Epstein Secrets

order the Service Providers to provide this data pursuant to a warrant 2 See In re Application, 460 F. Supp. 2d 448, 459-60 & n. 55 (S.D.N.Y. 2006) (Kaplan, J.) (cellphone location information falls within § 2703(c)(1)); accord, e.g., United States v. Caraballo, 963 F. Supp. 2d 341, 361 (D.Vt. 2013); I

falls within § 2703(c)(1)); accord, e.g., United States v. Caraballo, 963 F. Supp. 2d 341, 361 (D.Vt. 2013); In re Order, 632 F. Supp. 2d 202, 207 (E.D.N.Y. 2008); In re Application, 405 F. Supp. 2d 435, 444-45 (S.D.N.Y. 2005). But see In re Application, 849 F. Supp. 2d 526, 574 (D.Md. 2011) (rejecting

, in violation of 18 U.S.C. § 2423(a); and perjury, in violation of 18 U.S.C. § 1623 (the "Subject Offenses"). 8. On June 29, 2020, a grand jury in the Southern District of New York returned an indictment charging GHISLAINE MAXWELL with the Subject Offenses. The Indictment charging MAXWELL is attached as Exhibit A hereto (the "

on and Pen Register Information APPLICATION Mag. The United States of America, by its attorney, Audrey Strauss, Acting United States Attorney for the Southern District of New York, Assistant United States Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed Warrants and Orders for prospe

order the Service Providers to provide this data pursuant to a warrant 2 See In re Application, 460 F. Supp. 2d 448, 459-60 & n. 55 (S.D.N.Y. 2006) (Kaplan, J.) (cellphone location information falls within § 2703(c)(1)); accord, e.g., United States v. Caraballo, 963 F. Supp. 2d 341, 361 (D.Vt. 2013); I

falls within § 2703(c)(1)); accord, e.g., United States v. Caraballo, 963 F. Supp. 2d 341, 361 (D.Vt. 2013); In re Order, 632 F. Supp. 2d 202, 207 (E.D.N.Y. 2008); In re Application, 405 F. Supp. 2d 435, 444-45 (S.D.N.Y. 2005). But see In re Application, 849 F. Supp. 2d 526, 574 (D.Md. 2011) (rejecting

: Epstein Date: Sun, 24 Mar 2019 20:08:43 +0000 Importance: Normal Thanks, and sounds good. And IM and I chatted a bit about his conversation with Kaplan — M a let me know if/when you get back to her, and happy to circle up to talk further thereafter. From: Sent: Sunday, March 24, 2019 3:53 PM To:

arch 24, 2019 3:40 PM To: Cc: Subject: Epstein How did the rest of the trip go? Deputy Chief, Public Corruption Unit U.S. Attorney's Office for the Southern District of New York Tel. >; EFTA00015003

il and U.S. Mail Roberta A. Kaplan Ka Ian Hecker & Fink LLP New York, NY 10118 Re: Request for Information Relating to Jeffrey Epstein Dear Ms. Kaplan: I am the Assistant U.S. Attorney ("AUSA") who will be handling the request you discussed with AUSA for certain information relating to Jeffrey Ep

y v. Ragen, 340 U.S. 462 (1951); 28 C.F.R. § 16.21 et seq. The "proper official" in this case is Geoffrey S. Berman, the United States Attorney for the Southern District of New York. The Touhy regulations provide a set of procedures for the United States Attorney to follow when considering such requests. See 28 C.F.R. §§ 16.22(b

aplan Kaplan Hecker & Fink LLP 350 Fifth Avenue, Suite 7110 New York, NY 10118 Re: Request for Information Relating to Jeffrey Epstein Dear Ms. Kaplan: I am the Assistant U.S. Attorne ("AUSA") who will be handling the request you discussed with AUSA for certain information relating to Jeffrey Eps

d a chance to review this letter if you would like to discuss the issues herein further. Sincerely, GEOFFREY S. BERMAN United States Attorney for the Southern District of New York By: Assistant United States Attorne Telephone Facsimile: E-mail: EFTA00010332

or Cellphone Location and Pen Register Information The United States of America, by its attorney, Audrey Strauss, Acting United States Attorney for the Southern District of New York, Assistant United States Attorney, of counsel, respectfully requests that the Court issue the accompanying proposed Second Warrant and Order for p

order the Service Provider to provide this data pursuant to a warrant 2 See In re Application, 460 F. Supp. 2d 448, 459-60 & n. 55 (S.D.N.Y. 2006) (Kaplan, J.) (cellphone location information falls within § 2703(c)(1)); accord, e.g., United States v. Caraballo, 963 F. Supp. 2d 341, 361 (D.Vt. 2013); I