EFTA00247131

3. 
Any nude, partially nude, or sexually suggestive photographs of individuals who 
appear to be teenage girls, or younger. 
4. 
Any documents evidencing the presence of co-conspirators at the Subject Premises. 
5. 
Records or other items that evidence ownership, control, or use of, or access to 
devices, storage media, and related electronic equipment used to access, transmit, or store 
information relating to the Subject Offenses, including, but not limited to, sales receipts, 
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved 
usemames and passwords, user profiles, e-mail contacts, and photographs. 
6. 
Any child erotica defined as suggestive visual depictions of nude minors that do 
not constitute child pornography, as defined by 18 U.S.C. § 2256(8). 
7. 
Any computer devices. and storage media believed to be owned or used by 
JEFFREY EPSTEIN including, but not limited to, desktop and laptop computers, disk drives, 
modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners, 
routers, moderns, and network equipment used to connect to the Internet. In lieu of seizing any 
such computer devices or storage media, this warrant also authorizes, in the alternative, the 
copying of such devices or media for later review. 
8. 
Any items or records needed to access the data stored on any seized or copied 
computer devices or storage media, including but not limited to any physical keys, encryption 
devices, or records of login credentials, passwords, private encryption keys, or similar information. 
9. 
Any items or records that may facilitate a forensic examination of the computer 
devices or storage media, including any hardware or software manuals or other information 
concerning the configuration of the seized or copied computer devices or storage media. 
10. 
Any evidence concerning the identities or locations of those persons with access to, 
control over, or ownership of the seized or copied computer devices or storage media. 
11. 
Any evidence concerning the ownership of the Subject Premises, and any maps or 
other geographical guides to the Subject Premises. 
3 
2017.08.02 
EFTA00247151

AO 106 (SDNY Rev. 01/17) Application fora Search Warrant 
UNITED STATES DISTRICT COURT 
for the 
Southern District of New Ilk 
MAG 
5 7 8 
In the Matter of the Search of 
• 
(Erich describe the property to be searched 
or identify thethe person to, name and address) 
Six binders with various CDs 
Case No. 
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 (Went°, the person or describe the 
property robe searched and give its location): 
located in the 
Southern 
District of 
New York 
, there is now concealed (Eden* the 
person or describe the property to be seized): 
See Attached Affidavit and its Attachment A 
The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): 
X O evidence of a crime; 
O contraband, fruits of crime, or other items illegally possessed; 
O property designed for use, intended for use, or used in committing a crime; 
O a person to be arrested or a person who is unlawfully restrained. 
The search is related to a violation of: 
Code Section(s) 
18 USC 1591 
18 USC 371 
Offense Description(s) 
Sex Trafficking of Minors 
Sex Trafficking Conspiracy 
The application is based on these facts: 
See Attached Affidavit and its Attachment A 
61 Continued on the attached sheet 
O Delayed notice of 
30 days (give exact ending date if more than 30 days: 
under 18 U.S.C. § 3103; the basis of which is set forth on theettached 
Sworn to before me and signed in my presence. 
Date: 
City and state:  New York, NY 
Applicant's signature 
) is requested 
pi 
Printed nanteeiditi le 00 u 
ast 
JudgCs-stgaffir 
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Cott, United. otatkaagistra,teW
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•--irrett'SN 
EFTA00247152

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 six binders with various CDs 
TO BE FILED UNDER SEAL 
Agent Affidavit in Support of 
Application for Search and Seizure 
Warrant 
SOUTHERN DISTRICT OF NEW YORK) ss.: 
S
ing duly sworn, deposes and says: 
I. Introduction 
A. Affiant 
1. 
I have been a Task Force Officer with the Federal Bureau of Investigation ("FBP") 
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 am also a detective 
with the New York Police Department ("NYPD") and have been employed by the NYPD for 
approximately thirteen years. I am currently assigned to investigate violations of criminal law 
relating to the'sexual exploitation of children as part of an FBI Task Force. 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 participated in the execution of search warrants for electronic devices and electronic storage 
media. 
2. 
I make this Affidavit in support of an application pursuant to Rule 41 of the Federal 
Rules of Criminal Procedure for a wan-ant to search certain electronic devices, compact disks and 
related electronic media specified below (the "Subject Items") for the items and information 
1 
2017.08.02 
EFTA00247153

