act in good faith you have to understand the context of the investigation it was a  because it was the government as every single almost every civil court has agreed with was ultimately illegal search the government did with the net was ultimately not valid and the only really remaining argument is that whether or not the government acted in good faith i'm arguing that the government  applying for the warrant did not act in good faith and the reason why i'll try and get you quickly which is that this was not an ordinary investigation they had buy in from the executives of the d o j it was an easy decision to host and distribute child pornography and the lead up to the to the investigation there was a manual that basically in two thousand and nine acted as a roadmap for exactly the legal issues that the court ultimately sad this is why then this we go was a two thousand and thirteen case in texas that was again a roadmap to the legal issues in this case that said than it was an authorized knowing all there was all of this also available to the old with yes but the older only focused on geographical issue is the words were relocated which is in a sub paragraph and then if you actually look at the face of the warrant the face of the warrant highlights that is eastern district of virginia where the search will happen and the words were relocated the only word that would give rise to the inference that this is going to be a search of computers all over the world is not even in the search warrant it's not in the face no warrant it's not in the attachment now this is the government buried the geographical issue another fact to highlight is that act doesn't allow this search to happen when it happens so it's an illegal search everyone has agreed with that or seem to for the sake of argument and then the or then if the agents are crafting a misleading application and trying to make a judge think the search is going to happen in these district of virginia when in fact it's happening wherever in unknown locations all over the world that's not going to face and leon talks exactly about about this issue about not wanting agents to mislead manager just thank you  algeria that actions taken by the government surrounding this more and more broadly demonstrate the sort of deliberate reckless or grossly negligent conduct that the exclusionary rule exists to deter eldred panel went into detail discussing how quote the affidavit facts that i am relying on but the only addressed one prong of leon really just one consideration of leon one public policy consideration and that was whether the warrant on its face an agent looking at it could circumstances that suggest that this was the case they intentionally the judges that they knew they had a geographical school official and they weren't forthcoming about it and you can actually use the other case in texas the two thousand and thirteen case in research or computers wherever located and in that case is in the exact language the government put in the search warrant and what they talk about in texas case is target computer and they talk about target's computers being located wherever but in this case the government didn't talk about targeting pewters they talk about the target web site in the eastern district of virginia so they shifted the whole focus to the statistical virginia to obscure the fact that this is actually a search of computers were located so looking at the circumstances surrounding the warrant application the lead up to it that what they knew who was involved the highest level of the d o j the remote operations unit who's the experts in this very esoteric unusual piece of technology that they knew they have legal issues with and they just they just b they bury the issue  participated in the application for the warrants and if having all these people involved who knew what about that there was an issue with the geographical scope of the w yeah i think the way the warrant was was drafted apply for a know what the government knew i think they were complicit in trying to hide the ball in trying to minimize that the opportunity for this magistrate judge to do what happened in texas we have in texas we had to do this over again are you going to politic consideration well that's position see you identified in the war initially only on is basically a policy sort of the calculus of whether it's worth  leader the lack of candor thank you very much