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a. Target Cellphone-1 has been active within the last 30 days. b. Target Cellphone-1 has been in contact with a phone subscribed to in the name of "Joshua Perry," which I know from my review of a law enforcement database is the name of the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Ph
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
a. Target Cellphone-1 has been active within the last 30 days. b. Target Cellphone-1 has been in contact with a phone subscribed to in the name of "Joshua Perry," which I know from my review of a law enforcement database is the name of the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Ph
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
a. Target Cellphone-1 has been active within the last 30 days. b. Target Cellphone-1 has been in contact with a phone subscribed to in the name of "Joshua Perry," which I know from my review of a law enforcement database is the name of the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Ph
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
a. Target Cellphone-1 has been active within the last 30 days. b. Target Cellphone-1 has been in contact with a phone subscribed to in the name of "Joshua Perry," which I know from my review of a law enforcement database is the name of the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Ph
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 →a. Target Cellphone-1 has been active within the last 30 days. b. Target Cellphone-1 has been in contact with a phone subscribed to in the name of "Joshua Perry," which I know from my review of a law enforcement database is the name of the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Ph
Page: EFTA00026504 →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 →a. Target Cellphone-1 has been active within the last 30 days. b. Target Cellphone-1 has been in contact with a phone subscribed to in the name of "Joshua Perry," which I know from my review of a law enforcement database is the name of the husband of a former employee of Jeffrey Epstein (the "Joshua Perry Ph
Page: EFTA00016359 →Entities connected to both Joshua Perry and the Prospective Location Information

Ghislaine Maxwell
PERSONIsabel Maxwell
PERSONColleen McMahon
PERSONFBI
ORGANIZATIONLisa Margaret Smith
PERSONScott Borgerson
PERSON
Target
ORGANIZATIONLaura Menninger
PERSON
T-Mobile
ORGANIZATION
Audrey Strauss
PERSON
Jeffrey Epstein
PERSONthe Service Providers'
ORGANIZATIONHaddon, Morgan, & Foreman
ORGANIZATIONPrecision Location Capability
ORGANIZATION
United States
LOCATIONthe Southern District
LOCATIONHaddon
PERSONB. Historical Location Information
ORGANIZATIONthe Pen Register Information
ORGANIZATIONFederal Rule of Criminal
ORGANIZATION