MIDLOTHIAN POLICE DEPARTMENT se
EVIDENTIARY SEARCH/SEIZURE WARRANT
THE STATE OF TEXAS LOCATION:
Linkedin Corporation
ATTN: Legal Department
2029 Stierlin Court
Mountain View, CA 94043
BY FAX: 650-810-2897
COUNTY OF ELLIS
The State of Texas to the Sheriff or any Peace Officer of Ellis County, Texas, or any
Peace Officers of the State of Texas and Officers of the Midlothian Police Department
and other law enforcement forensic specialists.
GREETINGS:
Whereas, the Affiant whose signature is affixed to the attached Application and Affidavit
appearing on the document labeled “Exhibit A" hereof is a Peace Officer under the laws
of Texas and did heretofore this day subscribe and swear to said affidavit before me
(which said affidavit is by this reference incorporated herein for all purposes), and
whereas | find that the verified facts, stated by The Affiant show that The Affiant has
Probable Cause for the belief he expresses therein and establishes the existence of
proper grounds for the issuance of this Evidentiary Search Warrant.
IN CONCLUSION,
You are commanded to produce the evidence described herein within the attached
Application and Affidavit appearing on the document labeled “Exhibit A” hereof.
Issued at_5-% , on this the, Z 2_ day of Ale. 20 LL _ to certify
which witness my hand this day
JUDGE BOB CARROLL
40™ JUDICIAL DISTRICT COURT
4H
IS COUNTY, TEXAS‘THE STATE OF TEXAS
COUNTY OF ELLIS
MIDLOTHIAN POLICE DEPARTMENT
APPLICATION & AFFIDAVIT IN SUPPORT OF
EVIDENTIARY SEARCH/SEIZURE WARRANT
EXIGENT CIRCUMSTANCES
LOCATION:
cedin Corporation
‘TIN: Legal Department
2029 Stierlin Court
Mountain View, CA 94043
BY FAX: 650-810-2897
THE UNDERSIGNED AFFIANT, BEING A PEACE OFFICER UNDER THE LAWS OF
TEXAS, SPECIFICALLY THE MIDLOTHIAN POLICE DEPARTMENT AND BEING
DULY Ss
(ORN, ON OATH MAKES THE FOLLOWING STATEMENTS AND
ACCUSATIONS:
1
THERE IS IN MIDLOTHIAN, ELLIS COUNTY, TEXAS, A PLACE AND
PREMISES DESCRIBED AND LOCATED AS FOLLOWS:
The Midlothian Police Department, which seeks information contained herein and
believed to be in the possession of Linkedin Corporation, ATTN: Legal Department,
2029 Stierlin Court, Mountain View, CA 94043 BY FAX: 650-810-2897
THERE JS AT SAID PECTED PLACE AND PREMISES PROPERTY
CONCEALED AND KEPT IN VIOLATION OF THE LAWS OF TEXAS AND
DESCRIBED AS FOLLOWS; AND EVIDENCE OF THE COMMISSION OF THE
CRIME OF MURDER:
Any and all data. and/or _ information regarding Linkedin 1D
“https://www.linkedin.com/in/missy-bevers-5a18375a", Terri "Missy" Leann
Bevers, White Female, 5'3", Blonde hair, blue eyes, DOB 8/9/1970, to include
Member Content including: Messages; Invitations, and Connections; and Basic
Subscriber Information including: Email address(es); Member identification number
(‘Member ID"); Date and time of account creation; Billing information; Snapshot of
Member Profile Page, which may include: Profile Summary; Experience; Education;
Page 2 of 7
EVIDENTIARY SEARCHISEIZURE WARRANT
LinkedIn Corpora
m, 2029 Stierlin Court, Mountain View, CA 94043Recommendations; Groups; Network Update Stream; User profile photo regarding
Midlothian Police Department Case Number 16MP016585
Affiant has reasonable grounds to believe that the contents of the electronic
communication, records or other information sought herein are relevant and material
to an ongoing criminal investigation
THIS IS IN CONNECTION WITH A MURDER (CASE NUMBER 16MP016585) THAT
MAY BE PART OF A CONTINUING CRIMINAL ACT IN PROGRESS. THE
EXIGENCY OF THIS SITUATION REQUIRES AN IMMEDIATE REPLY TO ASSIST
INVESTIGATORS IN LOCATING THE SUSPECT.
