Epstein Data Wiki

Grand jury subpoena to Google on the domain helpfulexperts.com, July 2017 (EFTA00153743)

Properties1
tagsdocument, subpoena, 2017, sdny, grand-jury, google, non-disclosure-order, draft

15 min read

CourtUnited States District Court, Southern District of New York1
Magistrate case number, hand-stamped on the page17MAG520712
USAO reference number2017R0055012
Docket numberPrinted and unfilled on both the application and the order12
Application affirmedNew York, New York, July 11, 20173
Non-disclosure order datedJUL 1 2 2017, over the s-signature “S/Andrew J. Peck”, United States Magistrate Judge2
Subpoena and covering letter datedJuly 13, 201745
Signature on the subpoena face pageA signature in the name of Joon H. Kim, written above a printed block whose first line reads “JOON H. KIM” and whose second reads “Acting United States Attorney for the Southern District of New York”5
Statutes named on the face page18 U.S.C. §§ 1341, 13435
AddresseeGoogle, Inc., Attn: Legal Department, Mountain View, California45
Appearance date demandedJuly 21, 2017, 10:00 a.m., United States Courthouse, 40 Foley Square, Room 2205
Non-disclosure period ordered180 days from the date of the order, extensions reserved2
Sheets in the filing96

On July 13, 2017 a grand jury subpoena issued out of the Southern District of New York demanding from Google, Inc. the records of every e-mail account on a single domain, helpfulexperts.com, and naming as the alleged violation 18 U.S.C. §§ 1341 and 1343, the mail-fraud and wire-fraud statutes.57 The day before, on July 12, 2017, a United States magistrate judge had signed an order forbidding Google to disclose the subpoena’s existence to the subscriber of the accounts it named, or to anyone else.2

All of it was released together as one nine-sheet filing in Data Set 9 of the Department of Justice’s Epstein release, under the document identifier EFTA00153743. The nine sheets hold four instruments: the sealed application for the non-disclosure order, the signed order granting it, a covering letter to Google’s legal department, and the subpoena itself with its rider, a further request for secrecy and a blank custodian-of-records declaration.13457892

Every sheet cited below was read from the scanned page image, at the full resolution the released file holds, which is 96 pixels to the inch.10 Where that scan and the machine-read text disagree, this page follows the scan and says so. The release gives each of the nine pages a label of its own, but those labels are not printed on the scans: each sits in the file’s text at the foot of its page, and at that position on the scan there is no ink at all. This page therefore cites the document and the page number as the served file itself paginates it, read at the image, and does not name a sheet by a label that does not appear on it.6

The three dates, in the order they were made

The filing records a sequence of three consecutive days, each on a different sheet.

The application is affirmed under 28 U.S.C. § 1746 by an Assistant United States Attorney, who states: “I am an Assistant United States Attorney in the Office of the United States Attorney for the Southern District of New York and am familiar with the investigation underlying this request.”1 Its closing sheet is dated New York, New York, July 11, 2017, and its paragraph 6 reads in full: “No prior request for the relief set forth herein has been made.”3

The order is dated by hand stamp JUL 1 2 2017, that is July 12, 2017, and carries the s-signature “S/Andrew J. Peck” above the printed title “UNITED STATES MAGISTRATE JUDGE” and a second printed block naming Andrew J. Peck, United States Magistrate Judge, Southern District of New York.2

The subpoena face page and the covering letter are both dated July 13, 2017.45 The face page carries a signature in the name of Joon H. Kim, written above a printed block whose first line reads “JOON H. KIM” and whose second reads “Acting United States Attorney for the Southern District of New York”. A separate printed line beneath it reads “Assistant United States Attorney”, with the office address at One St. Andrew’s Plaza.5 The covering letter is on the same office’s letterhead and is addressed to Google’s legal department, marked “BY EMAIL”.4

The face page names the appearance date as July 21, 2017.5 That date is what the subpoena demanded; this page does not report that any appearance or production occurred on it, and the filing does not say.

What the application asked the court to find

Paragraph 3 of the application sets out the five statutory grounds in 18 U.S.C. § 2705(b), as a numbered list.11 Paragraph 4 then applies them. Its opening sentence reads in full: “In this case, such an order would be appropriate because the attached subpoena relates to an ongoing criminal investigation that is neither public nor otherwise known to all targets of the investigation, the account holder is suspected of being involved in or associated with persons involved in the conduct under investigation, and disclosure of the subpoena to the account owner or to any other person may alert subjects or targets of the ongoing investigation.”11 The paragraph continues for three further sentences, which are not reproduced here.

The paragraph is the government’s assertion in support of an ex parte application. It is not a finding, and the document records no response to it from any other party.