described in Attachment A. This affidavit is based upon my personal knowledge; my review of 
documents and other evidence; my conversations with other law enforcement personnel; and my 
training, experience and advice received concerning the use of computers in criminal activity and 
the forensic analysis of electronically stored information ("ESP'). Because this 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 Items 
3. 
The. Subject Items are particularly described as follows': 
a. 
Two blue binders with CDs, which were seized by Special Agent M
,
_from 
a blue suitcase on or about July 11, 2019 ("Subject Item-1"). 
b. 
Three blue binders with various CDs and one clear binder with a green spine 
with various CDs, all four of which were seized by Special Agent 
_horn 
a black 
suitcase on or about July 11, 2019 ("Subject Item-2"). 
4. 
The Subject Items are all presently located in the Southern District of New York. 
C. The Target Subjects and the Subject Offenses 
5. 
For the reasons detailed below, I believe that there is probable cause to believe that 
the Subject Device contains evidence, fruits, and instrumentalities of violations of Title 18, United 
States Code, Sections 1591 (sex trafficking of minors), and 371 (sex trafficking conspiracy) (the 
To the extent that the Subject Items contain any removable storage media, including CDs, the 
description of each such item encompasses those other media. 
2 
2017.08.02 
EFTA00247154

S. 
"Subject Offenses"). The Target Subjects of this investigation are known and unknown co-
conspirators of JEFFREY EPSTEIN, including but not limited tici 
II. Probable Cause 
A. Probable Cause Regarding the 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. EPSTEIN was arrested pursuant to the 
Indictment on or about July.6, 2019, and had been detained pending trial at the Metropolitan 
Correctional Center ("MCC") in New York, New York. 
7. 
On or about August 10, 2019, the Bureau of Prisons confirmed that JEFFREY 
EPSTEIN had been found unresponsive in his cell at the MCC that morning, and was pronounced 
dead shortly thereafter. 
8. 
Notwithstanding EPSTEIN's death, the sex trafficking investigation that led to his 
indictment remains ongoing. In particular, Count One of the Indictment alleged that EPSTEIN 
conspired with others to traffic minors, and further identified three individuals who worked for 
EPSTEIN (identified in Exhibit A as "Employee-1", "Employee-2," and "Employee-3") and 
facilitated EPSTEIN's at?use of minor girls by, among other things, arranging victims' encounters 
with EPSTEIN and paying victims after these encounters. The individual identified in Exhibit A 
is "Employee-2" is 
, a Target Subject of this investigation. 
9. 
On or about November 28, 2018, the Miami Herald began publishing a series of 
articles relating to the defendant, his sexual misconduct with minors, and a previous investigation 
into his conduct in Florida from in or about 2005 through 2008. The article included information 
about 
role in EPSTEIN's sexual abuse of minors. Based on my participation 
in this investigation, I have learned that bank records obtained by the Government appear to show 
2017.08.02 
EFTA00247155

that just days later, on or about December 3, 2018, the defendant wired $250,000 from a trust 
account to a 
This course of action, and in particular its timing, suggests. that EPSTEIN 
was attempting to influence 
who might have been able to provide information against 
him in light of the recently re-emerging allegations. 
B. Probable Cause Justifying Search of the Subject Items 
The Indictment and Victim-1 
10. 
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 a multi-story, single-family residence located at 9 East 71st Street, New 
York, New York, which is described in Exhibit A as "the New York Residence." 
11. 
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 New York Residence. In particular, and as alleged in the Indictment, when a 
victim arrived at the New York Residence, 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 
EPSTEIN typically 
would also 
FolloWing each 
encounter, EPSTEIN or one of his employees or associates paid the victim in cash. 
4 
2017.08.02 
EFTA00247156

