under 16 years of age to so touch the perpetrator, commits lewd or lascivious 
molestation," which is a felony of the second degree if the victim is 12 years of age or older 
but less than 16 years of age; 
d. 
Florida Statutes Sections 800.04(6)(a) and 800.04(6)(b), an adult "who 
[i]ntentionally touches a person under 16 years of age in a lewd or lascivious manner or 
[s]olicits a person under 16 years of age to commit a lewd or lascivious act commits lewd or 
lascivious conduct," which is a felony of the second degree; 
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e. 
Florida Statutes Sections 800.04(7)(a) and 800.04(7)(c), an adult "who: 
(1) [i]ntentionally masturbates; (2) [i]ntentionally exposes the genitals in a lewd or lascivious 
manner, or (3) [i]ntentionally commits any other sexual act that does not involve actual 
physical or sexual contact with the victim, including, but not limited to ... the simulation of 
any act involving sexual activity in the presence of a victim who is less than 16 years of age, 
commits lewd or lascivious exhibition," which is a felony of the second degree. 
f. 
Florida Statutes Section 800.04(2), "[n]either the victim's lack of 
chastity nor the victim's consent is a defense to the crimes proscribed by [Section 800.04]" 
g. 
Florida Statutes Section 800.04(3), "[t]he perpetrator's ignorance of the 
victim's age, the victim's misrepresentation of his or her age, or the perpetrator's bona fide 
belief of the victim's age cannot be raised as a defense in a prosecution under [Section 
800.04]" 
h. 
Florida Statutes Section 800.02, a "person who commits any unnatural 
and lascivious act with another person commits a misdemeanor of the second degree." 
The Epstein Investigation 
6. 
In the Spring of 2006, Detective 
with the Town of Palm Beach Police 
Department contacted me about the investigation of Jeffrey Epstein's solicitation of minors to 
engage in prostitution and his lewd and lascivious conduct with minors. The FBI opened a case file 
in July 2006, and your Affiant is the case agent assigned to the investigation. 
7. 
At around the same time that the FBI opened its investigation, the U.S. Attorney's 
Office began a grand jury investigation. Your Affiant is one of the agents on the Federal Rule of 
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Criminal Procedure 6(e) list, that is, someone who is authorized to have-access to the facts of the 
investigation and the materials related thereto. 
8. 
As part of the Federal Grand Jury investigation, a subpoena was issued for all of the 
physical evidence obtained by PBPD during the course of its investigation, including the evidence 
seized when PBPD executed the search warrant at Epstein's residence in October 2005. Included 
in the evidence seized during the search of the Premises were the two CompactFlash memory cards. 
I have reviewed that evidence, which included a number of photographs of topless and nude young 
women taken at Epstein's residence. The evidence, including the two CompactFlash memory cards 
that are the subject of this application, have been in the custody of the Federal Bureau of 
Investigation since August 2006 and have not been tampered with or altered. Prior to that, they were 
in the custody of the Evidence Custodian of the Palm Beach Police Department, and I understand 
that the evidence was not tampered with or altered while in PBPD's custody. 
9. 
I note that I am aware that Epstein's attorneys have alleged that Detective 
made misstatements in his application for the state search warrant, but they have not moved to 
suppress any of that evidence in connection with the prosecution of Epstein by the State Attorney's 
Office for felony solicitation of prostitution. No federal agency was involved in the application for 
or execution of the search warrant, and this application is based upon evidence obtained through the 
FBI's independent investigation. 
10. 
During the course of the federal investigation, federal agents have interviewed more 
than two dozen young women who have reported engaging in sexual activity with Jeffrey Epstein 
while they were under eighteen. All of those girls have reported essentially the same information. 
