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This is an FBI investigation document from the Epstein Files collection (FBI VOL00009). Text has been machine-extracted from the original PDF file. Search more documents →

FBI VOL00009

EFTA00225102

276 pages
Pages 21–40 / 276
Page 21 / 276
From: Vlllafana, Ann Marie C. (USAFLS) 
Sent: Monday, February 25, 2008 9:59 AM 
To: Miller, Caroline (USAFLS) 
Subject: Question regarding use of Grand Jury 
Hi Caroline — I have received two conflicting points of view regarding this question, so I thought 1 should ask 
the expert. Here is my situation: 
I have been involved in a long-term investigation of a child exploitation case. Throughout the investigation, I 
have presented evidence and testimony to Grand Jury A. Some of that evidence and testimony related to six 
victims (of a total of 19 victims), including the live testimony of one of those victims. I also began presenting 
evidence related to what I called a "draft proposed indictment." For various reasons, the indictment has been 
delayed about 9 months. And, for other strategic reasons, we have decided to drop the six victims referenced 
above, and replaced them with a different six victims. 
The question is now raised as to whether I should continue presenting to Grand Jury A, with a 404(b)-type 
instruction related to the evidence of the six dropped victims and some sort of instruction regarding the initial 
"draft proposed indictment", or whether I should present to Grand Jury B, excluding any testimony regarding 
those six victims. One other consideration — Grand Jury A is due to expire in August, and I anticipate that the 
investigation will continue for quite some time after indictment. It is possible that the 6 dropped victims will be 
re-added in a superseding indictment. 
Thank you. 
A. Marie Villafaila 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
1547 
08-80736-CV-MARRA 
P-014624 
EFTA00225122
Page 22 / 276
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Monday, February 25, 2008 12:00 PM 
To: 
Sloman, Jeff (USAFLS); Senior, Robed (USAFLS); Garcia, Rolando (USAFLS); Atkinson, 
Karen (USAFLS) 
Cc: 
Braden, Myesha 
,. 
Subject: 
Epstein 
all - I wanted to raise an issue with you regarding the presentation of the Epstein indictment. I have been 
A
the West Palm Beach Tuesday grand jury in the past, which has included presentation of testimony from 
R. and agent testimony regarding girls who will no longer be referenced in the indictment. 
I have conferred with Karen Atkinson and Caroline Heck 
regarding whether to stay with the same grand 
jury or present to a different grand jury. They agree that I should present to the same grand jury with some sort 
of instruction regarding not relying on evidence/testimony regarding those girls. 
That is my intention. I would like to present on March I I Lb. Epstein will be in town on March 10th for his state 
court hearing and hopefully we will be able to keep track of his whereabouts until the following day. Karen is 
reviewing the package now, so it should be in Miami by Monday, March 31 
Also, I invited Myesha to be present for the grand jury proceedings, but she is waiting to hear from Alice and 
Drew about her level of involvement in the case. She is available on that dater so, if Alice and Drew decide 
about this, she will be able to attend. 
Thank you. 
A. Mark Villafafia 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820.8777 
EXHIBIT B-113 
Tracking: 
1542 
08-80736-CV-MARRA 
P-014628 
EFTA00225123
Page 23 / 276
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, February 26, 2008 10:05 AM 
To: 
Braden, Myesha 
Subject: 
Epstein 
Hi Myesha — I won't even tell you about how today is starting off badly on this case (politics, of course, not 
facts). But, in any event, the word is that CEOS is going to undertake an "independent review" of the case and 
meet with Epstein's attorneys some time next week. My supervisor is finishing the review of the indictment 
package and I know she caught some typos. When I finish those revisions, I will e-mail to you the entire 
indictment package, and you can find out what Drew wants to look at. I have one real concern, however. As 
you know, there are several girls that are still unknown to the defense. I want to avoid any possibility that those 
names might be disclosed. Should I redact the names of all of the girls from the pros memos that I send to you? 