12. 
As set forth in paragraphs 12 through 13 of Exhibit A, to further facilitate his ability 
to abuse minor girls in New York, JEFFREY EPSTEIN asked and enticed certain of his victims to 
recruit additional minor girls to perform "massages" and similarly engage in sex acts with 
EPSTEIN. When a victim would recruit another minor girl for EPSTEIN, he paid both the victim-
recruiter and the new victim hundreds of dollars in cash. EPSTEIN knew that his victims were 
underage, including because certain victims told him their age. 
13. 
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 and I have interviewed 
Victim-1.2 During those interviews, Victim-1 has said, in substance and in part, that EPSTEIN 
sexually abused Victim-1 on multiple occasions between approximately 2002 and 2005 in the New 
York Residence. This sexual abuse all occurred when Victim-1 was under the age of 18. 
The July 6.2019 and July 7.2019 Search Warrants for the New York Residence 
14. 
On or about July 6, 2019, the Honorable Barbara Moses, United States Magistrate 
Judge, signed a search warrant authorizing a search of the New York Residence. The search 
warrant is attached as Exhibit B and incorporated by reference herein. 
15. 
At approximately 6 p.m. on or about July 6, 2019, law enforcement officers (the 
"Search Team") commenced executing the search warrant at the New York Residence. 
2 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. 
5 
2017.08.02 
EFTA00247157

16. 
Based on the Search Team's observations during an initial search of the New York 
Residence, at approximately 7 pan., the Search Team stopped the search and froze the scene in 
order to seek a new search warrant. 
17. 
On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate 
Judge, signed a second search warrant authorizing a search of the New York Residence (the 
"Second Warrant"). The Second Warrant is attached as Exhibit C, 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. 
18. 
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 New York Residence. 
b. Inside a safe in a closet on the third floor (the "Safe"), 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 
labeled ` 
and 
" Another disc is labeled "Nudes 00-24." Another is 
labeled "Misc. Nudes." Yet another is labeled "Girl Pics Nude." Some discs contain the word 
"Zorro" or "LS.J." For example, one disc is marked (IM Zorro Pies." Based on my 
conversations with law enforcement agents who have participated in this investigation, I believe 
the name "Zorro" refers to Zorro Ranch, EPSTEIN's property in New Mexico, and the name LSJ 
refers to Little Saint James, EPSTEIN's property in the U.S. Virgin Islands. The majority of the 
discs contain titles that include female names. Some of the discs in the binders seized by the 
Search Team have titles that appear to refer to trips or vacations. 
6 
2017.08.02 
EFTA00247158

c. At the time of the search, the Search Team did not seize certain binders of discs 
located in the Safe, where the majority of the discs in the binder were labeled in a manner that did 
not appear to refer to girls or nudes. The Search Team also did not seize at that time several 
unlabeled hard drives, which were also located in the Safe. As detailed below, those additional 
. binders of discs are among the subjects of this application. 
d. In addition to the Safe, in the drawer of a dresser in a room on the Fifth floor of the 
New York Residence, the Search team discovered and seized, among other items, a shoebox (the 
"Shoebox") which contained numerous compact discs. The majority of the discs are labeled, in 
handwriting, with female names. One disc is labeled "Thai Massage." Mother disc is labeled 
"Blonde Girl Photo Shoot." Yet another disc is labeled "Misc. Girls Nude/Dinner—Scientists." 
The discs in the Shoebox were seized by the Search Team. In another drawer of that same dresser, 
the Search Team discovered loose polaroid photographs depicting young, nude females who, based 
on 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 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 also contained 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 ". 
at LIS 6/03" (the "Elise"), which was seized by the Search Team. 
e. In a closet on the Fifth Floor of the New York 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 labeled "nudes 00-24." Mother is labeled Thotographera '03" The remaining 
7 
2017.08.02 
EFTA00247159

discs contain titles that include female names. All of the foregoing discs were seized by the Search 
Team. 
f. 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, at least some of the young girls depicted in the photographs appear 
to be teenagers, including some who appear to be under the age of 18. The Seized Binders also 
include photographs of what appear to be personal functions, events, and travel. 
g. The compact discs seized by the Search Team and described in paragraphs 16(a)-(d) 
are currently stored within the Southern District of New York in containers marked for 
identification with FBI evidence numbers 15, 16, 17, 18, and 22 (the "Seized Discs"). 
 
