AO 106A (08/18) Application for a Warrant by Telephone or Other Reliable Electronic Means # UNITED STATES DISTRICT COURT for the District of New Hampshire In the Matter of the Search of (Briefly describe the property to be searched or identify the person by name and address) The Premises Known and Described as 338 East Washington Road, Bradford, New Hampshire 03221 Case No. ## APPLICATION FOR A WARRANT BY TELEPHONE OR OTHER RELIABLE ELECTRONIC MEANS 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 (identify the person or describe the property to be searched and give its location): Please see attached Affidavit and Attachment A. located in the District of New Hampshire , there is now concealed (identify the person or describe the property to be seized): Please see attached Affidavit and Attachment A. The basis for the search under Fed. R. Crim. P. 41(c) is (check one or more): □ evidence of a crime; contraband, fruits of crime, or other items illegally possessed; property designed for use, intended for use, or used in committing a crime; a person to be arrested or a person who is unlawfully restrained. The search is related to a violation of: Code Section 18 U.S.C. 371 Offense Description 18 U.S.C. 2422, 2423(a) conspiracy to entice minors and transport minors enticement of a minor, and transportation of a minor 18 U.S.C. 1623 perjury The application is based on these facts: Please see attached Affidavit. Continued on the attached sheet. Delayed notice of 30 days (give exact ending date if more than 30 days: ___) is requested under 18 U.S.C. § 3103a, the basis of which is set forth on the attached sheet. Applicant’s signature , Special Agent, FBI Printed name and title Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephonic means (specify reliable electronic means). Date: 07/02/2020 City and state: Concord, NH Judge's signature Hon. Andrea K. Johnstone, U.S. Magistrate Judge Print Printed name and title Save As... Attach Reset EFTA00099530 # 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 338 East Washington Road, Bradford, New Hampshire 03221 ## TO BE FILED UNDER SEAL Agent Affidavit in Support of Application for Search Warrant SOUTHERN DISTRICT OF NEW YORK) ss.: , 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. During that time, I have participated in numerous investigations and prosecutions of crimes against children, including the sexual abuse of minors. I have also participated in the execution of multiple search warrants. 2. I make this Affidavit in support of an application pursuant to Rule 41 of the Federal Rules of Criminal Procedure for a warrant to search the premises specified below (the “Subject Premises”) for the purpose of locating GHISLAINE MAXWELL, who is a person to be arrested pursuant to an arrest warrant issued by a United States Magistrate Judge sitting in the Southern District of New York. 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 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. 2017.08.02 1 EFTA00099531 ## B. The Subject Premises 3. The Subject Premises are particularly described as a 156-acre property located at 338 East Washington Road, Bradford, New Hampshire 03221 and containing three separate structures: a main residence, a guesthouse, and a garage. As detailed further herein, GHISLAINE MAXWELL, a Target Subject of this investigation, is believed to be currently present within the Subject Premises. An aerial photograph depicting all three of the structures of the Subject Premises is included below: Two photographs of the front of the main residence of the Subject Premises from two different angles are included below: 2017.08.02 2 EFTA00099532 A photograph of the guesthouse of the Subject Premises is included below: 2017.08.02 3 EFTA00099533 ## C. The Target Subject and the Subject Offenses 4. The Target Subject of this investigation is GHISLAINE MAXWELL. 5. On June 29, 2020, a grand jury in the Southern District of New York returned an indictment charging GHISLAINE MAXWELL with violations of 18 U.S.C. § 371 (conspiracy to entice minors to travel to engage in illegal sex acts); 18 U.S.C. § 2422 (enticement of a minor to travel to engage in illegal sex acts); 18 U.S.C. § 371 (conspiracy to transport minors with intent to engage in criminal sexual activity); 18 U.S.C. § 2423(a) (transportation of a minor with intent to engage in criminal sexual activity); and 18 U.S.C. § 1623 (perjury) (collectively, the “Subject Offenses”). The Indictment charging MAXWELL is attached as Exhibit A hereto (the “Indictment”). 6. Also on June 29, 2020, United States Magistrate Judge Lisa Margaret Smith signed a warrant for GHISLAINE MAXWELL’s arrest, which is attached as Exhibit B hereto (the “Arrest 2017.08.02 4 EFTA00099534 Warrant"). Accordingly, I respectfully submit that there is probable cause to believe that MAXWELL is a “person to be arrested” within the meaning of Federal Rule of Criminal Procedure 41(c)(4). 