EFTA01265487.pdf

Google
Google LLC
1600 Amphitheatre Parkway
Mountain View, California 94043 www.google.com
12/30/19
Assistant U.S. Attorney
USAO
1 St. Andrew's Plaza
New York, NY 10007
Re: Grand Jury Subpoena dated October 23, 2019 (Google Ref. No. 3011708)
Dear Assistant U.S. Attorney
Pursuant to the Grand Jury Subpoena issued in the above-referenced matter, we have
conducted a diligent search for documents and information accessible on Google's systems that
are responsive to your request. Our response is made in accordance with state and federal law,
including the Electronic Communications Privacy Act. See 18 U.S.C. § 2701 et seq.
Accompanying this letter is responsive information to the extent reasonably accessible
from our system associated with the Google account(s),
as specified in the Grand Jury Subpoena. We have
also included a signed Certificate of Authenticity which includes a list of hash values that
correspond to each file contained in the production. Google may not retain a copy of this
production but does endeavor to keep a list of the files and their respective hash values. To the
extent any document provided herein contains information exceeding the scope of your request,
protected from disclosure or otherwise not subject to production, if at all, we have redacted such
information or removed such data fields.
After a dill ent search and reasonable in ui , we have found no records for the sign-in
phone number(s) S The primary account identifier for most
Google services is an email address, not a phone number.
Google objects and has not produced records associated with Google accounts for which
you have not expressly provided an account identifier or which derive from records or other
information of the subject account(s) that you seek to have Google search. Because this exceeds
the scope of 18 U.S.C. § 2703(c)(2), Google requires a court order pursuant to 18 U.S.C. §
2703(d) based on specific and articulable facts showing that the account(s) linked by cookies or
other identifiers is relevant and material to your investigation for the duration of the time period
requested.
Please note that Google Pay service data is under the control of Google Payment
Corporation. Any request for such data must be specifically addressed to Google Payment
Corporation and can be served through the email address
For a Google Custodian of Records, we will require a subpoena and confirmation from
you of the time and date of the appearance, the scope of testimony, any Google Reference
CONFIDENTIAL SDNY_GM_00004773
EF1'A_00118846
EFTA01265487

Got gle
Google LLC
1600 Amphitheatre Parkway
Mountain View, California 94043 www.google.com
Number(s) associated with the case, and the travel for the appearance at least one week in
advance in order to identify, make the appropriate plans for, and prepare a custodian for trial.
Finally, in accordance with Section 2706 of the Electronic Communications Privacy Act,
Google may request reimbursement for reasonable costs incurred in processing your request.
Regards,
Google Legal Investigations Support
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EFTA01265488

Go gle
Google LLC
1600 Amphitheatre Parkway
Mountain View, California 94043 www.google.com
CERTIFICATE OF AUTHENTICITY
I hereby certify:
1. I am authorized to submit this affidavit on behalf of Google LLC ("Google"), located in
Mountain View, California. I have personal knowledge of the following facts, except as noted,
and could testify competently thereto if called as a witness.
2. I am qualified to authenticate the records because I am familiar with how the records
were created, managed, stored and retrieved.
3. Google provides Internet-based services.
4. Attached is a true and correct copy of records pertaining to the Google account-holder(s)
identified with account(s),
with Google Ref. No. 3011708 ("Document"). Accompanying this Certificate
of Authenticity as Attachment A is a list of hash values corresponding to each file produced in
response to the Grand Jury Subpoena.
5. The Document is a record made and retained by Google. Google servers record this data
automatically at the time, or reasonably soon after, it is entered or transmitted by the user, and this
data is kept in the course of this regularly conducted activity and was made by regularly
conducted activity as a regular practice of Google.
6. The Document is a true duplicate of original records that were generated by Google's
electronic process or system that produces an accurate result. The accuracy of Google's
electronic process and system is regularly verified by Google.
7. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true
and correct to the best of my knowledge.
/s Date: 12/30/19
(Signature of Records Custodian)
(Name of Records Custodian)
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EFTA01265489

Go gle
Google LLC
1600 Amphitheatre Parkway
Mountain View, California 94043 www.google.com
Attachment A: Hash Values for Production Files (Google Ref. No. 3011708)
Accountlnfo.txt:
MD5- 2f1935f54b7c8b246547d566c1d3ed3a
SHA512-
14ef72f03645d4ed8f52eed5ef5a8a4bc0d464c19fd843faa505c3b2eee08dOad87e0bb37aba78b74e
d3d70b0249421c4913a8feellb32418eb8b70a853f5602
.AccountInfont:
MD5- b87e49d0e75a092a869179c2114fedc9
SHA512-
2df27e030822f30365c6f8fb4010e933f609abe8aOlcdde09e73a2800939a49a8e8cb2474a7ba0c2f5
ed2638efe0a6ccfe3b8339c29848914d891fed83c21277
CONFIDENTIAL SDNY_GM_00004776
EF1'A_00118849
EFTA01265490