Terri "Missy" Leann Bevers was found murdered by Midlothian Police on Monday 18
April 2016 around 0500 AM, a crime under Texas Penal Code 19.02 MURDER (b)
(1), to wit: A person commits an offense if he: (1) intentionally or knowingly causes
the death of an individual. An offense under this section is a felony of the first
degree.
In the course of investigating this crime Affiant has developed probable cause to
believe that Terri "Missy" Leann Bevers is the victim of this crime, and that the victim
has been using a computer to access the Linkedin social media website and
engaged in message transactions constituting evidence in this murder investigation
and potentially further offenses.
3. SAID SUSPECTED PLACE AND PREMISES ARE IN CHARGE OF AND
CONTROLLED BY EACH OF THE FOLLOWING NAMED PARTIES
(HEREAFTER CALLED “SUSPECTED PARTY” WHETHER ONE OR MORE), TO-
WIT: IT IS THE BELIEF OF THE AFFIANT, AND AFFIANT HEREBY CHARGES
AND ACCUSES, THAT:
Because of the nature of the accesses described above, and in furtherance of the
investigation described herein, Affiant believes that additional private messages,
image sharing, and communications between the above named account and others,
except fromithrough Linkedin itself. This request is specific, with respect to
requested account holder and related information from within the dates and
approximate times listed above.
Your Affiant is requesting this warrant authorized under Texas Code of Criminal
Procedure Article 18.21, Sec. 5A and a reciprocating statute of the State of
California: Pursuant to California Penal Code 1524.2(c), which reads "A California
corporation that provides electronic communication services or remote computing
services to the general public, when served with a warrant issued by another state to
produce records that would reveal the identity of the customers using those
services, data stored by, or on behalf of, the customer, the customer’ s usage of
those services, the recipient or destination of communications sent to or from those
customers, or the content of those communications, shall produce those records as
Page 3 of7
URE WARRANT
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043
|
|
|
|if that warrant had been issued by a California court." Your Affiant therefore
requests that Linkedin honor this Affidavit for search warrant issued within the State
of Texas.
THE COURT HEREBY ORDERS THE ABOVE-LISTED PROVIDER NOT TO
DISCLOSE THE EXISTENCE OF THIS SEARCH WARRANT, BECAUSE THE
EVIDENCE BEING SOUGHT IS EASILY DELETED OR DESTROYED. IN
ADDITION, AFFIANT’S INVESTIGATION IS NOT KNOWN TO THE SUSPECT AND
DISCLOSURE OF THE INVESTIGATION WILL LIKELY CAUSE IMMEDIATE
DANGER TO WITNESSES, DESTRUCTION OF OTHER PHYSICAL EVIDENCE AND
FLIGHT FROM PROSECUTION.
BECAUSE OF THE EXIGENCY OF THIS INVESTIGATION AND THE BELIEF OF
AFFIANT THAT DELAY MAY POSE IMMEDIATE DANGER TO HUMAN LIFE
THIS COURT HEREBY ORDERS THAT LINKEDIN USE ALL REASONABLE
MEANS TO RESPOND TO THIS ORDER WITHIN THREE (3) DAYS FROM THE
DATE OF ISSUANCE.
4, AFFIANT HAS PROBABLE CAUSE FOR THE SAID BELIEF BY REASON OF THE
FOLLOWING FACTS, TO-WIT:
See attached Supporting Affidavit labeled “Exhibit A". Exhibit A is attached hereto
and by this reference incorporated herein for all purposes.