While they were under the age of eighteen (between the ages of fourteen and seventeen), they were 
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approached by a colleague — either an acquaintance at school, a co-worker, a "friend of a friend," or 
the like — who told them that they could make a lot of money performing a "massage" for a wealthy 
older man who lived on Palm Beach island. In some cases the girls were told that they would have 
to remove some clothing during the massage, other girls were not told about this. The girls traveled 
to Epstein's residence and entered through a side door into the kitchen of the residence. There they 
were met by Epstein and/or one of his personal assistants, usually 
The girls would be 
led up to the master bathroom area of Epstein's bedroom. The bathroom had a separate room similar 
to a dressing area where a massage table would be set up. The girls described the presence of nude 
and topless photographs of young women throughout the house. Epstein would lie face down on the 
massage table and the girl would begin by massaging his back and legs. Epstein would then turn 
over and begin to masturbate while instructing the girl to pinch his nipples or to straddle him. In 
some cases, Epstein would place a large back massager/vibrator on the victim's vagina. With some 
girls, he would digitally penetrate her vagina while he masturbated. The sexual activity with some 
minors progressed to oral sex, sexual intercourse, and the introduction of an adult female into the 
activity. With some girls, the sexual activity began with the first massage; with others, there was no 
sexual activity at first but sexual activity occurred in later massages; and in many cases, Epstein 
pushed the girls to engage in more and more sexual activity with each visit. 
11. 
Almost all of the sexual massages ended the same way, when Epstein ejaculated. 
Epstein or one of his assistants would pay the girl $200 or more, depending on how much sexual 
activity occurred. A fee of $200 also would be paid to the "recruiter" who brought the girl for the 
visit. If Epstein liked the girl, he or his assistant would ask for the girl's telephone number. Later, 
one of Epstein's assistants would call the girl directly to arrange for the girl to return. In some 
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instances of scheduling a girl for "work," which was a euphemism for performing a sexual massage, 
Epstein's assistants would make the arrangement for the next time that Epstein was in Florida. 
During those calls, the assistant would invite the girl to return to Epstein's home to "work." None 
of the girls ever spontaneously went to Epstein's home to provide a sexual massage. The 
appointments were set up over the telephone. 
12. 
The victims interviewed by the federal agents were asked about Epstein's knowledge 
that they were minors. Many of the victims specifically discussed their ages with Epstein, and he 
provided them with birthday gifts, made statements about trips that he wanted to take them on when 
they were eighteen, and discussed high school events and college plans with them. For other victims, 
the subject of age was never discussed, and for others, their "recruiter" instructed them to lie and say 
they were eighteen. 
13. 
One of the young women interviewed during the course of the FBI's investigation was 
■ 
who stated that she first met Epstein at the age of fourteen. Epstein paid■$200 - $400 to 
provide him with massages. According to 
during the three years that she saw Epstein, all but 
three of the over one hundred massages she provided were sexual in nature. The sexual activity 
ranged from self masturbation on Epstein's part to Epstein touching. vagina. On a separate 
occasion, Epstein introduce an unidentified female during a massage, who performed oral sex on. 
while Epstein had sexual intercourse with the unidentified female. 
14. 
When. was approximately sixteen years old, 
Epstein's assistant, 
contacted, and told her that Epitein wanted 
to take some photographs of her. =, 
utilizing a digital camera, took nude photographs of, in several different locations in and around 
Epstein's Palm Beach residence. 
paid. $500 for posing for the nude photographs. Other 
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victims interviewed have repeatedly pointed to the existence of the pictures of nude and semi-nude 
women throughout the residence. 
15. 
Efforts have been made to corroborate the statements a 
and the other young 
women who have described their sexual relationships with Epstein. With respect toll, there are 
telephone records showing 
phone calls taduring the time period that she was seeing 
Epstein.also described receiving gifts from Epstein via Federal Express. A grand jury subpoena 
issued to Federal Express contained records of a number of packages sent by Epstein or his assistants 
to.. Likewise, the statements of other victims have been corroborated through telephone records, 
Western Union records, travel records, credit card receipts, sales records of theaters, and rental car 
records. 
16. 
Also, during the FBI's investigation, I interviewed a young woman, 
who had 
known Epstein several years ago, when she was in her late teens/early twenties. The woman was a 
struggling artist in New York who was specializing in painting nude portraits. Prior to preparing a 
portrait,■ would take several photographic studies. Epstein was very interested in her work and 
her photographs, and also expressed an interest in the artist's younger sister, Si' who was sixteen 
years old at the time. 
