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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
has sent multiple packages within approximately the last year (the "Scott Borgerson Phone"). The most recent contact between Target Cellphone-1 and the Scott Borgerson Phone occurred in or about August 2019. 13. Accordingly, I respectfully submit there is probable cause to believe that the location of Target Cellphone-1
30 days, Target Cellphone-2 has been in contact with the Isabel Maxwell Phone, the Laura Menninger Phone, the Haddon, Morgan, & Foreman Phone, and the Scott Borgerson Phone. 15. Accordingly, I respectfully submit that there is probable cause to believe that the location of Target Cellphone-2 will reveal the location of
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
has sent multiple packages within approximately the last year (the "Scott Borgerson Phone"). The most recent contact between Target Cellphone-1 and the Scott Borgerson Phone occurred in or about August 2019. 13. Accordingly, I respectfully submit there is probable cause to believe that the location of Target Cellphone-1
30 days, Target Cellphone-2 has been in contact with the Isabel Maxwell Phone, the Laura Menninger Phone, the Haddon, Morgan, & Foreman Phone, and the Scott Borgerson Phone. 15. Accordingly, I respectfully submit that there is probable cause to believe that the location of Target Cellphone-2 will reveal the location of
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
has sent multiple packages within approximately the last year (the "Scott Borgerson Phone"). The most recent contact between Target Cellphone-1 and the Scott Borgerson Phone occurred in or about August 2019. 13. Accordingly, I respectfully submit there is probable cause to believe that the location of Target Cellphone-1
30 days, Target Cellphone-2 has been in contact with the Isabel Maxwell Phone, the Laura Menninger Phone, the Haddon, Morgan, & Foreman Phone, and the Scott Borgerson Phone. 15. Accordingly, I respectfully submit that there is probable cause to believe that the location of Target Cellphone-2 will reveal the location of
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
has sent multiple packages within approximately the last year (the "Scott Borgerson Phone"). The most recent contact between Target Cellphone-1 and the Scott Borgerson Phone occurred in or about August 2019. 13. Accordingly, I respectfully submit there is probable cause to believe that the location of Target Cellphone-1
30 days, Target Cellphone-2 has been in contact with the Isabel Maxwell Phone, the Laura Menninger Phone, the Haddon, Morgan, & Foreman Phone, and the Scott Borgerson Phone. 15. Accordingly, I respectfully submit that there is probable cause to believe that the location of Target Cellphone-2 will reveal the location of
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
ntact with a phone identified as the Scott Borgerson Phone within the last 30 days. In fact, the Target Cellphone was most recently in contact with the Scott Borgerson Phone in or about March 2020. The errors resulted from my misreading of certain phone records for the Target Cellphone. In particular, while one ' The or
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
ntact with a phone identified as the Scott Borgerson Phone within the last 30 days. In fact, the Target Cellphone was most recently in contact with the Scott Borgerson Phone in or about March 2020. The errors resulted from my misreading of certain phone records for the Target Cellphone. In particular, while one ' The or
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
ntact with a phone identified as the Scott Borgerson Phone within the last 30 days. In fact, the Target Cellphone was most recently in contact with the Scott Borgerson Phone in or about March 2020. The errors resulted from my misreading of certain phone records for the Target Cellphone. In particular, while one 1 The or
Entities connected to both Colleen McMahon and the Scott Borgerson Phone

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATIONLaura Menninger
PERSON
Audrey Strauss
PERSON
Target
ORGANIZATIONScott Borgerson
PERSONIsabel Maxwell
PERSONthe Prospective Location Information
ORGANIZATIONHaddon
PERSONLisa Margaret Smith
PERSONthe Pen Register Information
ORGANIZATIONKaplan, J.
PERSONGPS data
ORGANIZATIONHaddon, Morgan, & Foreman
ORGANIZATIONPrecision Location Capability
ORGANIZATIONFBI Task Force
ORGANIZATIONB. Historical Location Information
ORGANIZATION