Thank you, Myesha. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
1520 
EXHIBIT I3-114 
08-80736-CV-MARRA 
P-014629 
EFTA00225124
Page 24 / 276
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Tuesday, February 28, 2008 8:41 AM 
To: 
Sloman, Jeff (USAFLS) 
Cc: 
Senior, Robed (USAFLS) 
Subject: 
RE: Confidential 
Why would we possibly let him keep the same deal after all he has put us through? And after we have 
discovered 6 new girls, plus another 3 probable victims in New York? 
A. Mole VillafaAa 
Assistant 11.S. Attorney 
500 S. Australian Ave. Suite 400 
West Palm Beach. FL. 33401 
Phone 561 209-1047 
Fax 561 820.8777 
From: Sloman, Jeff (USAFLS) 
Sent: Tuesday, February 26, 2008 9:34 AM 
To: Senior, Robert (USAFLS); VIllafana, Ann Marie C. (USAFLS) 
Subject: Confidential 
FYI 
From: Stoman, Jeff (USAFLS) 
Sent: Monday, February 25, 2008 7:43 PM 
To: [email protected] 
Cc: Oosterbaan, Andrew 
Subject: Epstein 
Jay, 
The Section Chief of DOJ's Child Exploitation Obscenity Section (CEOS) notified me today that 
he will review the matter involving your client Jeffrey Epstein. The Section Chief has indicated 
that he is ready to proceed immediately, and I understand you are in the process of providing 
him this week with a summary of issues to be reviewed, and expect to meet with him next 
week. 
The Section Chief also indicated that you would be calling this Office regarding the upcoming 
March 3, 2008 court date in the Fifteenth Judicial Circuit, in and for Palm Beach County. As you 
know, the Agreement entered into by your client originally provided that the United States 
1522 
08-80736-CV-MARRA 
EXHIBIT B-11S 
P-014630 
EFTA00225125
Page 25 / 276
Attorney's Office for the Southern District of Florida (this Office) would defer prosecution if 
your client pled guilty to enumerated state charges by October 26, 2007. Since then, that date 
has been postponed for a number of reasons. At this juncture, it would not be reasonable to 
keep the current March 3I date as a deadline for compliance with the Agreement. That said, 
this Office is very concerned about additional delays. Despite this concern, I want to assure 
you that if counsel for Mr. Epstein meets with CEOS next week (the week of March 31, this 
Office will extend the time for compliance with the Agreement to provide CEOS time to 
engage in a thorough review. 
It goes without saying that in the event that CEOS decides that a federal prosecution should 
not be undertaken against Mr. Epstein, this Office will close its investigation. However, should 
CEOS disagree with Mr. Epstein's position, Mr. Epstein shall have one week to abide by the 
terms and conditions of the September 24, 2007 Agreement as amended by letter from United 
States Attorney Acosta to Jay Lefkowitz. 
Jeffrey H. Sloman 
First Assistant U.S. Attorney 
Southern District of Florida 
• 
• 
Tracking: 
1523 
08-80736-CV-MARRA 
P-01463I 
EFTA00225126
Page 26 / 276
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Wednesday, February 27, 2008 4:28 PM 
To: 
Weinstein, David (USAFLS) 
Cc: 
Senior, Robert (USAFLS) 
Subject: 
RE: To the Civil Rights Chief 
That is fine. Just please send a copy to me for my file. 
A. Marie Villafaha 
Assistant U,S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
 
Original Message 
From: Weinstein, David (USAFLS) 
Sent: Wednesday, February 27, 2008 4:22 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Senior, Robert (USAFLS) 
Subject: Re: To the Civil Rights Chief 
Bob, Jeff, Alex and I discussed this yesterday. Jeff made some edits to your 
proposed letter and wants to send it out under Bob's signature. 
Bob have you had a chance to review Jeff's email? 
 
 Original Message  
From: Villafana, Ann Marie C. (USAFLS) 
To: Weinstein, David (USAFLS) 
Cc: Senior, Robert (USAFLS) 
Sent: Wed Feb 27 16:16:36 2008 
Subject: RE: To the Civil Rights Chief 
Hi David -- Have you had a chance to talk to Bob about this? I think my window 
is close to "opening" and I don't want the bad guys to come up with another 
reason for delay. 
