Epstein Secrets

are the cellphone assigned call number ("Target Cellphone-1") and the cellphone assigned call number ("Target Cellphone-2," and collectively with Target Cellphone-1, the "Target Cellphones"). As further discussed below, Target Cellphone-1 is subscribed to in the name of "Terramar Project, Inc." 2 2

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

are the cellphone assigned call number ("Target Cellphone-1") and the cellphone assigned call number ("Target Cellphone-2," and collectively with Target Cellphone-1, the "Target Cellphones"). As further discussed below, Target Cellphone-1 is subscribed to in the name of "Terramar Project, Inc." 2 2

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

are the cellphone assigned call number ("Target Cellphone-1") and the cellphone assigned call number ("Target Cellphone-2," and collectively with Target Cellphone-1, the "Target Cellphones"). As further discussed below, Target Cellphone-1 is subscribed to in the name of "Terramar Project, Inc." 2 2

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

n also sought authorization for Cellphone Location and Pen Register information for a second Target Cellphone, 917-520-3106, which was identified as Target Cellphone-1 in that application and which was also granted on or about June 29, 2020. Because there were no errors in the application with respect

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

n also sought authorization for Cellphone Location and Pen Register information for a second Target Cellphone, 917-520-3106, which was identified as Target Cellphone-1 in that application and which was also granted on or about June 29, 2020. Because there were no errors in the application with respect

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

ed call number 917-520- 3106 ("Target Cellphone-1") and the cellphone assigned call number 978-525-8484 ("Target Cellphone-2," and collectively with Target Cellphone-1, the "Target Cellphones"). As further discussed below, Target Cellphone-1 is subscribed to in the name of "Terramar Project, Inc." 2 2

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

application also sought authorization for Cellphone Location and Pen Register information for a second Target Cellphone, , which was identified as Target Cellphone-1 in that application and which was also granted on or about June 29, 2020. Because there were no errors in the application with respect

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

the pen register statute, because such data constitutes signaling information used by the Service Providers to route communications to and from the Target Cellphones. In order to collect such data, a valid pen register order is required.3 Accordingly, I hereby certify pursuant to 18 U.S.C. § 3122 that

of other documents in the case, and information received from investigative personnel. 2. The Investigating Agency, Target Cellphones, Subscribers, Target Subject, Service Providers, Subject Offenses, Successor Service Provider, and Successor Cellphone referenced in this Application are as specified i

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

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

ns 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 Inf