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UNITED STATES DISTRICT COURT 

 SOUTHERN DISTRICT OF FLORIDA 

 CASE NO. 22-mj-8489-BER 

IN RE: SEARCH WARRANT HIGHLY SENSITIVE DOCUMENT 

___________________________________/ 

 

SEALING ORDER 

 The United States of America, having applied to this Court for an Order sealing the Motion 

to Seal, the Search Warrant and all its accompanying documents, and this order and the Court 

finding good cause: 

IT IS HEREBY ORDERED that the Motion to Seal, the Search Warrant and its 

accompanying documents, and this Order shall be filed under seal until further order of this Court. 

However, the United States Attorney’s Office and the Federal Bureau of Investigation may obtain 

copies of any sealed document for purposes of executing the search warrant. 

DONE AND ORDERED in chambers at West Palm Beach, Florida, this _____day of 

October 2022 

 _________________________________________ 

 HON. BRUCE E. REINHART 

 UNITED STATES MAGISTRATE JUDGE 

TM Oct 27, 2022 West Palm Beach

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

IN RE: SEALED SEARCH WARRANT Case No. 22-mj-8489-BER 

Filed Under Seal 

APPLICATION FOR ORDER COMMANDING APPLE, INC. 

NOT TO NOTIFY ANY PERSON OF THE EXISTENCE OF SEARCH WARRANT 

 The United States respectfully requests that the Court order Apple, Inc. not to notify any 

person (including the subscribers or customers of the account listed in the search warrant) of the 

existence of the attached search warrant until further order of the Court. 

 Apple is a provider of an electronic communication service, as defined in 18 U.S.C. § 

2510(15), and/or a remote computer service, as defined in 18 U.S.C. § 2711(2). Pursuant to 18 

U.S.C. § 2703, the United States obtained the attached search warrant, which requires Apple to 

disclose certain records and information to the United States. This Court has authority under 18 

U.S.C. § 2705(b) to issue “an order commanding a provider of electronic communications service 

or remote computing service to whom a warrant, subpoena, or court order is directed, for such 

period as the court deems appropriate, not to notify any other person of the existence of the warrant, 

subpoena, or court order.” Id. 

 In this case, such an order would be appropriate because the attached search warrant relates 

to aspects of an ongoing criminal investigation that are neither public nor known to all of the 

targets of the investigation, and its disclosure may alert the targets to the ongoing investigation. 

Accordingly, there is reason to believe that notification of the existence of the attached search 

warrant will seriously jeopardize the investigation, by giving targets an opportunity to flee or 

continue flight from prosecution, destroy or tamper with evidence, change patterns of behavior, or 

notify confederates. See 18 U.S.C. § 2705(b)(2), (3), (5). Some of the evidence in this 

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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

IN RE: SEALED SEARCH WARRANT Case No. 22-mj-8489-BER 

Filed Under Seal 

ORDER 

The United States has submitted an application pursuant to 18 U.S.C. § 2705(b), requesting 

that the Court issue an Order commanding Apple, Inc., an electronic communications service 

provider and/or a remote computing service, not to notify any person (including the subscribers or 

customers of the account listed in the search warrant) of the existence of the attached search 

warrant until further order of the Court. 

 The Court determines that there is reason to believe that notification of the existence of the 

attached search warrant will seriously jeopardize the investigation, by giving targets an opportunity 

to flee or continue flight from prosecution, destroy or tamper with evidence, change patterns of 

behavior, or notify confederates. See 18 U.S.C. § 2705(b)(2), (3), (5). 

 IT IS THEREFORE ORDERED under 18 U.S.C. § 2705(b) that Apple shall not disclose 

the existence of the attached search warrant, or this Order of the Court, to the listed subscriber or 

to any other person, for a period of one year, except that Apple may disclose the attached search 

warrant to an attorney for Apple, for the purpose of receiving legal advice. 

 IT IS FURTHER ORDERED that the application and this Order are sealed until otherwise 

ordered by the Court. 

__________________ _________________________________________ 

Date HON. BRUCE E. REINHART 

 UNITED STATES MAGISTRATE JUDGE 

TM Oct 27, 2022 West Palm Beach

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3. The facts in this affidavit come from my personal observations, my training and 

experience, and information obtained from other agents and witnesses. This affidavit is intended 

to show that there is sufficient probable cause for the requested warrant and does not set forth all 

of my knowledge about this matter. 

4. Based on my training and experience and the facts as set forth in this affidavit, there 

is probable cause to believe that the TARGET ACCOUNT, as described in Attachment A, contains 

evidence of violations of 18 U.S.C. § 793(e) (willful retention of national defense information); 

18 U.S.C. § 2071 (concealment or removal of government records); 18 U.S.C § 1519 (obstruction 

of federal investigation), 18 U.S.C. § 1001 (material false statement); or 18 U.S.C. § 1623 

(perjury), as further described in Attachment B. 

JURISDICTION 

5. This Court has jurisdiction to issue the requested warrant because it is “a court of 

competent jurisdiction” as defined by 18 U.S.C. § 2711. 18 U.S.C. §§ 2703(a), (b)(1)(A), & 

(c)(1)(A). Specifically, the Court is “a district court of the United States . . . that has jurisdiction 

over the offense being investigated.” 18 U.S.C. § 2711(3)(A)(i).

PROBABLE CAUSE 

Background on Investigation

6. The FBI is investigating potential violations of 18 U.S.C. §§ 793(e), 2071, 1519, 

1001, and 1623 related to the improper removal and storage of classified national defense 

information in unauthorized spaces, as well as the unlawful concealment or removal of government 

records. 

7. This investigation began as a result of a referral that the United States National 

Archives and Records Administration (“NARA”) sent to the United States Department of Justice 

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(“DOJ”) on or about February 9, 2022 (hereinafter, the “NARA Referral”). The NARA Referral 

stated that on January 18, 2022, in accordance with the Presidential Records Act (“PRA”), NARA 

received from the office of former President Donald J. Trump (hereinafter “FPOTUS”), via 

representatives, fifteen (15) boxes of records (hereinafter, the “FIFTEEN BOXES”). The 

FIFTEEN BOXES, which had been transported from a property owned by FPOTUS at 1100 S. 

Ocean Blvd., Palm Beach, Florida, a residence and club known as “Mar-a-Lago,” were reported 

in the NARA Referral to contain, among other things, highly classified documents intermingled 

with other records. 

