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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 Cellphone for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—
2 mentions1 same-page
Page ?Same page
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 Cellphone for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—
2 mentions1 same-page
Page ?Same page
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 Cellphone for the period from June I, 2020 to the present (the "Historical Location Information"). Because such data—like "Prospective Location Information"—
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Mutual Connections (34)
Entities connected to both the Prospective Location Information and the Target Cellphone
FBI
ORGANIZATION10 w/ the·5 w/ the
Target
ORGANIZATION10 w/ the·5 w/ the
LM
Laura Menninger
PERSON10 w/ the·4 w/ the
Ghislaine Maxwell
PERSON10 w/ the·4 w/ the
CM
Colleen McMahon
PERSON10 w/ the·4 w/ the
LS
Lisa Margaret Smith
PERSON10 w/ the·3 w/ the
SB
Scott Borgerson
PERSON10 w/ the·3 w/ the
IM
Isabel Maxwell
PERSON10 w/ the·3 w/ the
the Southern District
LOCATION7 w/ the·5 w/ the
Haddon, Morgan, & Foreman
ORGANIZATION8 w/ the·4 w/ the
Audrey Strauss
PERSON8 w/ the·4 w/ the
KJ
Kaplan, J.
PERSON7 w/ the·4 w/ the
United States
LOCATION7 w/ the·4 w/ the
HA
Haddon
PERSON7 w/ the·4 w/ the
Federal Rule of Criminal
ORGANIZATION7 w/ the·4 w/ the
FBI Task Force
ORGANIZATION7 w/ the·4 w/ the
Precision Location Capability
ORGANIZATION7 w/ the·4 w/ the
GPS data
ORGANIZATION7 w/ the·4 w/ the
Morgan, & Foreman Phone
ORGANIZATION7 w/ the·4 w/ the
Sealing
ORGANIZATION6 w/ the·5 w/ the