17. 
Epstein and an associate/companion, Ghislaine Maxwell, made arrangements and paid 
for. to travel to one of his homes, located in Now Mexico. One morning during that visit, Epstein 
got into bed with.. Mr. Epstein toll that he felt like "cuddling."described Epstein's actions 
as "spooning" and constantly hugging her. 
18. 
Epstein and Maxwell also made arrangements and paid for 
to fly home a 
for the primary purpose of taking artistic photographs of her family members in the nude. This 
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included the artist's younger siblings, two sisters,. an 
Due to the sensitive nature of the photographs■ created a photo log to document each 
image and the order it was taken. Later. learned that seven photographs, two 0. and five of the 
were missing. who was very upset, contacted Epstein's office and asked for one 
of Epstein's assistants to look for the missing photographs. also confronted Epstein and Maxwell 
about the missing photographs which they claimed they did not possess. A few weeks later 
received a telephone call from an unidentified caller who stated that the missing photographs were 
in Epstein's briefcase. The missing photographs were not recovered and.believes that Epstein is 
in possession of them. Although those photographs were artistic, rather than pornographic in nature, 
this further shows Epstein's interest in taking and maintaining nude and semi-nude photographs of 
minors. 
19. 
I have interviewed.and.bout their experiences with Epstein. Botheandil are 
reluctant to divulge their experiences publically. During the interview with., she was visibly 
disturbed when recalling an incident with Epstein at his ranch in New Mexico when she was sixteen 
years old..tated that one evening Epstein had come into her bedroom and sat on the bed. Epstein 
stroked her hair and told her she was beautiful. was unable to recall the remainder of any events 
that evening. •has also expressed her concern of speaking publicly against Epstein for fear of 
reprisals against her or her family. 
The Items to Be Searched and the Information Sought 
20. 
This application seeks permission to forensically examine two CompactFlash memory 
cards. Your Affiant knows that electronic media, 
i.e., CompactFlash memory cards, may be 
important to a criminal investigation because the objects may be used as storage devices that contain 
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contraband, evidence, instrumentalities, or fruits of a crime in the form of electronic data. Rule 41 
of the Federal Rules of Criminal Procedure permit the government to search for and seize computer 
hardware, software, and electronic files that are evidence of crime, contraband, instrumentalities of 
crime and/or fruits of crime. I know that CompactFlash memory cards are most often used in digital 
cameras to store photographs taken with the cameras. However, memory cards can be used to store 
any type of digital data, including computer Ides. 
21. 
The nature of electronic media, i.e., CompactFlash memory cards, requires forensic 
analysis to employ a variety of different search techniques. These techniques include, but are not 
limited to, opening files, reviewing directories of files, and searching for and analyzing deleted 
and/or hidden information. While conducting the analysis, data will be continuously evaluated as 
to whether or not it is within the scope of the issued search warrant. Only information within the 
scope of the search wanant will be acknowledged, shared with, or provided to, the investigators 
involved in this matter. All other information will be closed and maintained within the analytical 
unit. Forensic analysis will be conducted in close consultation with the United States Attorney's 
office for specific legal guidance throughout the analytical and reporting process. 
22. 
I understand that reviewing the contents of the CompactFlash memory cards was 
within the scope of the State search warrant that gave rise to the seizure of the cards from Epstein's 
residence, and that PBPD reviewed the contents of the cards. I also understand that an FBI agent 
conducted a similar review when all of the items were taken into federal custody pursuant to the 
federal grand jury subpoena. Those reviews did not involve a forensic examination to determine if 
there were any deleted or corrupted files, which could be recovered only via such a forensic analysis. 
I understand that the cursory reviews performed by the other law enforcement officers did not delete 
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or add any files to the CompactFlash memory cards and, therefore, they contain the same information 
that they had at the time they were removed from the Epstein residence. While the cursory review 
performed by the FBI agent did not exceed the scope of the PBPD's review, and therefore did not 
require the issuance of a warrant, the forensic review that is requested by this application would 
expand that review and, accordingly, your Affiant requests the issuance of a search warrant in 
accordance with United States v. Jacobsen, 466 U.S. 109, 115-21 (1984). 