8. After an initial review of the NARA Referral, the FBI opened a criminal 

investigation to, among other things, identify any person(s) who may have removed or retained 

classified information without authorization and/or in an unauthorized space. The FBI’s 

investigation established that documents bearing classification markings, which appear to contain 

NDI, were among the materials contained in the FIFTEEN BOXES and were stored at Mar-a-Lago 

in an unauthorized location. 

9. As further described below, on May 11, 2022, the Department of Justice (“DOJ”) 

served a grand jury subpoena on counsel for the Office of the Former President (the “Office”) 

seeking “any and all documents . . . bearing classification markings” in FPOTUS’s and/or the 

Office’s possession. On June 3, 2022, FPOTUS’s counsel provided DOJ with a package of 37 

documents bearing classification markings at the Confidential, Secret, and Top Secret level. 

Counsel for FPOTUS provided DOJ with a written certification, signed by another person who 

was acting as the custodian of records on behalf of the Office for purposes of the subpoena, 

indicating that “a diligent search was conducted,” that the “search was conducted after receipt of 

the subpoena, in order to locate any and all documents that are responsive to the subpoena” seeking 

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all documents with classification markings in the custody or control of FPOTUS and/or the Office, 

and that “any and all responsive documents” were being provided. Counsel for FPOTUS indicated 

that all responsive documents had been located in one storage room located on the ground floor at 

Mar-a-Lago (hereinafter, “the storage room.”). 

10. After developing additional evidence that the June 3 production did not contain all 

of the documents with classification markings located at Mar-a-Lago, on August 8, 2022, the FBI 

executed a search and seizure warrant issued by a Magistrate Judge of the U.S. District Court for 

the Southern District of Florida. During the search, the FBI recovered from the storage room as 

well as FPOTUS’s office at Mar-a-Lago over 100 documents bearing classification markings, 

which had not been produced on June 3. The documents appeared to contain NDI. The search also 

yielded apparent government and/or Presidential records subject to the Presidential Records Act, 

44 U.S.C. § 2201. 

Background on NAUTA 

11. NAUTA began his career in the U.S. Navy 

NAUTA transitioned to work as a valet, 

or personal aide, for FPOTUS during FPOTUS’s Presidential Administration (hereinafter 

“Administration”). 

 In or around the summer of 2021, 

NAUTA retired from the military and went to work as a civilian for FPOTUS as his “body man” 

or assistant. According to publicly available information filed with the Federal Election 

Commission, the Save America PAC, a political action committee created by FPOTUS, paid 

NAUTA $149,167 between August 26, 2021 and August 30, 2022, which included $6,375 in 

“advance consulting” fees. 

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12. NAUTA was involved in at least two key movements of FPOTUS’s boxes at Mara-Lago: (1) in the weeks leading up to the provision of the FIFTEEN BOXES to NARA in January 

2022, NAUTA and two other FPOTUS employees brought, at FPOTUS’s request, the FIFTEEN 

BOXES from their location in a storage room at Mar-a-Lago to FPOTUS’s residential entryway at 

Mar-a-Lago for FPOTUS’s review; and (2) in the week before FPOTUS’s representatives claimed 

on June 3 that they had conducted a diligent search for classified documents, NAUTA moved 

approximately 64 boxes out of the storage room at Mar-a-Lago and returned only about 25-30 

prior to the review of the storage room for records responsive to the May 11 subpoena. 

 

13.

 

14.

 

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The door to the storage room was painted gold and had no other markings on 

it. 

18. In addition to the approximately eighty-five to ninety-five FPOTUS BOXES 

located in the storage room, there were also other boxes in the storage room with merchandise 

such as challenge coins, garment bags, memorabilia from Mar-a-Lago such as photograph frames, 

and other décor items. 

Provision of the Fifteen Boxes to NARA

19. Over the course of 2021, NARA endeavored to obtain what appeared to be missing 

records subject to the Presidential Records Act (PRA), 44 U.S.C. § 2201. On or about May 6, 2021, 

NARA made a request for the missing PRA records and continued to make requests until 

approximately late December 2021, when NARA was informed twelve boxes were found and 

ready for retrieval at Mar-a-Lago. 

20.

 

21. took a photograph of the storage room and provided it to FPOTUS 

sometime between January 1-17, 2022, to show FPOTUS the number of boxes that were in the 

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storage room. The storage photo, which appears below 

 captures approximately sixty-one of the FPOTUS BOXES located in the storage 

room: 

22.

23.

 

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24.

25.

26.

27.

28. From May 16-18, 2022, FBI agents conducted a preliminary review of the 

FIFTEEN BOXES provided to NARA and identified over 100 documents with classification 

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markings in fourteen of the FIFTEEN BOXES. Several of the documents also contained what 

appears to be FPOTUS’s handwritten notes. 

29. On May 11, 2022, an attorney representing FPOTUS, “FPOTUS COUNSEL 1,” 

agreed to accept service of a grand jury subpoena requesting “[a]ny and all documents or writings 

in the custody or control of Donald J. Trump and/or the Office of Donald J. Trump bearing 

classification markings.” The return date of the subpoena was May 24, 2022. 

30. After an extension was granted for compliance with the subpoena, on the evening 

of June 2, 2022, FPOTUS COUNSEL 1 contacted DOJ COUNSEL and requested that FBI agents 

meet him the following day to pick up responsive documents. On June 3, 2022, three FBI agents 

and DOJ COUNSEL arrived at Mar-a-Lago to accept receipt of the materials. In addition to 

FPOTUS COUNSEL 1, another individual, hereinafter “INDIVIDUAL 2,” was also present as the 

custodian of records for FPOTUS’s post-presidential office. The production included a single 

Redweld envelope, wrapped in tape, containing documents. FPOTUS COUNSEL 1 relayed that 

the documents in the Redweld envelope were found during a review of the boxes located in the 

storage room. INDIVIDUAL 2 provided a Certification Letter, signed by INDIVIDUAL 2, which 

stated the following: 

Based upon the information that has been provided to me, I am authorized to certify, on 

behalf of the Office of Donald J. Trump, the following: a. A diligent search was 

conducted of the boxes that were moved from the White House to Florida; b. This search 

was conducted after receipt of the subpoena, in order to locate any and all documents that 

are responsive to the subpoena; c. Any and all responsive documents accompany this 

certification; and d. No copy, written notation, or reproduction of any kind was retained 

as to any responsive document. 

