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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
ations of the Subject Offenses by the Target Subject. B. Historical Location Information 6. The Government also seeks historical cell site data for the Target Cellphone for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—
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
ations of the Subject Offenses by the Target Subject. B. Historical Location Information 6. The Government also seeks historical cell site data for the Target Cellphone for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—
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
ations of the Subject Offenses by the Target Subject. B. Historical Location Information 6. The Government also seeks historical cell site data for the Target Cellphone for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—
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
arget Cellphone. With respect to the prospective location information and pen register, that warrant expired on November 27, 2020. The subscriber of the Target Cellphone is the defendant in this case, who was indicted on November 19, 2020. The defendant, however, is currently in the Dominican Republic. Accordingly,
Entities connected to both Colleen McMahon and the Target Cellphone

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATION
George W. Bush
PERSON
Audrey Strauss
PERSONLaura Menninger
PERSON
Target
ORGANIZATIONHaddon
PERSONthe Prospective Location Information
ORGANIZATIONIsabel Maxwell
PERSONLisa Margaret Smith
PERSONScott Borgerson
PERSONPrecision Location Capability
ORGANIZATIONSealing
ORGANIZATIONHaddon, Morgan, & Foreman
ORGANIZATIONKaplan, J.
PERSONthe Pen Register Information
ORGANIZATIONGPS data
ORGANIZATION