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This will be your “typical” search warrant template that you would use for

a controlled buy search warrant. It includes language (“boiler plate”) regarding


computers and cell phones that should be applicable to most controlled buy
search warrants. At the end of this example is language regarding videotaping.
This paragraph might not always be used for these types of search warrants. Be
sure to read this example before you simply cut and paste it to ensure that its
statements will be true for your Statement of Probable Cause.

Within the previous ten days, your affiant received information from a confidential
informant hereinafter referred to in this affidavit as CI. The CI told your affiant that a
person known to the CI as Francisco Gonzalez is selling cocaine. The CI knows this as
the CI has purchased cocaine from Francisco Gonzalez in the past. The CI has purchased
cocaine from Francisco Gonzalez in various locales open to the public in the County of
Los Angeles. The CI described Francisco Gonzalez as a male Hispanic in his mid
thirties, black hair, brown eyes. The CI told your affiant that Francisco Gonzalez has a
cellular number of 310-555-2766. The CI told your affiant that Francisco Gonzalez
drives a maroon Chevy station wagon, and will drive his maroon Chevy station wagon
when meeting the CI in various locales open to the public in the County of Los Angeles.
The CI told your affiant that Francisco Gonzalez lives in San Luis Beach, and believed
the address that Francisco Gonzalez lived was 1234 156th Street.

Your affiant questioned the CI carefully regarding drug trafficking and the appearance,
price, use and effects of various street drugs. The CI’s answers demonstrated extensive
knowledge about street drugs including, cocaine.

Your affiant was able to identify Francisco Gonzalez through departmental resources as
Francisco Javier Gonzalez. Francisco Javier Gonzalez has a DOB of 08-18-71, is a male
Hispanic, 5-08, 180 lbs., black hair, brown eyes. Francisco Javier Gonzalez has a
CDL#A5987562. Francisco Javier Gonzalez has a residence address listed of 1234 W.
154th Street, San Luis Beach Ca. for his CDL as of May 06, 2006.

Within the previous ten days, and armed with this information your affiant caused a
complete and thorough search of the CI. The CI had no contraband on their person. The

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CI was given a quantity of police funds and went to a public place within the County of
Los Angeles and met with Francisco Javier Gonzalez. The CI was kept under constant
surveillance by Special Investigations Unit Detectives while the CI met with Francisco
Javier Gonzalez. After the CI met with Francisco Javier Gonzalez, the CI went to a
predetermined meeting location and met with your affiant. Your affiant was given a
quantity of a substance, resembling cocaine by the CI. The CI told your affiant that
Francisco Javier Gonzalez sold the cocaine to the CI when the CI met with Francisco
Javier Gonzalez.

Your affiant conducted a presumptive test on the substance believed to be cocaine. The
test returned positive indicating the substance was cocaine.

Within the previous ten days, surveillance was conducted on Francisco Javier Gonzalez.
Francisco Javier Gonzalez was observed driving a maroon 1998 Mercury station wagon,
Cal Lic#5DTT342.

Within the previous ten days, surveillance was conducted on Francisco Javier Gonzalez
and Francisco Javier Gonzalez was seen entering the location of 1234 W. 154th Street,
San Luis Beach. Francisco Javier Gonzalez used keys to unlock the front door and enter
the residence.

It is your affiant’s experience that records and paraphernalia such as weighing devices,
cutting material, and other containers are permanently possessed by narcotic traffickers
in much the same way a business will maintain records and tools of its trade, whether or
not the business has a particular item in inventory on a given day.

It is your affiant’s experience that narcotic dealers/sellers commonly sell drugs/narcotics


from their personal residence(s) and other locations (such as: public/private businesses,
open parking lots, other people’s residences, public streets and public park/recreation
areas). Narcotic dealers will sell narcotics at various locations in order to escape
detection of law enforcement. It is your affiant’s opinion based on experience and

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training that seller’s of narcotics often use vehicles to transport and store narcotics and
will use their vehicle(s) to store and sell narcotics from. It is your affiant’s opinion based
on experience and training that seller’s of narcotics will use their residence(s) to store
and sell narcotics from.

Based upon the information contained in this affidavit, coupled with your affiant’s
training and experience, your affiant states that the items of drug paraphernalia and
documentation enumerated on Search Warrant & Affidavit page #3 of this affidavit are
articles that are commonly found in, and associated with, places/persons where controlled
substances are found to be present. Your affiant has reason to believe and does believe
that there is controlled substance(s) in the form of cocaine being sold and stored from the
premise(s) and vehicle(s) for which this warrant is requested.