Grand Jury Subpoena, Related Correspondence, and Production of Additional Classified 

Documents

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31. During receipt of the production, FPOTUS COUNSEL 1 stated he was advised all 

the records that came from the White House were stored in the storage room at Mar-a-Lago and 

the boxes of records in the storage room were “the remaining repository” of records from the White 

House. FPOTUS COUNSEL 1 further stated he was not advised there were any records in any 

private office space or other location in Mar-a-Lago. The agents and DOJ COUNSEL were 

permitted to see the storage room (although they were not permitted to look inside the boxes) and 

observed that approximately fifty to fifty-five boxes remained in the storage room. Considering 

that only FIFTEEN BOXES had been provided to NARA of the approximately eighty-five to 

ninety-five FPOTUS BOXES that had been located in the storage room, it appeared that 

approximately fifteen to thirty of the FPOTUS BOXES had previously been relocated elsewhere. 

The FBI agents also observed that the composition of boxes differed such that fewer Bankers boxes 

were visible, while more plain cardboard boxes and storage bins were present. Other items were 

also present in the storage room, including a coat rack with suit jackets, as well as interior décor 

items such as wall art and frames. 

32.

33. A review of the documents contained in the Redweld envelope produced pursuant 

to the grand jury subpoena revealed 37 unique documents bearing classification markings, some 

of which bore classification markings at the highest levels. Based on my training and experience, 

I know that documents classified at these levels typically contain NDI. Multiple documents also 

contained what appears to be FPOTUS’s handwritten notes. 

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34. When producing the documents, neither FPOTUS COUNSEL 1 nor INDIVIDUAL 

2 asserted that FPOTUS had declassified the documents.1

 The documents being in a Redweld 

envelope wrapped in tape appears to be consistent with an effort to handle the documents as if they 

were still classified.2

Surveillance Camera Footage Shows NAUTA removing boxes from the Storage Room Area 

Prior to FPOTUS Counsel 1’s Review in Connection with the Subpoena

35. On July 6, 2022, in response to a grand jury subpoena for surveillance video from 

internal cameras located on the ground floor (basement)

representatives of the Trump Organization provided a hard drive to FBI agents. Upon review of 

the hard drive, the FBI determined that the drive contained video footage from four cameras in the 

basement hallway of Mar-a-Lago in which the door to the storage room is located. The footage on 

the drive begins on April 23, 2022, and ends on June 24, 2022. The recording feature of the cameras 

appears to be motion activated, so that footage is only captured when motion is detected within 

each camera’s field of view. 

1

 18 U.S.C. § 793(e) does not use the term “classified information,” but rather criminalizes the unlawful retention of 

“information relating to the national defense.” The statute does not define “information related to the national 

defense,” but courts have construed it broadly. See Gorin v. United States, 312 U.S. 19, 28 (1941) (holding that the 

phrase “information relating to the national defense” as used in the Espionage Act is a “generic concept of broad 

connotations, referring to the military and naval establishments and the related activities of national preparedness”). 

In addition, the information must be “closely held” by the U.S. government. See United States v. Squillacote, 221 

F.3d 542, 579 (4th Cir. 2000) (“[I]nformation made public by the government as well as information never protected 

by the government is not national defense information.”); United States v. Morison, 844 F.2d 1057, 1071-72 (4th 

Cir. 1988). Certain courts have also held that the disclosure of the documents must be potentially damaging to the 

United States. See Morison, 844 F.2d at 1071-72. 2

 On May 25, 2022, while negotiating for an extension of the subpoena, FPOTUS COUNSEL 1 sent two letters to 

DOJ COUNSEL. In the second such letter, available at 22-mj-8332-BER (D.E. 125), FPOTUS COUNSEL 1 asked 

DOJ to consider a few “principles,” which include FPOTUS COUNSEL 1’s claim that a President has absolute 

authority to declassify documents. In this letter, FPOTUS COUNSEL 1 requested, among other things, that “DOJ 

provide this letter to any judicial officer who is asked to rule on any motion pertaining to this investigation, or on 

any application made in connection with any investigative request concerning this investigation.” 

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36. One camera in particular, identified on the hard drive as “South Tunnel Liquor,” 

provides a view of entry and exit into a room (hereafter anteroom) that leads to the storage room. 

The doorway to the anteroom itself is not visible in the camera view, as a refrigerator is directly 

between the camera and doorway, but the footage from this camera nonetheless establishes entry 

and exit to the anteroom because it is apparent when persons within the camera’s field of view turn 

directly behind the refrigerator and then disappear from view. The anteroom, in addition to its 

entrance from the South Tunnel, has approximately four doors leading off it, one of which is the 

gold-painted door that leads to the storage room. The anteroom provides the only entrance to the 

storage room; however, other offices can also be entered from the anteroom, so it might be possible 

for persons to enter the storage room from those other offices without being visible in the 

surveillance camera footage. 

37. By reviewing the camera footage provided by the Trump Organization in response 

to the subpoena, the FBI has determined the following: 

On May 24, 2022, NAUTA is observed exiting the anteroom doorway with three boxes. 

On May 30, 2022, four days after NAUTA’s interview with the FBI during which the 

location of boxes was a significant subject of questioning, NAUTA is observed exiting 

the anteroom doorway with approximately fifty Bankers boxes, consistent with the 

description of the FPOTUS BOXES. FBI did not observe this quantity of boxes being 

returned to the storage room through the anteroom entrance in its review of the footage. 

On June 1, 2022, NAUTA is observed carrying eleven brown cardboard boxes out the 

anteroom entrance. One box did not have a lid on it and appeared to contain papers. 

The day after that, on June 2, 2022, NAUTA is observed moving twenty-five to thirty 

boxes, some of which were brown cardboard boxes and others of which were Bankers 

boxes consistent with the description of the FPOTUS BOXES, into the entrance of the 

ANTEROOM. Approximately three and a half hours later, NAUTA is observed escorting 

FPOTUS COUNSEL 1 in through the entrance of the anteroom, and FPOTUS 

COUNSEL 1 is not observed leaving until approximately two and a half hours later. 

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On June 3, 2022, FPOTUS COUNSEL 1 is escorted through the anteroom entrance by an 

unidentified individual wearing a jacket with “USSS POLICE” printed on the back. The 

unidentified individual and FPOTUS COUNSEL 1 exit the ANTEROOM entrance 

moments later. FPOTUS COUNSEL 1 appeared to be carrying a Redweld envelope after 

exiting the anteroom. 

38. According to FBI’s review of video footage, and as detailed in the paragraph above, 

NAUTA can be observed removing approximately 64 boxes from the storage room area between 

May 24 and June 1, 2022, but only returning 25-30 boxes to the storage room area on June 2, 2022. 

