# 20 MAG 6216

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

In Re Grand Jury Subpoena to Amazon.com, Inc., dated June 12, 2020, USAO Reference No. 2018R01618

§ 2705(b)
Non-Disclosure Order
to Service Provider

SEALED

Upon the application of the United States pursuant to 18 U.S.C. § 2705(b):

1. The Court hereby determines that there is reason to believe that notification of the existence of the attached subpoena will result in one or more of the following consequences, namely, endangering the life or physical safety of an individual; flight from prosecution; destruction of or tampering with evidence; intimidation of potential witnesses; or otherwise seriously jeopardizing an investigation or unduly delaying a trial.

	- Accordingly, it is hereby ORDERED:

2. Amazon.com, Inc. (the "Service Provider") shall not, for a period of 365 days from the date of this Order (and any extensions thereof), disclose the existence of this Order or the attached subpoena, to the listed subscriber of the accounts referenced in the subpoena, or to any other person, except that the Service Provider may disclose the attached subpoena to an attorney for the Service Provider for the purpose of receiving legal advice.

# UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK (cont.)

3. This Order and the Application upon which it was granted are to be filed under seal until otherwise ordered by the Court, except that the Government may without further order provide copies of the Application and Order as need be to personnel assisting the Government in the investigation and prosecution of this matter, and disclose these materials as necessary to comply with discovery and disclosure obligations in any prosecutions related to this matter.

Dated: New York, New York

June 12, 2020

UNITED STATES MAGISTRATE JUDGE

EFTA00018308

Grand Jury Subpoena

# United States District Court
SOUTHERN DISTRICT OF NEW YORK

TO: Amazon.com, Inc.
Corporation Service Company
300 Deschutes Way SW, Suite 304
Tumwater, WA 98501
Attn: Legal Department - Subpoena

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: June 26, 2020

Appearance Time: 10:00 a.m.

to testify and give evidence in regard to an alleged violation of:

18 U.S.C. §§ 371, 1591, 1594(c), 2422(b), 2423(a)

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:

# United States District Court
SOUTHERN DISTRICT OF NEW YORK (cont.)

## 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

June 12, 2020

D
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York

Assistant United States Attorney

Telephone:

STATES DISTRIC
INITED S COUR
2
STRICT OF FOR THE EW YORK

EFTA00018309

# RIDER (Grand Jury Subpoena to Amazon.com, Inc., dated June 12, 2020)

A.

- Please provide records for all accounts associated with the

following

identifiers:

• Ghislaine Maxwell

	- Ghislaine Borgerson

Records should include, but are not limited to, the following:

	1. All subscriber identifying information, including, but not limited to:

		• name, username or other subscriber identity or number

			- address

			- primary and alternate telephone numbers and email addresses

		• date of birth

		• social security number

			- length of service

	2. Records of any IP addresses used by the subscriber during session times;

	3. Order history from December 1, 2019 to the present, including billing/shipping
information;

	4. Means and source of payment for services (including any credit card or bank account number); and

	5. Account notes and logs, including any customer-service communications or other correspondence with the subscriber.

C. Please provide records of all orders shipped to the following individuals, from December 1, 2019 to the present:

	• Ghislaine Maxwell

	• Ghislaine Borgerson

EFTA00018310

# 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 June 12, 2020, and signed by Assistant United States Attorney | , 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)

# Declaration of Custodian of Records (cont.)

## 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.

EFTA00018311