What the order determined, and what it did not

The order’s paragraph 1 reads in full: “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.”2

The determination is disjunctive. The court found “one or more” of the five grounds and the order does not record which; the five are recited in the same sequence and the same words as the statutory list reproduced in the application.112

The operative paragraph follows, and reads in full: “Google, Inc. (the “Service Provider”) shall not, for a period of 180 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.”2 Paragraph 3 orders that the order and the application “are to be filed under seal until otherwise ordered by the Court”. That is a clause and not the whole sentence; it continues with exceptions for personnel assisting the government and for discovery obligations that are not reproduced here.2

Three separate non-disclosure instruments in one filing

Secrecy is imposed three times over, by three different mechanisms, each on its own sheet.

The order compels it, for 180 days.2 The covering letter restates the compulsion to Google and then adds a request that outlives it: “If you ever plan to notify the relevant subscriber(s) of the existence of this subpoena, even after the 180-day period, please advise me before you do so, in case the investigation remains ongoing and the order needs to be renewed.”4 And a separate sheet of the subpoena carries a heading in bold capitals, “IMPORTANT: REQUEST FOR NON-DISCLOSURE”, under which a single sentence asks for the same thing without any order behind it: “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.”8

The covering letter also carries a preservation directive the subpoena itself does not: “You are hereby directed to preserve, under the provisions of 18 U.S.C. § 2703(f)(1) any and all information, including, if applicable, all emails/attachments or other content information, as well as any backup copies of such data or data designated for deletion, pertaining to the domain(s) and account(s) referenced in the accompanying subpoena, for a period of 90 days.”4 The sentence is quoted as it is printed; the punctuation is the document’s.

The rider, and the domain

The face page commands production of “See Attached Rider” and names the offence as “an alleged violation of” 18 U.S.C. §§ 1341 and 1343, the mail-fraud and wire-fraud statutes.5

The rider is headed “RIDER (Grand Jury Subpoena to Google, Inc., dated July 13, 2017)” and opens with the words “Please provide all records for any accounts registered to or associated with the following identifiers”.7 A sub-bullet under that lead-in reads, as printed: “As well as any other accounts associated with the domain “helpfulexperts.com””. The inner double quotation marks are the rider’s own.7

Seven numbered demands follow. The first begins “All email accounts hosted by Google using the domain name “helpfulexperts.com”” and continues past that point; the continuation is not reproduced here.7 The second begins “All subscriber identifying information, including, but not limited to”, and runs to a lettered list of ten items covering the subscriber’s identity, contact and account details and the network and device information Google holds about them.7 The remaining five are for session times, durations and IP addresses; length and types of service; means and source of payment; account notes, logs and customer-service correspondence; and investigative files or user complaints concerning the subscriber, account or e-mail address.7

Two things follow from the rider’s own words and nothing else. The demand is addressed to a domain: the operative clause asks for accounts “associated with the domain”, and the first numbered demand asks for every Google-hosted mailbox on it.7 And every demand is a forward-looking obligation placed on Google. No return, production or response from Google appears on any of these nine sheets as released; what Google did with the subpoena is not recorded here.

The case number, measured

A search on 21 October 2026 of the machine-read text this project holds for the released files, each phrase taken exactly as written and in that order, returns:

phrase searchedreleased pagesdocuments
helpfulexperts11
2017R0055021
2018R01618794442

The index searched holds 2,925,025 pages across 1,425,556 documents, counted the same day. The one page carrying helpfulexperts is the rider; the two carrying 2017R00550 are the first sheet of the application and the order, which share a caption.12

Three limits on those figures, and each matters. The search runs against machine-read text and not against the pages themselves, so a page the machine read badly, or did not read at all, is invisible to it; and the index is this project’s, not the Department’s, so a figure of zero in it is a fact about the index and not about what the Department released. Every figure is a floor and not a total. The search ignores full stops, which means helpfulexperts also finds helpfulexperts.com and any address at that domain; a narrower search could have missed either form. And a count of documents is not a count of events, because a copy is not an occurrence.

The reference number on this filing is 2017R00550. A different reference number, 2018R01618, is the one carried by the sealed applications and orders set out at Unsealing Motions and Media Action, and it is the number that reaches 442 documents in the search above. What relation, if any, the matter opened under 2017R00550 bore to that one is not stated anywhere on these nine sheets, and this page does not supply one.

What this page is, and what it is not

This page covers one document. It does not cover the domain helpfulexperts.com beyond what this filing says about it, the registration history of that domain, any Google subpoena other than this one, or any return or production in response to any subpoena. It does not cover the question of when the Southern District’s investigation of Jeffrey Epstein began, which is not settled by this filing and is not addressed here.

Nothing on this page is a finding of wrongdoing, and no allegation is made here against anyone. A grand jury subpoena is an investigative demand, not an accusation, and naming a statute in the printed line “an alleged violation of” is not a charge. This filing is a demand and an order about disclosure; it charges no one.

No person is named here who is not named in print on the sheet cited for them. Where the released document does not show a name, this page does not supply it from the surrounding text, and does not describe, characterise or locate what any mark covers. Identity numbers, account numbers, dates of birth, telephone numbers, e-mail addresses and home addresses on the sheets cited here are not reproduced.