Notably, and as described above in paragraph 28, these boxes were removed following service of 

a grand jury subpoena but before FPOTUS COUNSEL 1’s review of boxes in the storage room 

area to locate documents responsive to the subpoena. 

39.

 

NAUTA concealed information during his FBI interview 

40. On May 26, 2022, the FBI interviewed NAUTA and explained that the FBI was 

conducting an investigation as to whether classified documents were stored at Mar-a-Lago and that 

the FBI was particularly interested in where the boxes with classified documents were located and 

whether they had been moved outside the storage room. 

41. During the 

interview, NAUTA claimed that the first time NAUTA saw the boxes was when NAUTA moved 

them from Pine Hall, the anteroom to FPOTUS’s personal residential suite, to the moving truck to 

provide the boxes to NARA. 

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 Further, in NAUTA’s interview with the FBI on May 

26, he had stated that he did not know where the boxes had come from prior to being located in 

Pine Hall. 

42.

43.

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Execution of Search Warrant at Mar-a-Lago and Movement of Boxes After June 3 

44. On August 8, 2022, the FBI executed a search warrant at Mar-a-Lago authorized 

by the Honorable Bruce E. Reinhart, U.S. Magistrate Judge in the Southern District of Florida. See

22-mj-83332-BER. The search yielded over 100 unique documents bearing classification 

markings, with some indicating the highest levels of classification and extremely limited 

distribution, found in both the storage room and FPOTUS’s office at Mar-a-Lago. Based on my 

training and experience, I know that documents classified at these levels typically contain NDI. 

45.

 

46.

 

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47.

 

The TARGET ACCOUNT 

48. On September 30, 2022, Apple provided records 

which confirmed has been the registered user of the TARGET ACCOUNT 

. Apple records also list as the telephone number 

associated with the TARGET ACCOUNT, as the email address associated 

with the TARGET ACCOUNT, iCloud as a service for the TARGET ACCOUNT, and an iPhone 

13 Pro Max as the device associated with the TARGET ACCOUNT . 

49.

 

50.

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51. On September 30, 2022, open-source research revealed that phone 

number was registered with WhatsApp, an encrypted communication application. 

In my training and experience, WhatsApp permits users to back up communications to a cloud 

service and accordingly, there may be stored communications through backed-up WhatsApp 

messages on the TARGET ACCOUNT. 

52. Based upon this investigation, I believe that there may be stored communications 

within the TARGET ACCOUNT that contain evidence detailing the removal of FPOTUS boxes, 

which likely contained classified information and NDI, from the White House to Mar-a-Lago and 

from the storage room at Mar-a-Lago. Furthermore, I believe there may be stored communications 

in the TARGET ACCOUNT detailing efforts to mislead law enforcement. Finally, the data from 

the TARGET ACCOUNT would also provide location information 

that could indicate when and where moved boxes, such as if moved the boxes to a storage 

facility or other location outside of Mar-a-Lago. As indicated below, Apple has location services 

that could be used to determine where a user traveled with the user’s phone. 

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INFORMATION REGARDING APPLE3

53. Apple is a United States company that produces the iPhone, iPad, and iPod Touch, 

all of which use the iOS operating system, and desktop and laptop computers based on the Mac 

OS operating system. 

54. Apple provides a variety of services that can be accessed from Apple devices or, in 

some cases, other devices via web browsers or mobile and desktop applications (“apps”). As 

described in further detail below, the services include email, instant messaging, and file storage: 

55. Apple provides email service to its users through email addresses at the domain 

names mac.com, me.com, and icloud.com. 

56. iMessage and FaceTime allow users of Apple devices to communicate in real-time. 

iMessage enables users of Apple devices to exchange instant messages (“iMessages”) containing 

text, photos, videos, locations, and contacts, while FaceTime enables those users to conduct video 

calls. 

57. iCloud is a file hosting, storage, and sharing service provided by Apple. iCloud can 

be utilized through numerous iCloud-connected services, and can also be used to store iOS device 

backups and data associated with third-party apps. 

3 The information in this section is based on information published by Apple on its website, 

including, but not limited to, the following document and webpages: “U.S. Law Enforcement 

Legal Process Guidelines,” available at http://images.apple.com/privacy/docs/legal-processguidelines-us.pdf; “Create and start using an Apple ID,” available at 

https://support.apple.com/en-us/HT203993; “iCloud,” available at http://www.apple.com/icloud/; 

“What does iCloud back up?,” available at https://support.apple.com/kb/PH12519; “iOS 

Security,” available at https://www.apple.com/business/docs/iOS_Security_Guide.pdf, and 

“iCloud: How Can I Use iCloud?,” available at https://support.apple.com/kb/PH26502.

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58. iCloud-connected services allow users to create, store, access, share, and 

synchronize data on Apple devices or via icloud.com on any Internet-connected device. For 

example, iCloud Mail enables a user to access Apple-provided email accounts on multiple Apple 

devices and on icloud.com. iCloud Photo Library and My Photo Stream can be used to store and 

manage images and videos taken from Apple devices, and iCloud Photo Sharing allows the user 

to share those images and videos with other Apple subscribers. iCloud Drive can be used to store 

presentations, spreadsheets, and other documents. iCloud Tabs and bookmarks enable iCloud to 

be used to synchronize bookmarks and webpages opened in the Safari web browsers on all of the 

user’s Apple devices. iWork Apps, a suite of productivity apps (Pages, Numbers, Keynote, and 

Notes), enables iCloud to be used to create, store, and share documents, spreadsheets, and 

presentations. iCloud Keychain enables a user to keep website username and passwords, credit 

card information, and Wi-Fi network information synchronized across multiple Apple devices. 

59. Game Center, Apple’s social gaming network, allows users of Apple devices to play 

and share games with each other. 

60. Find My iPhone allows owners of Apple devices to remotely identify and track the 

location of, display a message on, and wipe the contents of those devices. Find My Friends allows 

owners of Apple devices to share locations. 

61. Location Services allows apps and websites to use information from cellular, WiFi, Global Positioning System (“GPS”) networks, and Bluetooth, to determine a user’s 

approximate location. 

62. App Store and iTunes Store are used to purchase and download digital content. iOS 

apps can be purchased and downloaded through App Store on iOS devices, or through iTunes Store 

on desktop and laptop computers running either Microsoft Windows or Mac OS. Additional digital 

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content, including music, movies, and television shows, can be purchased through iTunes Store on 

iOS devices and on desktop and laptop computers running either Microsoft Windows or Mac OS. 