7. For the reasons detailed below, I respectfully submit that there is probable cause to believe that GHISLAINE MAXWELL will be found within the Subject Premises. ## II. Probable Cause ## A. Probable Cause Regarding the Target Subject’s Commission of the Subject Offenses 8. As set forth in paragraph 5 above, a grand jury sitting in the Southern District of New York has returned an indictment charging the Target Subject with the Subject Offenses. ## B. Probable Cause Justifying Search of the Subject Premises 9. As detailed herein, and notwithstanding the efforts of GHISLAINE MAXWELL described below to evade detection since the arrest in July 2019 of her co-conspirator, Jeffrey Epstein, I and other agents have been able to identify a cellphone used by MAXWELL that, as specified below, is presently located in or around the Subject Premises. In particular, as detailed herein, a cell-site simulator placed the cellphone used by MAXWELL at the Subject Premises at approximately 7:36 AM on July 2, 2020, and cell site data similarly confirms that the cellphone used by MAXWELL has been in the vicinity of the Subject Premises on a regular basis for at least the last 30 days. 10. Based on my participation in the investigation, I know that since the arrest of GHISLAINE MAXWELL’s co-conspirator, Jeffrey Epstein, in July 2019, MAXWELL has intentionally sought to evade detection. For example, since that time, MAXWELL has avoided public appearances, has moved at least twice, has stopped using a cellphone associated with her at the time of Epstein’s arrest and started using a new cellphone registered simply in the name “G 2017.08.02 5 | EFTA00099535 | | :--- | :--- Max,” (described herein as the “Target Cellphone”), has ordered packages from her Amazon account to be delivered to her under the name of another person, and has intentionally stayed out of public view. I further know that, since approximately July 2019, MAXWELL has been aware that she is the subject of an ongoing criminal investigation into her relationship with Epstein and her role in facilitating his abuse of minor girls. 11. Based on my review of Customs and Border Patrol records, I know that GHISLAINE MAXWELL is a United States citizen and that she most recently entered the United States in or about June of 2019. There is no record of MAXWELL leaving the United States since her arrival in June of 2019. 12. Based on my review of records, and as noted above, I have learned that the cellphone with phone number (the “Target Cellphone”) is subscribed in the name of “,” which appears to be a shortened version of GHISLAINE MAXWELL’s name. The Target Cellphone is presently active. 13. On or about June 30, 2020, United States Magistrate Judge Katharine H. Parker, signed a warrant for cellphone location information for the Target Cellphone (the “Cell Site Warrant”), which is attached as Exhibit C, after finding probable cause to believe that GHISLAINE MAXWELL is presently using the Target Cellphone. Pursuant to the Cell Site Warrant, the FBI has received GPS location data for the Target Cellphone since approximately 10:15 PM on June 30, 2020 and has also received historical cell site data for the Target Cellphone for the period June 1, 2020 to June 30, 2020. As detailed further below, data obtained pursuant to the Cell Site Warrant confirms that MAXWELL is presently in the general location of the Subject Premises and has remained in that area consistently for at least the past 30 days. 2017.08.02 6 EFTA00099536 14. On July 1, 2020, United States Magistrate Judge Andrea K. Johnstone signed a warrant for the use of a cell-site simulator for the Target Cellphone (the “Cell-Site Simulator Warrant”), which is attached as Exhibit D, after also finding probable cause to believe that MAXWELL is presently using the Target Cellphone. A copy of the application in support of that Cell-Site Simulator Warrant, which sets forth in greater detail the probable cause to believe MAXWELL is using the Target Cellphone, is attached as Exhibit E. 15. Pursuant to the Cell-Site Simulator Warrant, the Target Cellphone was found to be at the Subject Premises on July 2, 2020 at approximately 7:36 AM. 16. I know from my review of records and my conversations with other law enforcement agents that the GPS location and cell site data collected pursuant to the Cell Site Warrant revealed the following: a. GPS location data, also known as precision location information, provides relatively precise location information about a cellphone, which a provider can typically collect either via GPS tracking technology built into the phone or by triangulating the device’s signal as received by the provider’s nearby cell towers. Cell site data, by contrast, reflects only the cell tower and sector thereof utilized in routing any communication to and from the cellphone, as well as the approximate range of the cellphone from the tower during the communication (sometimes referred to as “per-call measurement” (“PCM”) or “round-trip time” (“RTT”) data). Because cell towers are often a half-mile or more apart, even in urban areas, and can be ten or more miles apart in rural areas, cell site data is helpful but typically less precise than precision location information. b. Through the Cell Site Warrant, law enforcement was able to obtain cell