Thank you. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
EXHIBIT B-116 
1499 
08-80736-CV-MARRA 
P-014632 
EFTA00225127
Page 27 / 276
 
Original Message 
From: Weinstein, David (USAFLS) 
Sent: Thursday, February 21, 2008 5:03 PM 
To: Villafana, Ann Marie C. (USAFLS) 
Cc: Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Garcia, Rolando (USAFLS) 
Subject: Re: To the Civil Rights Chief 
Timing is everything. Right now I am at the NAC attending the Criminal Civil 
Rights Seminar. 
Your letter seems to cover everything, but I want to chat with Bob about it 
before we send it out. It should probably be addressed to Stephan Curran, who is 
the Deputy assigned to cover our District. 
Bob and I can talk Monday when I get back and we can send out the letter. 
Since Drew's shop is involved and has been for a while, they will hopefully agree 
with our/your conclusion. 
DSW 
 
 Original Message  
From: Villafana, Ann Marie C. (USAFLS) 
To: Weinstein, David (USAFLS) 
Cc: Senior, Robert (USAFLS); Atkinson, Karen (USAFLS); Garcia, Rolando (USAFLS) 
Sent: Thu Feb 21 15:56:01 2008 
Subject: To the Civil Rights Chief 
Hi David - I was just perusing the U.S. Attorney's Manual looking for an answer 
on another case and I noticed that Section 9-75.030 (regarding Coordination of 
Child Sex Abuse cases) says that cases involving violations of 18 USC 1591 
(related to child sex trafficking) are supposed to be coordinated with CEOS and 
the Civil Rights Division. 
According to Section 8-3.120, prior to presentation to the grand jury, the U.S. 
Attorney is supposed to advise the Civil Rights Division in writing of the 
following: 
(a) Identity of the targets of the investigation; 
(b) The factual allegations to be investigated; 
(c) The statutes which may have been violated; 
(I) The United States Attorney's assessment of the significance of the case and 
whether the case is one of "national interest," and 
(e) The U.S. Attorney's proposed staffing of the matter (including whether a 
Civil Rights Division attorney should be assigned to work directly on the 
matter). 
Here is my proposal for such a written notification: 
Dear  
: Pursuant to USAM Section 8-3.120, I write to inform 
you of an ongoing investigation of a child exploitation matter that may result in 
charges of violet' 
targe. 
estiga '—
t 
pstein, 
and 
a/k/a 
The inves'iga on as revea ed 
a 
effrey pstein would use hiss
1500 
08-80736-CV-MARRA 
P-014633 
EFTA00225128
Page 28 / 276
assistants (Kellen, Marcinkova, and 
to arrange appointments with minors to 
engage in commercial sexual activity. 
ommunications were made via telephones. 
Once appointments were made, Epstein would travel to the Southern District of 
Florida, where he maintained a residence, and the minors would travel to his home 
in Palm Beach where the sexual activity would occur. The Office anticipates 
charges of violations of Title 18, united States Code, Sections 371, 2422, 2423, 
and 1591. The investigation of the case by the City of Palm Beach Police 
Department has resulted in press coverage because of the titillating nature of 
the facts, but we see this case as similar to other "sex tourism" cases charged 
by our office, and not a matter of "national interest" as' defined by the U.S. 
Attorney's Manual. With respect to staffing, the Office has consulted with the 
Child Exploitation and Obscenity Section, and we anticipate that the case will be 
staffed by at least one Assistant United States Attorney from our West Palm Beach 
office and at least one CEOS Attorney. 
If we determine that the case should be presented for an indictment, a copy will 
be provided to you. 
David - If you need any more info, please let me know. Also, the indictment is 
currently being reviewed by my supervisor. If you want to send the draft to 
Civil Rights now, please let me know. 
Thank you. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
Tracking: 
1501 
08-80736-CV-MARRA 
P-014634 
EFTA00225129
Page 29 / 276
Villafana, Ann Marie C. (USAFLS) 
From: 
Kuyrkendall, E N. 
