Epstein Secrets

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

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 Cellphones for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—

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

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 Cellphones for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—

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

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 Cellphones for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—

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

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 Cellphones for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—

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

vernment is also not seeking authorization to obtain post-cut-through dialed digits ("PCTDD"), or digits that are dialed after a telephone call from the Target Cellphones has been connected. Pursuant to the attached Order, if possible, the Service Provider will forward only pre- cut-through-dialed digits to the Invest