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

a CRI. It includes “boiler plate” language regarding the seizure of computers


and cell phones, including language to answer telephones. This language should
be applicable to most CRI warrants and other search warrants for a suspects
location.. 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 of the date of this affidavit, your affiant received
information from a confidential reliable informant hereinafter designated in this affidavit
as a CRI. The CRI is reliable based on the fact that the CRI has given law enforcement
information on prior occasions in the last five months that has led to the arrests of
individuals and the seizure of controlled substances, including methamphetamine.
Nothing the CRI has told your affiant was misleading or untruthful. Your affiant
questioned the CRI carefully regarding drug trafficking, appearance, price, packaging,
use, and effects of various street drugs including methamphetamine. The CRI’S answers
demonstrated extensive knowledge of street drugs.

The CRI related that a male Caucasian adult, who the CRI knows by the name of Allan
Crook, is currently selling methamphetamine. The CRI said that Allan Crook lives on
Main Drive in the City of San Luis Beach. The CRI indicated that Allan Crook keeps
methamphetamine for sale inside a converted shed in the backyard of the property. The
CRI indicated that the shed is covered by a blue tarp. The CRI knows that Allan Crook
sells methamphetamine as the CRI has purchased methamphetamine from Allan Crook in
the past. The CRI related that Allan Crook allows individuals to use methamphetamine
purchased from Allan Crook inside the blue tarp covered shed.

Within the previous ten days of the date of this affidavit, the CRI observed a quantity of
methamphetamine possessed for sale by Allan Crook inside the blue tarped covered shed
on the property of Allan Crook’s residence.

The CRI pointed out the location of Allan Crook’s residence as 5643 Main Drive in the
City of San Luis Beach. Through departmental resources I was able to identify Allan

Statement of Probable Cause


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Crook as Allan Edward Crook with a DOB of 07-12-1974. Allan Crook has a California
Driver’s license of N0987087. Allan Crook’s driver’s license shows a record of address
of 5643 Main Drive, San Luis Beach California, 96503. Your affiant was able to identify
the address as described on page two of the search warrant.

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
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

Statement of Probable Cause


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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 my 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 any conversations and
information received from the telephone calls, including caller identification information.
It is my opinion 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.

Statement of Probable Cause


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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.

An off site 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.

Statement of Probable Cause


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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 an 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 CRI remain confidential for the following
reasons: disclosure will jeopardize the life and safety of the CRI and disclosure will
destroy the CRI’S future usefulness to law enforcement.

Statement of Probable Cause


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