U.S. Department of Justice¶
United States Attorney Southern District of New York¶
The Silvio J. Mollo Building¶
One Saint Andrew’s Plaza¶
New York, New York 10007¶
May 2, 2019¶
BY FAX¶
| Cellco Partnership d/b/a “Verizon Wireless” |
| Attn: Custodian of Records |
| 180 Washington Valley Road |
| Bedminster, NJ 07921 |
To whom it may concern:¶
Please be advised that the accompanying grand jury subpoena has been issued in connection with an official criminal investigation of a suspected felony being conducted by a federal grand jury. The Government hereby requests that you voluntarily refrain from disclosing the existence of the subpoena to any third party. While you are under no obligation to comply with our request, we are requesting you not to make any disclosure in order to preserve the confidentiality of the investigation and because disclosure of the existence of this investigation might interfere with and impede the investigation.¶
If you intend to disclose the existence of this Grand Jury Subpoena request to a third party, please let me know before making any such disclosure.¶
Thank you for your cooperation in this matter.¶
Sincerely,¶
GEOFFREY S. BERMAN¶
United States Attorney¶
By:¶
Assistant United States Attorney Telephone:¶
EFTA00151593¶
Grand Jury Subpoena¶
United States District Court¶
SOUTHERN DISTRICT OF NEW YORK¶
TO: Cellco Partnership d/b/a “Verizon Wireless”¶
Attn: Custodian of Records¶
180 Washington Valley Road¶
Bedminster, NJ 07921¶
GREETINGS:¶
WE COMMAND YOU that all and singular business and excuses being laid aside, you appear and attend before the GRAND JURY of the people of the United States for the Southern District of New York, at the United States Courthouse, 40 Foley Square, Room 220, in the Borough of Manhattan, City of New York, New York, in the Southern District of New York, at the following date, time and place:¶
Appearance Date: May 20, 2019¶
Appearance Time: 10:00 a.m.¶
to testify and give evidence in regard to an alleged violation of :¶
18 U.S.C. §§ 1591, 1594(c), 2422(b)¶
and not to depart the Grand Jury without leave thereof, or of the United States Attorney, and that you bring with you and produce at the above time and place the following:¶
See Attached Rider¶
Personal appearance is not required if the requested records are (1) produced by on or before the return date to Special Agent Child Exploitation and Human Trafficking Task Force, telephone: or via email at ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.¶
Failure to attend and produce any items hereby demanded will constitute contempt of court and will subject you to civil sanctions and criminal penalties, in addition to other penalties of the Law.¶
DATED: New York, New York May 2, 2019¶
GEOFFREY S. BERMAN¶
United States Attorney for the Southern District of New York¶
Assistant United States Attorney¶
One St. Andrew’s Plaza¶
New York, New York 10007¶
Telephone:¶
EFTA00151594¶
(Grand Jury Subpoena to Verizon Wireless, Dated May 2, 2019)¶
Please provide any and all records (including, but not limited to, incoming and outgoing calls with any call details, local and long distance usage details, all subscriber opening and/or registration documents, all subscriber identification and contact information, all subscriber billing and payment information, SMS/text messaging records, IP history and login records, associated email addresses and/or screen names, and any additional accounts associated with any of the below-listed phone number, relating to the following telephone numbers, as listed below, for the time period of January 1, 2003 through August 1, 2006:¶
N. B.: Personal appearance is not required if the requested records are (1) produced by on or before the return date to Special Agent Child Exploitation and Human Trafficking Task Force, telephone: or via email at ; and (2) accompanied by an executed copy of the attached Declaration of Custodian of Records. PLEASE PROVIDE IN ELECTRONIC FORMAT IF POSSIBLE.¶
IMPORTANT: REQUEST FOR NON-DISCLOSURE¶
Due to the ongoing nature of the investigation, it is requested that you do not disclose any information relating to this Grand Jury subpoena request to any third party.¶
EFTA00151595¶
Declaration of Custodian of Records¶
Pursuant to 28 U.S.C. § 1746, I, the undersigned, hereby declare:¶
My name is ___.¶
[name of declarant]¶
I am a United States citizen and I am over eighteen years of age. I am the custodian of records of the business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration.¶
I am in receipt of a Grand Jury Subpoena, dated May 2, 2019, and signed by Assistant United States Attorney Alison Moe, requesting specified records of the business named below. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, I hereby certify that the records provided herewith and in response to the Subpoena:¶
(1) were made at or near the time of the occurrence of the matters set forth in the records, by, or from information transmitted by, a person with knowledge of those matters;¶
(2) were kept in the course of regularly conducted business activity; and¶
(3) were made by the regularly conducted business activity as a regular practice.¶
I declare under penalty of perjury that the foregoing is true and correct.¶
Executed on ___.¶
[date]¶
(signature of declarant)¶
(name and title of declarant)¶
(name of business)¶
(business address)¶
Definitions of terms used above:¶
As defined in Fed. R. Evid. 803(6), “record” includes a memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses. The term, “business” as used in Fed. R. Evid. 803(6) and the above declaration includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for profit.¶
EFTA00151596¶