UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF OHIO 

WESTERN DIVISION 

FILED 

TIME '(:1 ZPM 

NOV 2 8 2017 

RICHARD W. NAGEL 

Clerk of Court 

CINCINNATI, OHIO 

IN RE APPLICATION OF THE 

UNITED STATES OF AMERICA 

FOR AN ORDER PURSUANT TO 

CASENO. l 117M J •915 

18 U.S.C. § 2703(d) DIRECTING SPRINT TO 

PROVIDE HISTORICAL CELL SITE 

LOCATION RECORDS RELATED TO THE 

CELLULAR TELEPHONE IDENTIFIED BY 

CALL NUMBER 937-422-7413 

UNDER SEAL 

APPLICATION FOR COURT ORDER 

FOR DISCLOSURE OF HISTORICAL CELL-SITE RECORDS 

The United States of America, by and through its undersigned counsel, hereby moves this 

Court pursuant to 18 U.S.C. § 2703(c)-(d) for an order (1) requiring Sprint, an electronic 

communication service within the meaning of 18 U.S.C. § 2510(15), to disclose to the Department 

of Homeland Security, Homeland Security Investigations ("HSI"), all available subscriber and toll 

records to include call detail, SMS Detail, data sessions, per calf measurement data ("PCMD"), 

cell site and cell site sector information related to the use of a cellular telephone identified by the 

call number 937-422-7413 for the period from August 1, 2016 through the present; (2) precluding 

the provider of such service from disclosing to the subscriber or customers or to any other 

unauthorized person this request, any court order issued in connection with this request, the fact 

of disclosure of such records to the HSI or the existence ofthis investigation, pursuant to 18 U.S.C. 

§ 2705(b); and (3) sealing the government's application, the Court's order, and any related 

documents. 

In support of this application, the undersigned states as follows: 
1. The undersigned is an attorney for the government as defined by Rule 1 (b) of the 

Federal Rules of Criminal Procedure and, therefore, pursuant to 18 U.S.C. § 2703(c) may apply 

for an order as requested herein. 

2. The United States is investigating the production of child pornography. The 

investigation concerns possible violations of Title 18, United States Code, Section 2251. 

3. In or about May of2017, law enforcement obtained evidence of child 

pornography contained on JASON FLETCHER's phone. FLETCHER told law enforcement, in 

substance and in part, that (1) in or about September 2016, he made the child pornography videos 

with his cousin, CIERA RICHTER; (2) RICHTER provided the child used in the videos; and (3) 

RICHTER sold the child pornography videos to make money. 

4. The phone number associated with FLETCHER's phone is 937-422-7413. 

5. A records check conducted by law enforcement revealed that 93 7-422-7 413 is 

utilized by Sprint. 

6. Disclosure of this application, the Court's order, or the fact that the requested 

records have been produced to HSI may seriously jeopardize this pending criminal investigation. 

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7. WHEREFORE, applicant requests the Court to enter the attached Order (1) 

requiring Sprint to disclose to HSI all available toll records to include call detail, SMS Detail, data 

sessions, per call measurement data ("PCMD"), cell site and cell site sector information, including 

International Mobile Subscriber Identifier ("IMSI"), and/or International Mobile Station 

Equipment Identity (" IMEi") related to the use of the cellular telephone identified by the call 

number 937-422-7413 for the period from August 1, 2016 through the present; (2) precluding the 

provider of such service from disclosing to the subscriber or customers or to any other 

unauthorized person this request, any court order issued in connection with this request, the fact 

of disclosure of such records to the HSI or the existence of this investigation, pursuant to 18 U.S.C. 

§ 2705(b); and (3) sealing the government's application, the Court's Order and any related 

documents until otherwise ordered by the Court. 

Executed on November 28, 2017. 

3 

Respectfully submitted, 

BENJAMIN C. GLASSMAN 

United States Attorney 

s/Megan Gaffney 

MEGAN GAFFNEY 

Assistant United States Attorney 

221 East Fourth Street, Suite 400 

Cincinnati, Ohio 45202 

Office: (513) 684-3711 

Fax: (513) 684-6385 

E-mail: Megan.Gaffney@usdoj.gov