AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant
UNITED STATES DISTRICT COURT
for the
Southern District of New York
In the Matter of the Search of
(Briefly describe the property to be searched
or identify the person by name and address)
See Attachment A
19 MAG 6439
Case No. 19 Cr. 490 (RMB)
SEARCH AND SEIZURE WARRANT
To: Any authorized law enforcement officer
An application by a federal law enforcement officer or an attorney for the government requests the search
of the following person or property located in the Southern District of New York
(Identify the person or describe the property to be searched and give its location):
See Attachment A
The person or property to be searched, described above, is believed to conceal (identify the person or describe the property
to be seized):
See Attachment A
The search and seizure are related to violation(s) of (insert statutory citations):
Title 18, United States Code, Sections 371 and 1591
I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or
property.
YOU ARE COMMANDED to execute this warrant on or before July 12, 2019
(not to exceed 14 days)
[x] in the daytime 6:00 a.m. to 10 p.m.
[ ] at any time in the day or night as I find reasonable cause has been established.
Unless delayed notice is authorized below, you must give a copy of the warrant and a receipt for the property
taken to the person from whom, or from whose premises, the property was taken, or leave the copy and receipt at the
place where the property was taken.
The officer executing this warrant, or an officer present during the execution of the warrant, must prepare an
inventory as required by law and promptly return this warrant and inventory to the Clerk of the Court.
[ ] Upon its return, this warrant and inventory should be filed under seal by the Clerk of the Court.
USMJ Initials
[ ] I find that immediate notification may have an adverse result listed in 18 U.S.C. § 2705 (except for delay
of trial), and authorize the officer executing this warrant to delay notice to the person who, or whose property, will be
searched or seized (check the appropriate box)
[ ] for ___ days (not to exceed 30).
[ ] until, the facts justifying, the later specific date of
Date and time issued: 7/11/19
S/Henry Pitman
Judge's signature
City and state: New York, NY
Hon. Henry Pitman, U.S. Magistrate Judge
Printed name and title
EFTA00018425
AO 93 (SDNY Rev. 01/17) Search and Seizure Warrant (Page 2)
Return
Case No.: Date and time warrant executed: Copy of warrant and inventory left with:
Inventory made in the presence of :
Inventory of the property taken and name of any person(s) seized:
Certification
I declare under penalty of perjury that this inventory is correct and was returned along with the original warrant
to the Court.
Date:
Executing officer's signature
Printed name and title
EFTA00018426
ATTACHMENT A
I. Premises to be Searched—Subject Premises
1. The premises to be searched (the “Subject Premises”) are described as a multi-story
single-family residence located at 9 East 71st Street, New York, New York, and include all locked
and closed containers found therein. A photograph of the front entrance to the Subject Premises
is included below:
[Image: Photograph of building facade with Google watermark]
II. Items to Be Seized
A. Evidence, Fruits, and Instrumentalities of the Subject Offenses
This warrant authorizes the seizure of certain evidence, fruits, and instrumentalities of
violations of Title 18, United States Code, Sections 1591 (sex trafficking of minors), and 371 (sex
trafficking conspiracy) (the “Subject Offenses”) described as follows:
The items to be seized from the Subject Premises are any computer devices and storage
media that may contain any electronically stored information falling within the categories set forth
in Section B of this Attachment, including, but not limited to, desktop and laptop computers, disk
drives, modems, thumb drives, personal digital assistants, smart phones, digital cameras, scanners,
routers, modems, and network equipment used to connect to the Internet. In lieu of seizing any
such computer devices or storage media, this warrant also authorizes, in the alternative, the
copying of such devices or media for later review.
The items to be seized from the Subject Premises also include:
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EFTA00018427
1. Any items or records needed to access the data stored on any seized or copied
computer devices or storage media, including but not limited to any physical keys, encryption
devices, or records of login credentials, passwords, private encryption keys, or similar information.
2. Any items or records that may facilitate a forensic examination of the computer
devices or storage media, including any hardware or software manuals or other information
concerning the configuration of the seized or copied computer devices or storage media.
3. Any evidence concerning the identities or locations of those persons with access to,
control over, or ownership of the seized or copied computer devices or storage media.
B. Search and Seizure of Electronically Stored Information
As set forth in Section A to this attachment, this warrant authorizes the search of the Subject
Premises for any computer devices and storage media that may contain any electronically stored
information falling within the categories set forth below:
4. Any documents or communications with or regarding victims or potential victims
of the Subject Offenses;
5. Any photographs of victims or potential victims of the Subject Offenses;
6. Any nude, partially nude, or sexually suggestive photographs of individuals who
appear to be teenage girls, or younger;
7. Records or other items that evidence ownership, control, or use of, or access to
devices, storage media, and related electronic equipment used to access, transmit, or store
information relating to the Subject Offenses, including, but not limited to, sales receipts,
warranties, bills for Internet access, handwritten notes, registry entries, configuration files, saved
usernames and passwords, user profiles, e-mail contacts, and photographs;
8. Any child erotica, defined as suggestive visual depictions of nude minors that do
not constitute child pornography as defined by 18 U.S.C. § 2256(8).
C. Review of ESI
Law enforcement personnel (including, in addition to law enforcement officers and agents,
and depending on the nature of the ESI and the status of the investigation and related proceedings,
attorneys for the government, attorney support staff, agency personnel assisting the government in
this investigation, and outside technical experts under government control) will create a forensic
image of the Subject Devices (if practicable) and review the ESI contained therein for information
responsive to the warrant, that is, for the materials specified in Section B of this Attachment.
In conducting this review, law enforcement personnel may use various techniques to
determine which files or other ESI contain evidence or fruits of the Subject Offenses. Such
techniques may include, for example:
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• surveying directories or folders and the individual files they contain (analogous to
looking at the outside of a file cabinet for the markings it contains and opening a drawer
believed to contain pertinent files);
• conducting a file-by-file review by “opening” or reading the first few “pages” of such
files in order to determine their precise contents (analogous to performing a cursory
examination of each document in a file cabinet to determine its relevance);
• “scanning” storage areas to discover and possibly recover recently deleted data or
deliberately hidden files; and
• performing electronic keyword searches through all electronic storage areas to
determine the existence and location of data potentially related to the subject matter of
the investigation6; and
• reviewing metadata, system information, configuration files, registry data, and any
other information reflecting how, when, and by whom the computer was used.
Law enforcement personnel will make reasonable efforts to search only for files,
documents, or other electronically stored information within the categories identified in Section
II.A of this Attachment. However, law enforcement personnel are authorized to conduct a
complete review of all the ESI from seized devices or storage media if necessary to evaluate its
contents and to locate all data responsive to the warrant.
6 Keyword searches alone are typically inadequate to detect all relevant data. For one thing,
keyword searches work only for text data, yet many types of files, such as images and videos, do
not store data as searchable text. Moreover, even as to text data, there may be information properly
subject to seizure but that is not captured by a keyword search because the information does not
contain the keywords being searched.
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