WHEREFORE, Your Affiant respectfully requests this court to authorize this search/seizure
warrant
st Men,
AFFIANT
Investigator Cody McKinney
Midlothian Police Department
cee and sworn to before me at_2-S0/M by said “eZ on this the -27 day
ot Agi AD., 20_ 7 ie CEL. d /
JUDGE BOB CARROLL
40™ JUDICIAL DISTRICT COURT
ELLIS COUNTY, TEXAS
Page 4of7
EVIDENTIARY SEARCH(SEIZURE WARRANT
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043,EXHIBIT “A”
AFFIDAVIT IN SUPPORT OF EVIDENTIARY SEARCH
WARRANT
{Article 18.02(10), Texas Code of Criminal Procedure}
YOUR AFFIANT’S BACKGROUND, TRAINING AND EXPERIENCE
Your Affiant, Cody Mckinney, having been duly sworn, declare as follows:
| am a Sergeant with the Midlothian, Texas Police Department. | have been employed
by said department for a period of approximately eleven (11) years. | have served in
investigative capacities within the Midlothian Police Department for approximately nine
(9) years. | have received special deputation as a Deputy United States Marshall, and
sworn as a Federal Task Force Officer (TFO) assigned to the North Texas High
Intensity Drug Trafficking Area (HIDTA), Southern Money Laundering Initiative. | am
currently assigned as a Task Force Officer (TFO) with the Drug Enforcement
Administration (DEA) Eastern Drug Squad Group One. | currently possess an
Advanced Peace Officer Certification as merited by and with the State of Texas
Commission on Law Enforcement (TCOLE).
Your Affiant has also participated in numerous narcotics and financial investigations
with the Internal Revenue Service-Criminal Investigations (IRS-Cl) relevant to violations
of State and Federal Money Laundering statutes. Your Affiant has also received
specialized training in narcotics investigations from the Drug Enforcement
Administration (DEA) and related Money-Laundering matters from the Internal Revenue
Service-Criminal Investigations (IRS-Cl)
Your affiant is also trained and certified in the use of Cellebite/UFED electronic forensic
data extractions, and affiant has had substantial experience in extracting
electronic/digital data from various types, makes, and models of electronic/digital
devices including cell phones, tablets, and GPS devices. Additionally, affiant has spent
hundreds of hours on numerous cases analyzing such extracted data and information.
In addition, Your Affiant has experience in the execution of financial search warrants,
narcotics search warrants, debriefing defendants, informants, and other
witnesses/individuals who have personal knowledge of the amassing, spending,
converting, transporting, distributing, laundering, and concealing of proceeds derived
from the distribution of illegal drugs
Your Affiant has used a variety of investigative techniques during his investigations
including, but not limited to, electronic surveillance, visual surveillance, the use of
confidential sources and the use of undercover agents. Information contained in this
Affidavit is derived from Your Affiant's knowledge of, and prior experiences in financial
and narcotics investigations; information obtained during interviews with drug traffickers
Page S of 7
EVIDENTIARY SEARCH/SEIZURE WARRANT
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043familiar with this drug trafficking organization, and review of reports prepared by special
agents with DEA as well as other federal, state and local law enforcement agencies.
As a result of Your Affiant’s participation in this investigation, my conversations with,
and review of reports prepared by HIDTA Task Force Officers as well as other federal,
state and local law enforcement agencies, | am familiar with all aspects of this
investigation as articulated in this Affidavit. Information contained in this Affidavit
includes the results of review of property records and other information obtained from
public sources; physical surveillance; information from cooperating witnesses and law
enforcement personnel,
YOUR AFFIANT’S PROBABLE CAUSE
The recitation of facts contained in this Affidavit is not meant to be a complete narrative of all
information that is known to Your Affiant, but only a summary of facts to necessitate the
establishment of sufficient probable cause, in support of this affidavit, for an Evidentiary Search
Warrant.
The decedent was murdered as she arrived to prepare for a physical fitness class she
was to teach on the morning of the 18" of April 2016 at the Creekside Church,
Midlothian, Ellis County, Texas 76065. The suspect in this case is currently unknown
and at large.