Your affiant has been present during the execution of numerous search warrants. In
virtually all of these instances, your affiant has observed utility bills pertaining to the
location and/or personal letters addressed to the occupants of the location within the
residence being searched. On many occasions, your affiant has observed handwritten
notes or papers, photographs, digital cameras (including memory cards and internal
memory storage pictures/video) and video cameras (including memory cards and internal
memory storage pictures/video), keys that fit the location locks, and wallets, purses,
diaries, phone books, and luggage tags, all of which contained in or upon them some
personalization or which tended to identify the owner(s) thereof and thus circumstantially
identified to your affiant the occupant(s) of the premises for the purposes of arrest,
identification and crime charging.

Based upon the facts set forth in this affidavit, it your affiant’s opinion that suspect(s)
listed in the “to be searched page” are selling controlled substances and that the
suspect(s) are taking orders over the telephone for pickup and delivery. Thus, your
affiant also request this warrant authorize searching officers to answer telephones
(including cellular) and converse (including texting) with callers at the location of this
Search Warrant without revealing the Peace Officers true identity, and note and/or record

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any conversations and information received from the telephone calls, including caller
identification information. It is your affiant’s opinion that persons will call ordering
narcotics and that such calls will constitute evidence of the commission of a felony.

It is your affiant’s experience and the experience of other narcotic investigators with
whom your affiant has spoken with that suspect(s) who traffic in narcotics frequently
possess cellular telephones to enhance their trade. These suspect(s) use cellular
telephones to house buyers and sellers lists, track profits and losses, store receipts, and to
communicate with other traffickers of narcotics. Thus, your affiant requests if cellular
telephones are located in possession of suspect(s) and/or location(s) listed in the “to be
searched page” being searched as authorized by this warrant that your affiant be allowed
to seize such cellular telephones. An offsite search of the suspect’s cellular telephone,
including all storage devices, is needed for a complete search of all the data on the
cellular telephone may be necessary, based on your affiant’s experience that suspect(s)
who traffic in narcotics will use cellular telephones to enhance their trade.

In order to assure that the cellular telephone can be examined (including a forensic
examination) all peripheral equipment, such as powering devices and external storage
devices will need to be collected along with manuals and support documentation. A
forensic examination of the cellular phone(s) in a controlled environment with forensic
equipment may be necessary in order to assist not only your affiant’s investigation, but
also the interests of the suspect(s) in this matter.

It is also your affiant’s experience and the experience of other narcotic investigators with
whom your affiant has spoken with that suspect(s) who traffic in narcotics frequently
possess computers to enhance their trade. These suspect(s) use computers to house buyers
and seller’s lists, track profits and losses, store receipts, and to communicate with other
traffickers of narcotics. Thus, your affiant also requests if computers are located in
possession of suspect(s) listed and/or location(s) listed in the “to be searched page” being
searched as authorized by this warrant that your affiant be allowed to seize such
computers.

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An offsite search of the suspect’s computer system, including all storage devices, is
needed as your affiant’s experience has shown that computer systems can store an
equivalent to hundreds of thousands or even millions of pages of information. Also, as
suspect’s can disguise or rename computer files at will, a complete search of all the data
on the computer system may be necessary. This can best be done in a controlled
environment with forensic equipment. This will assist not only your affiant’s
investigation, but also the interests of the suspect(s) in this matter.

In order to assure that the computer system can be forensically examined all peripheral
equipment, such as computer hardware, software and external storage devices will need
to be collected along with manuals and support documentation. Computer hardware
consists of all equipment which can collect, analyze, create, display, convert, store,
conceal, or transmit electronic, magnetic, optical, or similar computer impulses or data.

As evidence in this matter could be stored either on a computer hard drive or on


removable storage devices, such as, floppy disks, CD’s, or tapes, all removable storage
devices would need to be seized. Due to the storage capacity of removable storage
devices, on scene inspection of them would not be practical. With respect to computer
systems and any items listed above found during the execution with this Search Warrant, the
searching Peace Officers are authorized to seize and book said computer systems and any
items listed above and transfer them to a Law Enforcement Agency location prior to
commencing the search of the items. Furthermore, said search may continue beyond the
ten-day period beginning upon issuance of this Search Warrant, to the extent necessary to
complete the search on the computer systems and any items listed above.

Your affiant requests that the identity of the CI remain confidential for the following
reasons: disclosure will jeopardize the life and safety of the CI and disclosure will
destroy the CI’s future usefulness to law enforcement.

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Your affiant believes that through documentation of the scene is critical to the
preservation of the evidence and to understanding its significance and relationships, and
requests authority to make a videotape of the scene (location), before, during, and after
its investigative processing. Your affiant requests that the scene (location), if necessary,
be videotaped before, during, and after the investigation to preserve all details.

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