Every quotation above was read at the page image, and every cut is disclosed at the point it is made. Quotations introduced as reading “in full” reproduce a complete sentence or a complete printed line as the sheet carries it; the others are clauses, embedded as clauses in a sentence of this page’s own. The machine-read text of this document is damaged in several places: it renders “I am an” as “Ism an” on the first sheet, and on the rider it misreads the opening quotation mark before the domain. Nothing above is taken from it where the image disagrees.17

Footnotes

  1. Application for a § 2705(b) grand jury non-disclosure order to a service provider, In Re Grand Jury Subpoena to Google, Inc., 17MAG5207, USAO Reference No. 2017R00550 (S.D.N.Y.), first sheet of the nine. Read at the page image. https://epstein-data.com/EFTA00153743 p.1. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  2. 2705(b) non-disclosure order, In Re Grand Jury Subpoena to Google, Inc., 17MAG5207, USAO Reference No. 2017R00550 (S.D.N.Y.), marked SEALED, dated by hand stamp JUL 1 2 2017 over the s-signature “S/Andrew J. Peck”, United States Magistrate Judge, with a second printed signature block naming Andrew J. Peck. The final sheet. Read at the page image. https://epstein-data.com/EFTA00153743 p.9. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11 ↩12 ↩13

  3. The same application, third sheet, carrying paragraphs 5 and 6, the “WHEREFORE” clause, the date line and the printed page number “3”. Read at the page image. https://epstein-data.com/EFTA00153743 p.3. ↩ ↩2 ↩3

  4. Letter on United States Attorney, Southern District of New York letterhead to Google, Inc., Attn: Legal Department, marked “BY EMAIL”, July 13, 2017, fourth sheet. Read at the page image. https://epstein-data.com/EFTA00153743 p.4. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7

  5. Grand jury subpoena face page, Southern District of New York, dated New York, New York, July 13, 2017, fifth sheet, carrying the form revision mark “rev. 02.01.12”. Read at the page image. https://epstein-data.com/EFTA00153743 p.5. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9 ↩10 ↩11

  6. The released file carries a label of its own for each of its nine pages, right-aligned at the foot, running consecutively from the document’s own identifier, and reading the file’s text out returns all nine. They are not visible on the scans. Measured on the scanned images at their own resolution, the band at the foot of the page where each label sits is blank paper on seven of the nine pages: the lightest pixel in that band reads 253, 255, 255, 242, 232, 255 and 255 out of 255 on a scale where 0 is black. The two pages that do carry ink there carry other printed matter: the subpoena face page has the form’s revision mark, “rev. 02.01.12”, and the order has the foot of the judge’s printed signature block. On none of the nine is there a stamp. A control box over ordinary body text on the first page returns 4,068 pixels at or below 200 on the same scale. Because no Bates stamp is printed on these pages, every citation below names the document and the page as the served file paginates it, counting from one, and none names a page by a label of its own or by any number taken from a database. Measured 21 October 2026. ↩ ↩2

  7. Rider to the grand jury subpoena to Google, Inc. dated July 13, 2017, sixth sheet. Read at the page image. The machine-read text of this sheet renders the opening double quotation mark before the domain as a letter, and the sheet itself prints “acconts” for “accounts” in the first numbered demand; neither is corrected in any quotation above. https://epstein-data.com/EFTA00153743 p.6. ↩ ↩2 ↩3 ↩4 ↩5 ↩6 ↩7 ↩8 ↩9

  8. Notice sheet carrying the N.B. on personal appearance and the heading “IMPORTANT: REQUEST FOR NON-DISCLOSURE”, seventh sheet. Read at the page image. https://epstein-data.com/EFTA00153743 p.7. ↩ ↩2

  9. Declaration of Custodian of Records under 28 U.S.C. § 1746, a blank template with the declarant’s name, date, signature, title, business and business address all left as printed rules. The eighth sheet. Read at the page image. https://epstein-data.com/EFTA00153743 p.8. ↩

  10. The file served for this document is a nine-page PDF of 899,488 bytes, which is also the size this project’s index records for it. Each of its nine pages holds one grayscale raster of 817 × 1056 pixels at 96 × 96 pixels per inch, and the only text render mode present in the file is mode 3, the invisible overlay: the visible content of every sheet is the scan. Every sheet quoted above was read at that resolution and no further: none was enlarged, because enlarging a 96-pixel-per-inch scan invents apparent detail rather than revealing it. Measured 21 October 2026. ↩

  11. The same application, second sheet, carrying paragraphs 3 and 4 and the printed page number “2”. Read at the page image. https://epstein-data.com/EFTA00153743 p.2. ↩ ↩2 ↩3

  12. Counts taken 21 October 2026 against this project’s full-text index of the release, not against the Department’s own systems. Each phrase was matched whole and in order, with no wildcard and no partial-word matching. “Released pages” counts matching pages in that index; “documents” counts the distinct documents those pages belong to. The index held 2,925,025 pages across 1,425,556 documents when these counts were taken. A phrase that returns nothing there has not been shown absent from the release: only from the machine-read text this project holds. ↩

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