The unknown suspect dressed in police tactical/riot gear, obtained forcible entry to the
location of the murder, to-wit, the Creekside Church, and appears on the Creekside
Church surveillance videos. The unknown suspect is the only person detected within
the building during a period of approximately thirty (30) minutes when the victim and
decedent, Terri “Missy” Leann Bevers, was murdered, and it is reasonably believed that
the said unknown suspect is responsible in part or in full for murdering Ms. Bevers.
In the course of our investigation we have had multiple references to the Decedent's
social media accounts, specifically her Linkedin account. LinkedIn is a social media
networking service used to make connections to others. In the course of our
investigation, we have received information from interviews conducted with persons of
interest and persons close to the victim that the decedent was a regular user of
LinkedIn. During one such interview a friend of the victim told law enforcement that less
than three days before the murder, the victim showed this friend a private message
from the victim's LinkedIn account.
The message was from a male unknown to them both, and they both agreed that the
message was creepy and strange. This friend could not recall the person's name on the
account.
Additionally, law enforcement has identified another person of interest through evidence
gathered and an interview was conducted. This person of interest confirmed that they
Page 6 of 7
EVIDENTIARY SEARCHISEIZURE WARRANT
Linkedin Corporation, 2029 Stierlin Court, Mountain View, CA 94043had engaged in a series of communications with the decedent while on the Linkedin
Social Media Service some time starting around (January 2016) until her death that
ultimately turned flirtatious and familiar.
An electronic forensic data extraction of the cell phones belonging to the decedent and
the identified person of interest confirms that the communications using Linkedin
occurred. The content of the recovered communications appears intimate in nature.
The extracted information also showed that these communications were deleted after
the conversation ended and were only able to be partially recovered.
Your Affiant has probable cause to believe that the decedent was in contact with
several people through the LinkedIn service who are of direct interest to this
investigation.
A Meier
AFFIANT
INVESTIGATOR CODY MCKINNEY
MIDLOTHIAN POLICE DEPARTMENT
Subscribed and sworn to before me u 250A by said Affiant on this the_22 day
of Lei ap.,20 £6.
JUDGE BOB CARROLL
40" JUDICIAL DISTRICT COURT
ELLIS COUNTY, TEXAS
Page 7 of7
EIZURE WARRANT
in Court, Mountain View, CA 94043,
EVIDENTIARY SEARCH
Linkedin Corporation, 2029MIDLOTHIAN POLICE DEPARTMENT
Criminal investigation Division
1150 N. US Highway 67, Suite 300, Midlothian, TX 76065
(972) 775-3333
26 APRIL 2016
LinkedIn Corporation |
ATTN: Legal Department
2029 Stierlin Court
Mountain View, CA 94043
BYF. 5
81
1897,
RE MPD CASE NUMBER 16MP016585
EMERGENCY DATA REQUEST
My name is Detective Nick Selby, badge number is #168, and Iam a sworn police officer with |
the Midlothian, Texas, Police Department, 1150 N. US Highway 67, Suite 300, Midlothian, TX
76065. Since July, 2014, I have been assigned to the Criminal Investigation Division. The
telephone number for Central Dispatch is (972) 775-3333. My mobile phone number is (817)
908-3171
In the course of my duties I have been assigned to the team working to investigate the murder of
Terri “Missy” Leann Bevers (“Decedent”), which occurred on the morning of 18 April 2016
sometime between 0400 and 0500 CST in the Creekside Church, Midlothian, Texas, a crime |
under Texas Penal Code 19.02 MURDER (b) (1), to wit: a person commits an offense if he: (1)
intentionally or knowingly causes the death of an individual. An offense under this section is a
felony of the first degree. |
‘The case number for this investigation is 16MP016585.
