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e Isabel Maxwell Phone occurred in or about August 2019. e. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
e 41. See 18 U.S.C. § 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's request for a warrant to obtain the Prospective Location Information requested above also supports the issuance of a warrant under § 2703(c) for the requested Historical Location Information. In addition, the Governm
e Isabel Maxwell Phone occurred in or about August 2019. e. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
e 41. See 18 U.S.C. § 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's request for a warrant to obtain the Prospective Location Information requested above also supports the issuance of a warrant under § 2703(c) for the requested Historical Location Information. In addition, the Governm
e Isabel Maxwell Phone occurred in or about August 2019. e. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
e 41. See 18 U.S.C. § 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's request for a warrant to obtain the Prospective Location Information requested above also supports the issuance of a warrant under § 2703(c) for the requested Historical Location Information. In addition, the Governm
& Foreman Phone occurred within the last 30 days. c. The Target Cellular Device has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
e 41. See 18 U.S.C. § 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's request for a warrant to obtain the Prospective Location Information requested above also supports the issuance of a warrant under § 2703(c) for the requested Historical Location Information. In addition, the Governm
& Foreman Phone occurred within the last 30 days. c. The Target Cellular Device has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
e 41. See 18 U.S.C. § 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's request for a warrant to obtain the Prospective Location Information requested above also supports the issuance of a warrant under § 2703(c) for the requested Historical Location Information. In addition, the Governm
e Isabel Maxwell Phone occurred in or about August 2019. e. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
e 41. See 18 U.S.C. § 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's request for a warrant to obtain the Prospective Location Information requested above also supports the issuance of a warrant under § 2703(c) for the requested Historical Location Information. In addition, the Governm
& Foreman Phone occurred within the last 30 days. c. The Target Cellular Device has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
e 41. See 18 U.S.C. § 2703(c)(1)(A). I respectfully submit that the same probable cause supporting the Government's request for a warrant to obtain the Prospective Location Information requested above also supports the issuance of a warrant under § 2703(c) for the requested Historical Location Information. In addition, the Governm
rder — the same period of time for which a warrant for a tracking device may be granted under Rule 41(e)(2)(C). It bears noting, however, that while the Prospective Location Information may permit "tracking" the user of the phone in the colloquial sense, this is not an application for a warrant for a "tracking device" as defined in
Page: EFTA00016350 →e Isabel Maxwell Phone occurred in or about August 2019. e. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
Page: EFTA00016360 →y represents GHISLAINE MAXWELL in civil litigation (the "Laura Menninger Phone"). The most recent contact between Target Cellphone-I and the Laura Menninger Phone occurred in or about August 2019. f. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Scott Borgerson,"
Page: EFTA00016360 →rder — the same period of time for which a warrant for a tracking device may be granted under Rule 41(e)(2)(C). It bears noting, however, that while the Prospective Location Information may permit "tracking" the user of the phone in the colloquial sense, this is not an application for a warrant for a "tracking device" as defined in
Page: EFTA00026495 →e Isabel Maxwell Phone occurred in or about August 2019. e. Target Cellphone-1 has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
Page: EFTA00026505 →rder — the same period of time for which a warrant for a tracking device may be granted under Rule 41(e)(2)(C). It bears noting, however, that while the Prospective Location Information may permit "tracking" the user of the phone in the colloquial sense, this is not an application for a warrant for a "tracking device" as defined in
Page: EFTA00020373 →& Foreman Phone occurred within the last 30 days. c. The Target Cellular Device has also been in contact with a phone subscribed to in the name of "Laura Menninger," which I know from my review of court records is the name of an attorney who currently represents GHISLAINE MAXWELL in civil litigation (the "Laura
Page: EFTA00020384 →Entities connected to both Laura Menninger and the Prospective Location Information

Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSONHaddon
PERSON
Audrey Strauss
PERSONthe Southern District
LOCATION
United States
LOCATIONFBI
ORGANIZATIONDistrict Court for the Southern District of New York
ORGANIZATIONColleen McMahon
PERSON
Target
ORGANIZATIONIsabel Maxwell
PERSONLisa Margaret Smith
PERSONScott Borgerson
PERSONGPS data
ORGANIZATIONHaddon, Morgan, & Foreman
ORGANIZATION
T-Mobile
ORGANIZATIONFBI Task Force
ORGANIZATIONFederal Rule of Criminal
ORGANIZATIONMorgan, & Foreman Phone
ORGANIZATIOND. Sealing
PERSON