63. Apple services are accessed through the use of an “Apple ID,” an account created 

during the setup of an Apple device or through the iTunes or iCloud services. A single Apple ID 

can be linked to multiple Apple services and devices, serving as a central authentication and 

syncing mechanism. 

64. An Apple ID takes the form of the full email address submitted by the user to create 

the account; it can later be changed. Users can submit an Apple-provided email address (often 

ending in @icloud.com, @me.com, or @mac.com) or an email address associated with a thirdparty email provider (such as Gmail, Yahoo, or Hotmail). The Apple ID can be used to access 

most Apple services (including iCloud, iMessage, and FaceTime) only after the user accesses and 

responds to a “verification email” sent by Apple to that “primary” email address. Additional email 

addresses (“alternate,” “rescue,” and “notification” email addresses) can also be associated with 

an Apple ID by the user. 

65. Apple captures information associated with the creation and use of an Apple ID. 

During the creation of an Apple ID, the user must provide basic personal information including 

the user’s full name, physical address, and telephone numbers. The user may also provide means 

of payment for products offered by Apple. The subscriber information and password associated 

with an Apple ID can be changed by the user through the “My Apple ID” and “iForgot” pages on 

Apple’s website. In addition, Apple captures the date on which the account was created, the length 

of service, records of log-in times and durations, the types of service utilized, the status ¬¬of the 

account (including whether the account is inactive or closed), the methods used to connect to and 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 28 of 53
22 

utilize the account, the Internet Protocol address (“IP address”) used to register and access the 

account, and other log files that reflect usage of the account. 

66. Additional information is captured by Apple in connection with the use of an Apple 

ID to access certain services. For example, Apple maintains connection logs with IP addresses 

that reflect a user’s sign-on activity for Apple services such as iTunes Store and App Store, iCloud, 

Game Center, and the My Apple ID and iForgot pages on Apple’s website. Apple also maintains 

records reflecting a user’s app purchases from App Store and iTunes Store, “call invitation logs” 

for FaceTime calls, “query logs” for iMessage, and “mail logs” for activity over an Apple-provided 

email account. Records relating to the use of the Find My iPhone service, including connection 

logs and requests to remotely lock or erase a device, are also maintained by Apple. 

67. Apple also maintains information about the devices associated with an Apple ID. 

When a user activates or upgrades an iOS device, Apple captures and retains the user’s IP address 

and identifiers such as the Integrated Circuit Card ID number (“ICCID”), which is the serial 

number of the device’s SIM card. Similarly, the telephone number of a user’s iPhone is linked to 

an Apple ID when the user signs in to FaceTime or iMessage. Apple also may maintain records of 

other device identifiers, including the Media Access Control address (“MAC address”), the unique 

device identifier (“UDID”), and the serial number. In addition, information about a user’s 

computer is captured when iTunes is used on that computer to play content associated with an 

Apple ID, and information about a user’s web browser may be captured when used to access 

services through icloud.com and apple.com. Apple also retains records related to communications 

between users and Apple customer service, including communications regarding a particular Apple 

device or service, and the repair history for a device. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 29 of 53
23 

68. Apple provides users with five gigabytes of free electronic space on iCloud, and 

users can purchase additional storage space. That storage space, located on servers controlled by 

Apple, may contain data associated with the use of iCloud-connected services, including: email 

(iCloud Mail); images and videos (iCloud Photo Library, My Photo Stream, and iCloud Photo 

Sharing); documents, spreadsheets, presentations, and other files (iWork and iCloud Drive); and 

web browser settings and Wi-Fi network information (iCloud Tabs and iCloud Keychain). iCloud 

can also be used to store iOS device backups, which can contain a user’s photos and videos, 

iMessages, Short Message Service (“SMS”) and Multimedia Messaging Service (“MMS”) 

messages, voicemail messages, call history, contacts, calendar events, reminders, notes, app data 

and settings, Apple Watch backups, and other data. Records and data associated with third-party 

apps may also be stored on iCloud; for example, the iOS app for WhatsApp, an instant messaging 

service, can be configured to regularly back up a user’s instant messages on iCloud Drive. Some 

of this data is stored on Apple’s servers in an encrypted form but can nonetheless be decrypted by 

Apple. 

69. In my training and experience, evidence of who was using an Apple ID and from 

where, and evidence related to criminal activity of the kind described above, may be found in the 

files and records described above. This evidence may establish the “who, what, why, when, where, 

and how” of the criminal conduct under investigation, thus enabling the United States to establish 

and prove each element or, alternatively, to exclude the innocent from further suspicion. 

70. For example, the stored communications and files connected to an Apple ID may 

provide direct evidence of the offenses under investigation. Based on my training and experience, 

instant messages, emails, voicemails, photos, videos, and documents are often created and used in 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 30 of 53
24 

furtherance of criminal activity, including to communicate and facilitate the offenses under 

investigation. 

71. In addition, the user’s account activity, logs, stored electronic communications, and 

other data retained by Apple can indicate who has used or controlled the account. This “user 

attribution” evidence is analogous to the search for “indicia of occupancy” while executing a 

search warrant at a residence. For example, subscriber information, email and messaging logs, 

documents, and photos and videos (and the data associated with the foregoing, such as geolocation, date and time) may be evidence of who used or controlled the account at a relevant time. 

As an example, because every device has unique hardware and software identifiers, and because 

every device that connects to the Internet must use an IP address, IP address and device identifier 

information can help to identify which computers or other devices were used to access the account. 

Such information also allows investigators to understand the geographic and chronological context 

of access, use, and events relating to the crime under investigation. 

72. Account activity may also provide relevant insight into the account owner’s state 

of mind as it relates to the offenses under investigation. For example, information on the account 

may indicate the owner’s motive and intent to commit a crime (e.g., information indicating a plan 

to commit a crime), or consciousness of guilt (e.g., deleting account information in an effort to 

conceal evidence from law enforcement). 

73. Other information connected to an Apple ID may lead to the discovery of additional 

evidence. For example, the identification of apps downloaded from App Store and iTunes Store 

may reveal services used in furtherance of the crimes under investigation or services used to 

communicate with co-conspirators. In addition, emails, instant messages, Internet activity, 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 31 of 53
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documents, and contact and calendar information can lead to the identification of co-conspirators 

and instrumentalities of the crimes under investigation. 

74. Therefore, Apple’s servers are likely to contain stored electronic communications 

and information concerning subscribers and their use of Apple’s services. In my training and 

experience, such information may constitute evidence of the crimes under investigation including 

information that can be used to identify the account’s user or users. 