Sent: 
Thursday, February 28.2008 4:34 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Re: A fun task 
We made contact w ny girl. Ny agent to set up interview for next week. Sorry 
haven't made it over there yet, I'm hoping to finish up qp the GJSs soon. 
 
 Original Message  
From: Villafana, Ann Marie C. (USAFLS) <[email protected]> 
To: Kuyrkendall, E N.; Richards, Jason R. 
Sent: Thu Feb 28 16:07:12 2008 
Subject: A fun task 
Hi guys - I am still wading through these FedEx records. There are a lot of 
shipments from "The Art of Women" in Haleiwa, Hawaii. I was able to access their 
MySpace page and he claims to be a photographer for "aspiring models." He 
invites aspiring models to visit his website, www.artofwomen.com 
<http://www.artofwomen.com> , but I cannot access it because DO) blocks me. Can 
you try? 
Also, someone from JE's office sent a package to Chiko 
Hoge, U.S. Secret 
Service, in Honolulu. It looks like it was around thetime that JE took Clinton 
to Africa. 
Dave Rogers also sent a package to "Inspector Lewis, U.S. Customs Service, 1210 
Corbin Street, Elizabeth, NJ 07201" 
There were a lot of packages to Karin Models/MC-squared. 
name appears as the pers 
e packages a lot, do we know if 
sesz 
works for JE? What about 
Any word from FBI New York? 
Thanks. 
A. Marie Villafana 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
1484 
EXHIBIT 13.117 
08-80736-CV-MARRA 
P-014650 
EFTA00225130
Page 30 / 276
Villafana, Ann Marie C. (USAFLS) 
From: 
Villafana, Ann Marie C. (USAFLS) 
Sent: 
Friday, February 29, 2008 4:09 PM 
To: 
Senior, Robed (USAFLS); Sloman, Jeff (USAFLS); Weinstein, David (USAFLS) 
Subject: 
More good evidence
Hi guys — Another New York girl has been identified and will be interviewed next week. We also have FedEx 
records corroborating a girl who saw Epstein (and received a gift from him) when she was 15. 
I have e-mailed CEOS about additional information in preparation for their meeting but have received no 
response. 1.don't know whether I should send them info about the additional girls (to show how this case 
continues to grow, and has become multi-state) or not send the info to avoid an unintentional leak to Epstein's 
lawyers. 
I also wasn't sure whether you guys heard that 
parents have voluntarily dismissed their case against 
Epstein. According to the papers here no money changed hands, but it seems unlikely. I will be issuing a 
subpoena for her deposition transcript. 
Can someone give me an update? Thank you. 
A. Marie Vil 
Assistant U.S. Attorney 
500 S. Australian Ave, Suite 400 
West Palm Beach, FL 33401 
Phone 561 209-1047 
Fax 561 820-8777 
EXHIBIT B.-118 
Tracking: 
1474 
08-80736-CV-MARRA 
P-014655 
EFTA00225131
Page 31 / 276
Villafana, Ann Marie C. (USAFLS) 
From: 
Kuyrkendall, E N. 
Sent: 
Wednesday, March 12, 2008 9:50 PM 
To: 
Villafana, Ann Marie C. (USAFLS) 
Subject: 
Affidavit 
Attachments: 
AttachmentA; flashcardsw.aff 
Marie, 
Hey, here Is a rough and do I mean rough copy of the affidavit for the memory cards. Let me know what you think, it 
seems pretty thin. I did not know If you wanted all of the '4" and "A" passages but I Included it. I did not include A.H. 
at the bath tub because we are unsure of her age at the time the photo was taken (I am going to recheck to make sure). 
Paragraphs we need to add and I was hoping you might have - the characteristics of someone who is a collector of Child 
Pornography and any more technical verbiage regarding the forensic examination. I also did not do an Attachment 
B(typIcally the items we will be searching for ???). 
Text me on a time you would like me at your office and I will be there. I will be spending the day in our conference 
rooming prepping for GI 
Think about this SW - I guess I. think It Is pretty bad but I am to tired tonight to try and start over.(not sure if there is 
enough PC) 
p.s. Jason Is also concerned because he believes he reviewed the flash cards some time ago and now It appears we may 
not have had legal means. 