The-Julv-7,201-9-Seareh-Wanant-for-the-Seized-Discs 
19. 
On or about July 7, 2019, the Honorable Barbara Moses, United States Magistrate 
Judge, signed a third search warrant to search and seize electronic media stored on the Seized Discs 
(the "Third Search Warrant"). The Third Warrant is attached as Exhibit D, and incorporated by 
reference herein. 
20. 
Based on my conversations with law enforcement agents who have reviewed the 
Seized Discs pursuant to the Third Search Warrant (the "Reviewing Agents"), I have learned the 
following: 
3 The Search Team did not seize the remaining binders. 
8 
2017.08.02 
EFTA00247160

C • 
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 labeled "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-I's counsel that Individual-1 recalls the month and year during which she 
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.' 
21. 
In addition, I have learned that some of the file names are marked." which are 
the initials of 
reported that 
photos may have been taken by 
. As set forth below, I have interviewed an individual who has 
photographed her. Accordingly, I believe that a portion of these 
4 A preliminary review of the metadata from these photographs has been inconclusive. In 
particular, some of die photographs of Individual-1 contain metadata suggesting the photographs 
were taken on a date when Individual-1 would have been 18 years old. Other photographs of 
Individual-1, which appear based on Individual-I's appearance and surroundings to have been 
taken around the same time, contain metadata suggesting the photographs were taken on a date 
when Individual-1 would have been 15 years old. 
9 
2017.08.02 
EFTA00247161

22. 
Among the photographs seized from the New York Residence, the Reviewing 
Agents identified partially-nude photographs of a young girl, labeled with die name of a particular 
individual ("Individual-1"). In or about August 2019, I participated in an interview of Individual-
1, with her counsel present. Based on my personal observations, I believe that the photographs 
described in Paragraph 20(b) depict Individual-1. I have also spoken with another law enforcement 
agent who interviewed Individual-1 on a separate occasion in or about July 2019, with her counsel 
present. During the course of these interviews, Individual-1 stated, in sum an substance that she 
met EPSTEIN in 2003 when she was approximately 17, and that she travelled to several of 
EPSTEIN's properties before she turned 18. EPSTEIN paid for the trips, and would give 
Individual-1 money and gifts while she traveled with him. During these trips, EPSTEIN sexually 
abused and assaulted Individual-1 on approximately four different occasions, all of which occurred 
before she turned 18. Individual- I reported that EPSTEIN raped her during two of these incidents. 
Individual-1 further reported that, when she was approximately 17, 
asked to 
photograph her, and did in fact photograph Individual-1. 
The July 11, 2019 Search Warrant for All Electronic Devices and Storage Media in the 
New York Residence 
23. 
Following the initiation of the FBI's review of the Seized Discs, on or about July 
11, 2019, the Honorable Henry B. Pitman, United States Magistrate Judge, signed another search 
warrant authorizing another search of the New York Residence and specifically authorizing the 
seizure and search of all electronic devices and storage media inside the New York Residence (the 
"Fourth Warrant"). The Fourth Warrant is attached as Exhibit E and incorporated by reference 
herein. 
24. 
Later on July 11, 2019, the Search Team executed the Fourth Warrant at the New 
York Residence. 
10 
2017.08.02 
EFTA00247162

25. 
Based on my conversations with members of the Search Team, I have learned the 
following, among other things, regarding the execution of the Fourth Warrant: 
a. 
During the July 11, 2019 execution of the Fourth Warrant inside the New 
York Residence, the Search Team found that the Safe described above was empty and, in 
particular, that the collection of discs and hard drives described in paragraph 16(b), above, that the 
Search Team had not seized during its prior search of the New York Residence on July 7, 2019, 
had been removed. 
b. 
After discovering that the Safe was empty, the Search Team spoke with an 
employee who worked at the New York Residence (the "Employee"). During that conversation, 
the Employee told the Search Team that after the completion of the prior search on July 7, 2019, 
the Employee had been instructed by a third party ("the Third Party") to take the contents of the 
Safe out of the New York Residence and deliver those items to the Third Party. The Employee 
further told the Search Team that after receiving that instruction, the Employee packed the contents 
of the Safe into two suitcases and delivered those suitcases to the Third Party. The Employee 
provided the Search Team with the Third Party's contact information. 
c. 
The Search Team then contacted the Third Party. During the ensuing 
conversation, the Third Party confirmed receipt of two suitcases from the Employee but also told 
the Search Team that the Third Party had not opened the suitcases or touched or tampered with 
their contents. The Third Party also agreed to deliver the two suitcases to the Search Team. 
d. 
Later on July 11, 2019, and consistent with the conversation described 
above, the Third Party met the Search Team outside of the New York Residence and provided 
Special Agent 
with the two suitcases described above, one of which was blue and 
one of which was black. Consistent with standard law enforcement protocol, the Search Team 
11 
2017.08.02 
EFTA00247163