REVIEW OF THE INFORMATION OBTAINED PURSUANT TO THE WARRANT 

75. Pursuant to 18 U.S.C. § 2703(g), the presence of a law enforcement officer is not 

required for the service of a search warrant issued under § 2703, or for the collection or production 

of responsive records. Accordingly, the warrant requested herein will be transmitted to Apple, 

which shall be directed to produce a digital copy of any responsive records to law enforcement 

personnel within 14 days from the date of service. Law enforcement personnel (who may include, 

in addition to law enforcement officers and agents, attorneys for the government, attorney support 

staff, agency personnel assisting the government in this investigation, and outside technical experts 

in the governments control) will retain the records and review them for evidence, fruits, and 

instrumentalities of the Subject Offenses as specified in Section II of Attachment B to the proposed 

warrant. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 32 of 53
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76. In conducting this review, law enforcement personnel may use various methods to 

locate evidence, fruits, and instrumentalities of the Subject Offenses, including but not limited to 

undertaking a cursory inspection of all emails within the TARGET ACCOUNT. This method is 

analogous to cursorily inspecting all the files in a file cabinet in an office to determine which paper 

evidence is subject to seizure. Although law enforcement personnel may use other methods as 

well, particularly using keyword searches, I know that keyword searches and similar methods are 

typically inadequate to detect all information subject to seizure. As an initial matter, keyword 

searches work only for text data, yet many types of files commonly associated with emails, 

including attachments such as scanned documents, pictures, and videos, do not store data as 

searchable text. Moreover, even as to text data, keyword searches cannot be relied upon to capture 

all relevant communications in an account, as it is impossible to know in advance all of the unique 

words or phrases that investigative subjects will use in their communications, and consequently 

there are often many communications in an account that are relevant to an investigation but that 

do not contain any keywords that a law enforcement officer is likely to search for. 

CONCLUSION 

77. Based on the forgoing, I request that the Court issue the proposed search warrant. 

Because the warrant will be served on Apple, who will then compile the requested records at a 

time convenient to it, reasonable cause exists to permit the execution of the requested warrant at 

any time in the day or night. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 33 of 53
27 

REQUEST FOR NON-DISCLOSURE AND SEALING 

78. The United States request that the Court order that all papers in support of this 

application, including the affidavit and search warrant, be sealed until further order of the Court. 

These documents discuss aspects of an ongoing criminal investigation that are neither public nor 

known to the targets of the investigation. Accordingly, there is good cause to seal these documents 

because their premature disclosure may give targets an opportunity to flee, destroy or tamper with 

evidence, change patterns of behavior, notify confederates, or otherwise seriously jeopardize the 

investigation.

79. The United States further requests that pursuant to the preclusion of notice 

provisions of 18 U.S.C. § 2705(b), Apple be ordered not to notify any person (including the 

subscriber or customer to which the materials relate) of the existence of this warrant for a period 

of one year. The United States submits that such an order is justified because notification of the 

existence of this Order would seriously jeopardize the ongoing investigation. Such a disclosure 

would give the subscribers an opportunity to destroy evidence, change patterns of behavior, notify 

confederates, or flee from prosecution.

FILTER PROCEDURES 

80. has been represented by attorneys in this matter since at least in or around 

. A Filter Team will review seized communications and segregate potentially protected 

materials, i.e., communications that are to/from an attorney, or that otherwise reference or reflect 

attorney advice. The Filter Team will have no future involvement in the investigation of this 

matter. At no time will the Filter Team advise the Prosecution Team of the substance of any of the 

potentially protected materials. The Filter Team then will provide all communications that are not 

potentially protected materials to the Prosecution Team and the Prosecution Team may resume its 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 34 of 53
Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 35 of 53
ATTACHMENT A 

Property to Be Searched 

 This warrant applies to information associated with Apple Destination Signaling Identifier 

(DSID) that is owned, maintained, controlled, or operated by Apple Inc., a company 

headquartered at 1 Infinite Loop, Cupertino, CA 95014. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 36 of 53
2 

ATTACHMENT B 

Particular Things to be Seized 

I. Information to be disclosed by Apple

 To the extent that the information described in Attachment A is within the possession, 

custody, or control of Apple, Inc (“the Provider”), regardless of whether such information is 

located within or outside of the United States, including any messages, records, files, logs, or 

information that have been deleted but are still available to the Provider, or have been preserved 

pursuant to a request made under 18 U.S.C. § 2703(f), the Provider is required to disclose the 

following information to the government, in unencrypted form whenever available, for each 

account or identifier listed in Attachment A: 

a. All records or other information regarding the identification of the account, to 

include full name, physical address, telephone numbers, email addresses (including 

primary, alternate, rescue, and notification email addresses, and verification information 

for each email address), the date on which the account was created, the length of service, 

the IP address used to register the account, account status, associated devices, methods of 

connecting, and means and source of payment (including any credit or bank account 

numbers); 

b. All records or other information regarding the devices associated with, or used in 

connection with, the account (including all current and past trusted or authorized iOS 

devices and computers, and any devices used to access Apple services), including serial 

numbers, Unique Device Identifiers (“UDID”), Advertising Identifiers (“IDFA”), Global 

Unique Identifiers (“GUID”), Media Access Control (“MAC”) addresses, Integrated 

Circuit Card ID numbers (“ICCID”), Electronic Serial Numbers (“ESN”), Mobile 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 37 of 53
3 

Electronic Identity Numbers (“MEIN”), Mobile Equipment Identifiers (“MEID”), Mobile 

Identification Numbers (“MIN”), Subscriber Identity Modules (“SIM”), Mobile Subscriber 

Integrated Services Digital Network Numbers (“MSISDN”), International Mobile 

Subscriber Identities (“IMSI”), and International Mobile Station Equipment Identities 

(“IMEI”); 

c. The contents of all emails associated with the account, including stored or preserved 

copies of emails sent to and from the account (including all draft emails and deleted 

emails), the source and destination addresses associated with each email, the date and time 

at which each email was sent, the size and length of each email, and the true and accurate 

header information including the actual IP addresses of the sender and the recipient of the 

emails, and all attachments; 

d. The contents of all instant messages associated with the account including stored 

or preserved copies of instant messages (including iMessages, SMS messages, and MMS 

messages) sent to and from the account (including all draft and deleted messages), the 

source and destination account or phone number associated with each instant message, the 

date and time at which each instant message was sent, the size and length of each instant 

message, the actual IP addresses of the sender and the recipient of each instant message, 

and the media, if any, attached to each instant message; 

e. The contents of all files and other records stored on iCloud, including all iOS device 

backups, all Apple and third-party app data, all files and other records related to iCloud 

Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork 

(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and bookmarks, and iCloud 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 38 of 53
4 

Keychain, and all address books, contact and buddy lists, notes, reminders, calendar 

entries, images, videos, voicemails, device settings, and bookmarks; 

f. All activity, connection, and transactional logs for the account (with associated IP 

addresses including source port numbers), including FaceTime call invitation logs, 

messaging and query logs (including iMessage, SMS, and MMS messages), mail logs, 

iCloud logs, iTunes Store and App Store logs (including purchases, downloads, and 

updates of Apple and third-party apps), My Apple ID and iForgot logs, sign-on logs for all 

Apple services, Game Center logs, Find My iPhone and Find My Friends logs, logs 

associated with web-based access of Apple services (including all associated identifiers), 

and logs associated with iOS device purchase, activation, and upgrades; 

g. All records and information regarding locations where the account or devices 

associated with the account were accessed, including all data stored in connection with 

Location Services, Find My iPhone, Find My Friends, and Apple Maps; 

h. All search history or web history; 

i. All records pertaining to the types of service used; 

j. All usernames associated with or sharing a login IP address or browser cookie with 

the account; 

k. All cookies, including third-party cookies, associated with the user; 

l. All records that are associated with the machine cookies associated with the user; 

m. All records pertaining to communications between Apple and any person regarding 

the account, including contacts with support services and records of actions taken; and 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 39 of 53
5 

n. All files, keys, or other information necessary to decrypt any data produced in an 

encrypted form, when available to Apple (including, but not limited to, the keybag.txt and 

fileinfolist.txt files). 

 The Provider is hereby ordered to disclose the above information to the government within 

14 days of service of this warrant. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 40 of 53
6 

II. Information to be seized by the government 

 All information described above in Section I that constitutes contraband, fruits, evidence, 

and/or instrumentalities of violations of 18 U.S.C. § 793 (willful retention of national defense 

information); 18 U.S.C. § 2071 (concealment or removal of government records); 18 U.S.C. § 

1519 (obstruction of federal investigation); 18 U.S.C. § 1001 (material false statement); or 18 

U.S.C. § 1623 (perjury) , since January 2021, 

including, for each account or identifier listed on Attachment A, information pertaining to the 

following matters: 

(a) Communications, records, documents, and other files regarding the access to or 

movement or location of any boxes or records; 

(b) Information, including communications in any form, regarding the retrieval, 

storage, or transmission of national defense information or classified material; 

(c) Information, including communications in any form, regarding any government 

and/or Presidential records created between January 20, 2017, and January 20, 

2021; 

(d) Any evidence of the knowing alteration, destruction, or concealment of any 

government and/or Presidential records, or of any documents with classification 

markings; 

(e) Communications, records, documents, and other files regarding the source and 

nature of any monetary transactions; 

(f) Evidence indicating how and when the account was accessed or used to determine 

the context of account access, use, and events relating to the crimes under 

investigation and to the account owner; 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 41 of 53
7 

(g) Evidence establishing the motive, capability, or willingness to commit the abovereferenced crimes, including but not limited to evidence indicating the account 

owner’s state of mind as it relates to the crimes under investigation; 

(h) The identity of the person(s) who communicated with the account user about 

matters relating to violations of the above-referenced crimes, including records that 

help reveal their whereabouts. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 42 of 53
AO 93 (Rev. 1/13) Search and Seizure Warrant

UNITED STATES DISTRICT COURT

for the

 

In the Matter of the Search of )

)

)

)

)

)

(Briefly describe the property to be searched

 or identify the person by name and address) Case No.

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 District of

(identify the person or describe the property to be searched and give its location):

I find that the affidavit(s), or any recorded testimony, establish probable cause to search and seize the person or property

described above, and that such search will reveal (identify the person or describe the property to be seized):

YOU ARE COMMANDED to execute this warrant on or before (not to exceed 14 days)

u in the daytime 6:00 a.m. to 10:00 p.m. u at any time in the day or night because good 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 .

(United States Magistrate Judge)

u Pursuant to 18 U.S.C. § 3103a(b), 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)

u for days (not to exceed 30) u until, the facts justifying, the later specific date of .

Date and time issued:

Judge’s signature

City and state:

Printed name and title

 Southern District of Florida

22-mj-8489-BER

Information associated with Apple Destination Signaling

Identifier (DSID) , as further described in

Attachment A

Northern California

See Attachment A

See Attachment B

November 10, 2022

✔

Duty Magistrate

West Palm Beach, FL Hon. Bruce E. Reinhart, U.S. Magistrate Judge

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 43 of 53
AO 93 (Rev. 1/13) 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

designated judge.

Date:

Executing officer’s signature

Printed name and title

22-mj-8489-BER

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 44 of 53
ATTACHMENT A 

Property to Be Searched 

 This warrant applies to information associated with Apple Destination Signaling Identifier 

(DSID) that is owned, maintained, controlled, or operated by Apple Inc., a company 

headquartered at 1 Infinite Loop, Cupertino, CA 95014. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 45 of 53
2 

ATTACHMENT B 

Particular Things to be Seized 

I. Information to be disclosed by Apple

 To the extent that the information described in Attachment A is within the possession, 

custody, or control of Apple, Inc (“the Provider”), regardless of whether such information is 

located within or outside of the United States, including any messages, records, files, logs, or 

information that have been deleted but are still available to the Provider, or have been preserved 

pursuant to a request made under 18 U.S.C. § 2703(f), the Provider is required to disclose the 

following information to the government, in unencrypted form whenever available, for each 

account or identifier listed in Attachment A: 

a. All records or other information regarding the identification of the account, to 

include full name, physical address, telephone numbers, email addresses (including 

primary, alternate, rescue, and notification email addresses, and verification information 

for each email address), the date on which the account was created, the length of service, 

the IP address used to register the account, account status, associated devices, methods of 

connecting, and means and source of payment (including any credit or bank account 

numbers); 

b. All records or other information regarding the devices associated with, or used in 

connection with, the account (including all current and past trusted or authorized iOS 

devices and computers, and any devices used to access Apple services), including serial 

numbers, Unique Device Identifiers (“UDID”), Advertising Identifiers (“IDFA”), Global 