EXHIBIT 13-119 
1370 
08-80736-CV-MARRA 
P-014717 
EFTA00225132
Page 32 / 276
AO 93 IRev. 5185) 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: E. NESBITT KUYRKENDALL, FEDERAL BUREAU OF INVESTIGATION  , and any Authorized Officer of the United 
States: 
Affidavit(s) having been made before me by 
E. Nesbitt Kuvrkendall 
 who has reason to 
Alliant 
believe that E] 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 
 lit 
of 
FLORIDA 
there is now 
concealed a certain person or property, namely 
Me parson or Priseer49 
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. 44 371, 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 HE 
OMMANDED to search on or before 
he person or 
making the search (' 
ale cause has been estaS 
(Date) 
e person or property specified, serving this warrant 
Hat any time in the day or night as I find 
operty 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. 
WEST PALM BEACH. FLORIDA 
City and State 
LINNEA R. JOHNSON 
United States Ma, 'strata 
Name and Title of Judicial Of 
EXHIBIT 13-120 
EFTA00225133
Page 33 / 276
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
08-8067-LRJ 
IN RE: 
SEARCH WARRANT APPLICATION 
ORDER GRANTING UNITED STATES' MOTION TO SEAL 
This matter comes before the Court upon the United States' Motion to Seal the 
documents related to its Search Warrant Application. The Court being fully apprised in the 
premises, orders that the motion is hereby GRANTED. 
DONE AND ORDERED in chambers, in West Palm Beach, Florida, this  / 7  day of 
March, 2008. 
cc: 
A. Marie Villafana, AUSA 
LINNEA R. JOHNS() 
UNITED STATES.JvfAGISTRATE JUDGE 
'.0 
EFTA00225134
Page 34 / 276
(Rm. 06/2005)Seakd Document Du 
king Form 
UNITED STATES DISTRICT COURT 
Southern District of Florida 
Number: 08-8067-LRJ 
In Re 
SEARCH WARRANT APPLICATION 
SEALED DOCUMENT TRACKING FORM 
Party Filing Matter Under Seal 
On behalf of (select one): 
Name: A. Marie Villalana. U.S. Attorneys Oleos 
Address: 500 S. Australian Ave, Siete 400, West Palm Beach, FL 33401 
Telephone: 561 820-8711 
Date sealed document filed: 3/1712008 
1:1 Plaintiff 
0 Defendant 
If sealed pursuant to statute, cite statute: Fed. R. Crim. P. 6(e) (Grand Jury Material) 
If sealed pursuant to previously entered protective order, date of order and docket entry number: 
The matter should remain sealed until: 
K Conclusion of Trial 
0 Arrest of First Defendant 
1:1 Case Closing 
0 Conclusion of Direct Appeal 
K Other: 
0 Permanently. Specify the authorizing law, rule, court order: 
The moving party requests that when the sealing period expires, the filed matter should be (select one): 
El Unsealed and placed in the public portion of the court file 
Destroyed 
K Returned to the party or counsel for the party, as identified above 
Attorney for. Movani l
nited Stales o 
rice 
EFTA00225135
Page 35 / 276
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
08-8067-LRJ 
IN RE: 
SEARCH WARRANT APPLICATION 
MOTION TO FILE DOCUMENTS UNDER SEAL 
The United States of America, by and through the undersigned Assistant United States 
Attorney, hereby moves to seal its Application for Search Warrant for the following reasons: 
1. 
The attached documents contain information relating to an ongoing grand jury 
investigation; thus, pursuant to Fed. R. Crim. P. 6(e)(6), all records and orders related to the grand-
jury proceedings must be kept under seal to the extent and as long as necessary to prevent the 
unauthorized disclosure of a matter occurring before the grand jury. 
2. 
Public disclosure of this matter would jeopardize the criminal investigation, notify 
potential subjects and/or targets and undermine the public interest and the function of the grand jury. 
WHEREFORE, the United States respectfully requests that the aforementioned documents 
be sealed. 
Respectfully submitted, 
R. ALEXANDER ACOSTA 
UNITED STATES ATTORNEY 
By: 
A. 