site data for the Target Cellphone. While less precise than a cell-site simulator, consistent with the current location obtained pursuant to the Cell-Site Simulator Warrant as detailed in paragraph 15, 2017.08.02 7 | EFTA00099537 | | :--- | :--- above, I am aware that the cell site data for the Target Cellphone reveals that it has been located in and around Bradford, New Hampshire for at least the past 30 days. More specifically, I am aware that during that same period, the Target Cellphone has regularly connected with a cell tower that covers an area that includes the Subject Premises (the “Subject Premises Cell Tower”.) c. Cell site data further indicates that The Target Cellphone has been within the vicinity of the Subject Premises Cell Tower as recently as within the last approximately 24 hours. 17. In addition to the cell-site simulator data, which has confirmed that the Target Cellphone was at the Subject Premises on the morning of July 2, 2020, and the Cell Site Data confirming that the Target Cellphone has been in the vicinity of the Subject Premises for at least the past 30 days, I know based on my review of property records and my conversations with other law enforcement agents the following: a. Although there are multiple residences, including the Subject Premises, within the vicinity of the Subject Premises Cell Tower, with the exception of the Subject Premises, all of the other residences in that area are owned in the names of individuals or in the names of identified family trusts. By contrast, the Subject Premises is the only property within the vicinity of the Subject Premises Cell Tower that is owned by an entity. In particular, the Subject Premises is owned by an entity called Granite Realty LLC, a name seemingly designed to obscure the true identity of its owner. b. On or about December 13,2019, Granite Realty LLC purchased the Subject Premises for $1,070,000 in an all cash sale. 18. Based on the above, I respectfully submit that there is probable cause to believe that GHISLAINE MAXWELL is currently located within the Subject Premises. In particular, 2017.08.02 8 | EFTA00099538 | | :--- | :--- | This is a simple Markdown document with no headings or paragraphs. It contains just one line of text. the fact that the cell-site simulator confirmed the Target Cellphone was located in the Subject Premises at approximately 7:36 AM this morning and that cell site data confirmed that the Target Cellphone has been located in the vicinity of the Subject Premises on a regular basis for the past 30 days, makes it likely that MAXWELL is currently in the Subject Premises with her phone. Moreover, although there are multiple residences located within the range of the Subject Premises Cell Tower, the Subject Premises is the only residence located within that area that is owned in the name of an anonymous entity, which is consistent with MAXWELL’s extensive efforts, described above, to remain anonymous after the arrest of her co-conspirator, Jeffrey Epstein. ## III. Conclusion and Ancillary Provisions 19. Based on the foregoing, I respectfully submit that there is probable cause to believe that GHISLAINE MAXWELL is a person to be arrested for the Subject Offenses and that she is currently located at the Subject Premises. I therefore respectfully request the court to issue a warrant to search for the individual specified in Attachment A to this affidavit and to the Search and Seizure Warrant. The affiant appeared before me by telephonic conference on this date pursuant to Fed. R. Crim. P. 4.1 and affirmed under oath the content of this affidavit and application. Honorable Andrea K. Johnstone United States Magistrate Judge District of New Hampshire Dated: 2017.08.02 9 EFTA00099539 ## ATTACHMENT A ## I. Premises to be Searched—Subject Premises The Subject Premises are particularly described as a 156-acre property located at 338 East Washington Road, Bradford, New Hampshire 03221 and containing three separate structures: a main residence, a guesthouse, and a garage. As detailed further herein, GHISLAINE MAXWELL, a Target Subject of this investigation, is believed to be currently present inside the Subject Premises. An aerial photograph depicting all three of the structures of the Subject Premises is included below: 2017.08.02 EFTA00099540 Two photographs of the front of the main residence of the Subject Premises from two different angles are included below: 2017.08.02 2 EFTA00099541 A photograph of the guesthouse of the Subject Premises is included below: ## II. Person to Be Seized This warrant authorizes executing agents to search the Subject Premises for GHISLAINE MAXWELL, who is a person to be arrested for violations of 18 U.S.C. § 371 (conspiracy to entice minors to travel to engage in illegal sex acts); 18 U.S.C. § 2422 (enticement of a minor to travel to engage in illegal sex acts); 18 U.S.C. § 371 (conspiracy to transport minors with intent to engage in criminal sexual activity); 18 U.S.C. § 2423(a) (transportation of a minor with intent to engage in criminal sexual activity); and 18 U.S.C. § 1623 (perjury). 2017.08.02 3 EFTA00099542 # EXHIBIT A