Unique Identifiers (“GUID”), Media Access Control (“MAC”) addresses, Integrated 

Circuit Card ID numbers (“ICCID”), Electronic Serial Numbers (“ESN”), Mobile 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 46 of 53
3 

Electronic Identity Numbers (“MEIN”), Mobile Equipment Identifiers (“MEID”), Mobile 

Identification Numbers (“MIN”), Subscriber Identity Modules (“SIM”), Mobile Subscriber 

Integrated Services Digital Network Numbers (“MSISDN”), International Mobile 

Subscriber Identities (“IMSI”), and International Mobile Station Equipment Identities 

(“IMEI”); 

c. The contents of all emails associated with the account, including stored or preserved 

copies of emails sent to and from the account (including all draft emails and deleted 

emails), the source and destination addresses associated with each email, the date and time 

at which each email was sent, the size and length of each email, and the true and accurate 

header information including the actual IP addresses of the sender and the recipient of the 

emails, and all attachments; 

d. The contents of all instant messages associated with the account including stored 

or preserved copies of instant messages (including iMessages, SMS messages, and MMS 

messages) sent to and from the account (including all draft and deleted messages), the 

source and destination account or phone number associated with each instant message, the 

date and time at which each instant message was sent, the size and length of each instant 

message, the actual IP addresses of the sender and the recipient of each instant message, 

and the media, if any, attached to each instant message; 

e. The contents of all files and other records stored on iCloud, including all iOS device 

backups, all Apple and third-party app data, all files and other records related to iCloud 

Mail, iCloud Photo Sharing, My Photo Stream, iCloud Photo Library, iCloud Drive, iWork 

(including Pages, Numbers, Keynote, and Notes), iCloud Tabs and bookmarks, and iCloud 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 47 of 53
4 

Keychain, and all address books, contact and buddy lists, notes, reminders, calendar 

entries, images, videos, voicemails, device settings, and bookmarks; 

f. All activity, connection, and transactional logs for the account (with associated IP 

addresses including source port numbers), including FaceTime call invitation logs, 

messaging and query logs (including iMessage, SMS, and MMS messages), mail logs, 

iCloud logs, iTunes Store and App Store logs (including purchases, downloads, and 

updates of Apple and third-party apps), My Apple ID and iForgot logs, sign-on logs for all 

Apple services, Game Center logs, Find My iPhone and Find My Friends logs, logs 

associated with web-based access of Apple services (including all associated identifiers), 

and logs associated with iOS device purchase, activation, and upgrades; 

g. All records and information regarding locations where the account or devices 

associated with the account were accessed, including all data stored in connection with 

Location Services, Find My iPhone, Find My Friends, and Apple Maps; 

h. All search history or web history; 

i. All records pertaining to the types of service used; 

j. All usernames associated with or sharing a login IP address or browser cookie with 

the account; 

k. All cookies, including third-party cookies, associated with the user; 

l. All records that are associated with the machine cookies associated with the user; 

m. All records pertaining to communications between Apple and any person regarding 

the account, including contacts with support services and records of actions taken; and 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 48 of 53
5 

n. All files, keys, or other information necessary to decrypt any data produced in an 

encrypted form, when available to Apple (including, but not limited to, the keybag.txt and 

fileinfolist.txt files). 

 The Provider is hereby ordered to disclose the above information to the government within 

14 days of service of this warrant. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 49 of 53
6 

II. Information to be seized by the government 

 All information described above in Section I that constitutes contraband, fruits, evidence, 

and/or instrumentalities of violations of 18 U.S.C. § 793 (willful retention of national defense 

information); 18 U.S.C. § 2071 (concealment or removal of government records); 18 U.S.C. § 

1519 (obstruction of federal investigation); 18 U.S.C. § 1001 (material false statement); or 18 

U.S.C. § 1623 (perjury) , since January 2021, 

including, for each account or identifier listed on Attachment A, information pertaining to the 

following matters: 

(a) Communications, records, documents, and other files regarding the access to or 

movement or location of any boxes or records; 

(b) Information, including communications in any form, regarding the retrieval, 

storage, or transmission of national defense information or classified material; 

(c) Information, including communications in any form, regarding any government 

and/or Presidential records created between January 20, 2017, and January 20, 

2021; 

(d) Any evidence of the knowing alteration, destruction, or concealment of any 

government and/or Presidential records, or of any documents with classification 

markings; 

(e) Communications, records, documents, and other files regarding the source and 

nature of any monetary transactions; 

(f) Evidence indicating how and when the account was accessed or used to determine 

the context of account access, use, and events relating to the crimes under 

investigation and to the account owner; 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 50 of 53
7 

(g) Evidence establishing the motive, capability, or willingness to commit the abovereferenced crimes, including but not limited to evidence indicating the account 

owner’s state of mind as it relates to the crimes under investigation; 

(h) The identity of the person(s) who communicated with the account user about 

matters relating to violations of the above-referenced crimes, including records that 

help reveal their whereabouts. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 51 of 53
CERTIFICATE OF AUTHENTICITY OF DOMESTIC 

RECORDS PURSUANT TO FEDERAL RULES OF 

EVIDENCE 902(11) AND 902(13) 

I, _________________________________, attest, under penalties of perjury by the laws 

of the United States of America pursuant to 28 U.S.C. § 1746, that the information contained in 

this certification is true and correct. I am employed by Apple, and my title is 

_____________________________. I am qualified to authenticate the records attached hereto 

because I am familiar with how the records were created, managed, stored, and retrieved. I state 

that the records attached hereto are true duplicates of the original records in the custody of 

Apple. The attached records consist of ______________ [GENERALLY DESCRIBE 

RECORDS (pages/CDs/megabytes)]. I further state that: 

a. all records attached to this certificate were made at or near the time of the 

occurrence of the matter set forth by, or from information transmitted by, a person with 

knowledge of those matters, they were kept in the ordinary course of the regularly conducted 

business activity of Apple, and they were made by Apple as a regular practice; and 

b. such records were generated by Apple’s electronic process or system that 

produces an accurate result, to wit: 

 1. the records were copied from electronic device(s), storage medium(s), or 

file(s) in the custody of Apple in a manner to ensure that they are true duplicates of the original 

records; and 

 2. The process or system is regularly verified by Apple, and at all times 

pertinent to the records certified here, the process and system functioned properly and normally. 

I further state that this certification is intended to satisfy Rules 902(11) and 902(13) of 

the Federal Rules of Evidence. 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 52 of 53
 

Date Signature 

Case 9:22-mj-08489-BER Document 14-1 Entered on FLSD Docket 08/28/2023 Page 53 of 53