23. 
As explained above, Epstein instructed one of his assistants to photograph using 
a digital cameranreported Epstein's unusual interest in, and probable theft of, nude photographs 
of the minor members of her family; and Epstein engaged in inappropriate sexual activity with 
numerous minor females. In light of Epstein's display of photographs of nude and semi-nude young 
women throughout his residence, your Affiant avers that there is probable cause to believe that 
photographs or other evidence of the victims' visits to Epstein's residence may be found on the 
CompactFlash memory cards. Accordingly, your Affiant seeks permission to forensically examine 
the CompactFlash memory cards for evidence, instrumentalities, and fruits of the crimes listed 
above, that is, the electronic information contained within the memory cards, including electronic 
files containing photographs, owner identification information, date and time information, names, 
addresses, and information regarding the source of any photographs or the persons depicted in any 
photographs. 
24. 
Although the cursory reviews did not reveal any of the items sought, your Affiant 
avers that there is probable cause to believe that a thorough forensic examination, which would 
include the recovery of any deleted or corrupted files, would result in the discovery of the data listed 
above, which is evidence, instrumentalities, and fruits of the crimes under investigation. 
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WHEREFORE, your Affiant requests that this court issue a search wan-ant for the 
CompactFlash memory cards described in the Application for Search Warrant and for the seizure of 
the items listed above. 
FURTHER YOUR AFFIANT SAYETH NAUGHT. 
Special Agent 
Federal Bureau of Investigation 
Subscribed and sworn to before me 
this 
day of March, 2008 
LINNEA R. JOHNSON 
UNITED STATES MAGISTRATE JUDGE 
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AO 93 (Rev. MS) Search Warrant 
United States District Court 
SOUTHERN 
DISTRICT OF 
FLORIDA 
In the Matter of the Search of 
(Name, address or brief description of property or premises to be searched) 
One Ritz Big Print Digital Film 
128 Megabyte CompactFlash memory card, 
marked 3608128AW4801CF53 
in the custody of the Federal Bureau of Investigation 
SEARCH WARRANT 
CASE NUMBER 08-8067-LRJ 
TO:
 FEDERAL BUREAU OF INVESTIGATION  , and any Authorized Officer of the United 
States: 
Affidavit(s) having been made before me by 
who has reason to 
Alltant 
believe that [] on the person of or Ed on the premises known as (name. description andfor location) 
One Ritz Big Print Digital Film 128 Megabyte CompactFlash memory card, 
marked 3608128AW4801CF53 
in the custody of the Federal Bureau of Investigation, 
505 S. Flagler Drive, Suite 500, West Palm Beach, Florida 
in the 
SOUTHERN 
District of  
FLORIDA 
 there is now 
concealed a certain person or property, namely (describe the person or property) 
the electronic information contained in that CompactFlash memory card, 
which is property that constitutes evidence of the commission of a criminal offense, instrumentalities of such 
violations; and any fruits of those crimes, that is, violations of 18 U.S.C. §§ 371, 1591, 2252, 2252A, 2422, and 
2423. 
I am satisfied that the affidavit(s) and any recorded testimony establish probable cause to believe that the person 
or property so described is now concealed on the person or premises above-described and establish grounds for the 
issuance of this warrant. 
YOU ARE HEREBY COMMANDED to search on or before  
(Date) 
(not to exceed 10 days) the person or place named above for the person or property specified, serving this warrant 
and making the search (in the daytime - 6:00 A.M. to 10:00 P.M.)(at any time in the day or night as I find 
reasonable cause has been established)) and if the person or property be found there to seize same, leaving a copy 
of this warrant and receipt for the person or property taken, and prepare a written inventory of the person or 
property seized and promptly return this warrant to the duty Magistrate Judge as required by law. 
 
 at WEST PALM BEACH, FLORIDA 
Date and Time Issued 
City and State 
LINNEA R. JOHNSON 
United States Magistrate Judge 
Name and Title of Judicial Officer 
Signature of Judicial Officer 
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