• 
E VILLAFAM
irt
Assistant United States Attorney 
ann.marie.c.villafana®usdoj.gov 
Florida Bar No. 0018255 
500 South Australian Avenue, Suite 400 
West Palm Beach, FL 33401 
Telephone: 561 820-8711 
Facsimile: 561 820-8777 
EFTA00225136
Page 36 / 276
A0106 (Rev. 5/85) Affidavit for Search Warrant 
United States District Court 
SOITTHERN
In the Matter of the Search of 
(Name, lektreu or brkf thrurigeSoe of prnoo le be nankin 
DISTRICT OF 
FLORIDA 
One Ritz Big Print Digital Film 
128 Megabyte CompactFlash memory card 
marked 3608128AW4801CF53 
in the custody of the Federal Bureau of Investigation 
APPLICATION AND AFFIDAVIT 
FOR SEARCH WARRANT 
CASE NUMBER: 013-8067-LRJ 
I,  E. Nesbitt Kuvrkendall 
 , being duly sworn, depose and say: 
I am a  Special Agent, Federal Bureau of Investigation 
 , 
have reason to believe 
that 
on the person of or  X  on the premises known as (name, description and/or 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 (give alleged grounds for search and seizure under Rule 41(b) of the Federal Rules of Criminal Procedure) 
evidence, instrumentalities, and fruits of a crime, concerning violations of Title 18, United States Code, 
Sections 371, 1591, 2252, 2252A, 2422, and 2423. 
The facts to support the issuance of a Search Warrant are as follows: 
see Attached Affidavit of E. Nesbitt Kuyrkendall 
Continued on the attached sheet and made a part hereof. 
X Yes _N 
Sworn to before me, and subrbetl in mi..Eresence: 
3 (7-6-C 
Date 
LINNEA R. JOHNSON 
UNITED STATES MAGISTRATE( 
Name and Title of Judicial Officer 
at 
3 77 
t 
(Lc 
E. Nesbitt Kuyrkendall, Special Agent 
Federal Bureau of Investigation 
Signature of J 
cial Officer 
EFTA00225137
Page 37 / 276
AFFIDAVIT 
I, E. Nesbitt Kuyrkendall (the "Affiant"), being duly sworn, depose and state: 
1. 
I am a Special Agent with the Federal Bureau of Investigation ("FBI") and have been 
so employed for the past ten (10) years. I am currently assigned to PB-2, the Violent Crimes and 
Major Offenses Squad of the Palm Beach County Resident Agency, Miami Division. Among my 
responsibilities as a Special Agent are investigating crimes against children, particularly offenses 
involving child pornography and the exploitation of children. 
2. 
I make this affidavit in support of an application by the United States of America for 
issuance of a warrant to search and seize evidence of violations of Title 18, United States Code, 
Sections 371, 1591, 2252, 2252A, 2422, and 2423; instrumentalities of such violations; and any 
fruits of those crimes located within electronic media, specifically two 128MB CompactFlash 
memory cards, seized in October 2005 by The Town of Palm Beach Police Department("PBPD") 
during the execution of a State of Florida search warrant at the premises located at 358 El Brillo 
Way, Palm Beach, Florida 33480, owned by Jeffrey Epstein (hereinafter, "Epstein's residence"). 
Those CompactFlash memory cards are more fully described as follows: (a) one Ritz Big Print 
Digital Film 128 Megabyte CompactFlash memory card, marked 3608128AW4801CF53, and (b) 
one 
PNY 
Technologies 
128 
Megabyte CompactFlash memory card, marked 
THNCF128MMA(T00CB) 999223 TAIWAN 0247 (hereinafter jointly referred to as "CompactFlash 
memory cards"). 
3. 
The facts set forth in this affidavit arc based on my personal knowledge, information 
obtained in this investigation from others, including other law enforcement officers, my review of 
documents and records related to this investigation, and information gained through my training and 
EFTA00225138
Page 38 / 276
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; 
18 U.S.C. § 2422(b) 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(b) 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(5)(c)(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; 
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 Joseph Recarey 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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