conducted an inventory of both suitcases before taking custody of them. While taking an inventory 
of the blue suitcase, the Search Team discovered, among other items, Subject Item-1. While taking 
an inventory of the black suitcase, the Search Team discovered, among other items, Subject Item-
2. These items, i.e., Subject Items -1, and -2, appeared to be the same items observed in the Safe 
by the Search Team during the July 7, 2019 search of the New York Residence. 
The July 15, 2019 Search Warrant for Certain Items Located Inside the Blue and Black 
Suitcases 
26. 
On or about July 15, 2019, the Honorable Kevin Nathaniel Fox, United States 
Magistrate Judge, signed a search warrant authorizing the search of several items, including items 
recovered from the black and blue suitcases seized by Special Agent 
on or about 
July 11, 2019 (the "Fifth Warrant"). The Fifth Warrant is attached as Exhibit F and incorporated 
by reference herein. 
27. 
In support of the Government's request for the Fifth Warrant, a Special Agent of 
the FBI submitted an affidavit in which she described some of the contents of the black and blue 
suitcases seized by Special Agent 
on or about July 11, 2019. Before submitting 
that affidavit, that agent had not personally reviewed the contents of those suitcases; rather, those 
descriptions were based on her conversations with other FBI agents who had seized the suitcases. 
Based on those conversations with other agents, she requested that the Fifth Warrant authorize the 
search of, among other items, (a) two black binders with CDs, which were seized by Special Agent 
from a blue suitcase on or about July 11, 2019, and (b) two binders with various 
CDs, which were seized by Special Agent 
from a black suitcase on or about July 
11, 2019. The Fifth Warrant authorized the search of those specific items. 
28. 
After the Fifth Warrant was issued, other law enforcement agents retrieved some 
of the items listed in the Fifth Warrant from the blue and black suitcases, which were and remain 
12 
2017.08.02 
EFTA00247164

in FBI custody in the Southern District of New York. Those other agents initiated searches of 
certain items inside the two suitcases, including of Subject Item-1. 
29. 
Subsequently, I personally inspected the contents of these suitcases, and realized 
that there had been a miscommunication about the color and quantity of the binders of CDs in each 
suitcase. In particular, the blue suitcase in fact contained two blue binders with CDs (defined 
herein as Subject Item-1), not two black binders. Additionally, the black suitcase in fact contained 
a total of four binders with CDs, three of which are blue and one of which is clear with a green 
spine, (defined herein as Subject Item-2), not two binders. 
30. 
In light of these discrepancies, the FBI ceased its search of Subject Item-1 and never 
initiated a search of Subject Item-2. Accordingly, I now respectfully request a warrant authorizing 
a search of the binders that are in fact located inside the two suitcases, which have been identified 
as Subject Item-1 and Subject Item-2 herein. 
Request to Search the Subject Items 
31. 
Based on my training and experience and .participation in this investigation, I 
respectfully submit that there is probable cause to believe that the Subject Items will contain and/or 
constitute additional fruits, evidence and instrumentalities of the Subject Offenses. As an initial 
matter, all of the Subject Items were originally found in the same Safe in which EPSTEIN was 
storing discs and other media already reviewed and which contain hundreds of not thousands of 
nude and suggestive images of young females, some of whom appear to be under 18. Given as 
much, and because there is probable cause to believe that EPSTEIN and his co-conspirators, 
including 
engaged in sex trafficking of underage girls, there is probable cause 
to believe that the additional storage media in EPSTEIN' s possession and control—Le., the Subject 
Items-Lwill contain evidence of the Subject Offenses. Moreover, that efforts were made to remove 
13 
2017.01:02 
EFTA00247165

