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tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
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
tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
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
tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
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
tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
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
tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
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
tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
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
tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
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: EFTA00026495 →acking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5-'1'6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
Page: EFTA00026496 →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 →acking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5-'1'6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
Page: EFTA00016351 →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 →tracking device" for purposes of Rule 41 where used to collect location data); In re Application, 2009 WL 159187, at *5 *6 (S.D.N.Y. Jan.13, 2009) (McMahon, J.) (same). 3 See 18 U.S.C. § 3121 (prohibiting use of pen register or trap and trace device without an order under the pen register statute); 312
Page: EFTA00020374 →Entities connected to both Colleen McMahon and the Prospective Location Information

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATIONLaura Menninger
PERSON
Audrey Strauss
PERSON
Target
ORGANIZATIONScott Borgerson
PERSONIsabel Maxwell
PERSONLisa Margaret Smith
PERSONHaddon
PERSON
Kaplan
PERSONHaddon, Morgan, & Foreman
ORGANIZATIONGPS data
ORGANIZATIONPrecision Location Capability
ORGANIZATIONthe Pen Register Information
ORGANIZATIONKaplan, J.
PERSOND. Sealing
PERSONDistrict Court for the Southern District of New York
ORGANIZATION