Subject Items -1 and -2 from the New York Residence after the initial search only further reinforces 
the probable cause to believe that those Subject Items contain and constitute fruits, evidence and 
instrumentalities of the Subject Offenses. 
32. 
I further know from my training and experience that computer files or remnants of • 
such files can be recovered months or even years after they have been created or saved on an 
electronic device such as the Subject Items. Even when such files have been deleted, they can 
often be recovered, depending on how the device has subsequently been used, months or years 
later with forensics tools. Thus, the ability to retrieve from information from the Subject Items 
depends less on when the information was first created or saved than on a particular user's device 
configuration, storage capacity, and computer habits. 
33. 
Based on the foregoing, I respectfully submit there is probable cause to believe that 
evidence of JEFFREY EPSTElN's commission of the Subject Offences is likely to be found on 
the Subject Items. 
III. Procedures for Searching ESI 
A. Review of ESI 
34. 
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 Items for information responsive to the 
warrant. 
35. 
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: 
14 
2017.08.02 
EFTA00247166

• 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. 
36. 
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 Items to evaluate its contents and to locate all data responsive to the warrant. 
B. Return of the Subject Items 
37. 
If the Government determines that the Subject Items are no longer necessary to 
retrieve and preserve the data on the Subject Items, and that the Subject Items are not subject to 
seizure pursuant to Federal Rule of Criminal Procedure 41(c), the Government will return the.
Subject 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 
s 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. 
15 
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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 
38. 
Based on the foregoing, I respectfully request the court to issue a warrant to seize 
the items and information specified in Attaclunent A to this affidavit and to the Search and Seizure 
Warrant. 
39. 
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 to before me on 
September i Z- 2019 
S L. COTS 
STATES MAOIS,TRATE JUDGE 
Task Force Officer 
Federal Bureau of Investigation 
; • 
• -t• - • 
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Attachment A 
I. Items Subject to Search and Seizure 
The Subject Items are particularly described as follows: 
a. 
Two blue binders with CDs, which were seized by Special Agent 
a
from a blue suitcase on or about July 11, 2019 ("Subject Item-I"). 
b. 
Three blue binders with various CDs and one clear binder with a green spine 
with various CDs, all four of which were seized by Special Agent 
from a black 
suitcase on or about July 11, 2019 ("Subject Item-2"). 
II. Review of ESI on the Subject Items 
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 Items for evidence, fruits, and 
instrumentalities of violations of Title 18, United States Code, Sections 1591 (sex trafficking of 
minors), and 371 (sex trafficking conspiracy) (the "Subject Offenses") described as follows: 
1. 
Any documents or communications with or regarding victims or potential victims 
of the Subject Offenses; 
2. 
Any photographs of victims or potential victims of the Subject Offenses; 
3. 
Any nude, partially nude, or sexually suggestive photographs of individuals who 
appear to be teenage girls, or younger; 
4. 
Records, data, or other items that evidence ownership, control, or use of, or access 
to the Subject Items, including, but not limited to access history data, historical location data, 
configuration files, saved usemames and passwords, user profiles, e-mail contacts, and 
photographs; 
5. 
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). 
To the extent that the Subject Items contain any removable storage media, including CDs, the 
description of each such item encompasses those other media. 
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In conducting this review, law enforcement personnel may use various techniques to 
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such 
techniques may include, for example: 
• 
surveying directories or folders and the individual files they contain (analogous to 
looking at the outside of a file cabinet for the markings it contains and opening a drawer 
believed to contain pertinent files); 
• conducting a file-by-file review by "opening" or reading the first few "pages" of such 
files in order to determine their precise contents (analogous to performing a cursory 
examination of each document in a file cabinet to determine its relevance); 
• 
"scanning" storage areas to discover and possibly recover recently deleted data or 
deliberately hidden files; and 
• 
performing electronic keyword searches through all electronic storage areas to 
determine the existence and location of data potentially related to the subject matter of 
the investigation; and 
• 
reviewing metadata, system information, configuration files, registry data, and any 
other information reflecting how, when, and by whom the computer was used. 
Law enforcement personnel will make reasonable efforts to search only for files, 
documents, or other electronically stored information within the categories identified in Section II
of this Attachment. However, law enforcement personnel are authorized to conduct a complete 
review of all the ESI from seized devices or storage media if necessary to evaluate its contents and 
to locate all data responsive to the warrant. 
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