‘The LinkedIn account of Decedent is accessible through the following URL: |
https://www.linkedin.com/in/missy-bevers-5a18375a
During the course of this investigation, several references have been made to the Decedent’s
LinkedIn account, We are preparing a full search warrant for the judge to sign. I hereby attest
that there are exigent circumstances that make it necessary for me to additionally request on an
emergency basis all information that was sent to the Decedent through the LinkedIn service
using private messages, chats or InMail between April 14, 2016 and April 16, 2016. We have
reasonable grounds to believe that the killer, who is still at large and poses an immediate danger
to other human beings, communicated with the Decedent in this manner in that time period.Emergency Disclosure Request, Linkedin, MPD Case Number 1GMPO16585
Additionally we have reasonable grounds to believe, and request on an emergency basis the
content of any and all chat, private messages, InMail or other methods available to those with
access to the LinkedIn service were sent between the Decedent and Casey Williams
(https://www linkedin.com/in/casey 2 airborne) in the month prior to 18 April 2016, We base
this exigency request on statements made by witnesses during the course of this investigation,
also hereby submit a Preservation Request for the data contained in the accounts of both
Decedent and Casey Williams (https://www.linkedin.com/in/casey12 airborne)
Please respond to these requests via email: nick.selby@midlothian.tx.us. If this is not possible,
then please provide the data in the form of an encrypted digital download accessible through the
Internet by emailing instructions on access to the file to nick.selby@midlothian.tx.us.
‘The above is true and correct to the best of my knowledge
fac }
Detetive Nick Selby
Midlothian, TX Police Department
Criminal Investigation DivisionMIDLOTHIAN POLICE DEPARTMENT
VIDENTIARY SEARCH/SEIZURE WARRANT
bd
THE STATE OF TEXAS LOCATION:
LinkedIn Corporation
ATTN: Legal Department
2029 Stierlin Court
Mountain View, CA 94043
BY FAX: 650-810-2897
COUNTY OF ELLIS
The State of Texas to the Sheriff or any Peace Officer of Ellis County, Texas, or any
Peace Officers of the State of Texas and Officers of the Midlothian Police Department
and other law enforcement forensic specialists.
GREETINGS:
Whereas, the Affiant whose signature is affixed to the attached Application and Affidavit
appearing on the document labeled “Exhibit A” hereof is a Peace Officer under the laws
of Texas and did heretofore this day subscribe and swear to said affidavit before me
(which said affidavit is by this reference incorporated herein for all purposes), and
whereas | find that the verified facts, stated by The Affiant show that The Affiant has
Probable Cause for the belief he expresses therein and establishes the existence of
proper grounds for the issuance of this Evidentiary Search Warrant.
IN CONCLUSION,
You are commanded to produce the evidence described herein within the attached
Application and Affidavit appearing on the document labeled “Exhibit A” hereof.
Issued at FY EF, on hse AZ wy ot AK ZB wocentty
which witness my hand this day. Le 2 /
JUDGE BOB CARROLL
40"! JUDICIAL COURT JUDGE
ELLIS COUNTY TEXASMIDLOTHIAN POLICE DEPARTMENT
APPLICATION & AFFIDAVIT IN SUPPORT OF
EVIDENTIARY SEARCH/SEIZURE WARRANT
EXIGENT CIRCUMSTANCES
THE STATE OF TEXAS LOCATION:
inkedin Corporation
ATTN: Legal Department
2029 Stierlin Court
Mountain View, CA 94043
BY FAX: 650-810-2897
COUNTY OF ELLIS
THE UNDERSIGNED AFFIANT, BEING A PEACE OFFICER UNDER THE LAWS OF
TEXAS, SPECIFICALLY THE MIDLOTHIAN POLICE DEPARTMENT AND BEING
DULY SWORN, ON OATH MAKES THE FOLLOWING STATEMENTS AND
ACCUSATIONS:
1, THERE IS IN MIDLOTHIAN, ELLIS COUNTY, TEXAS, A PLACE AND
PREMISES DESCRIBED AND LOCATED AS FOLLOWS:
The Midlothian Police Department, which seeks information contained herein and
believed to be in the possession of LinkedIn Corporation, ATTN: Legal Department,
2029 Stierlin Court, Mountain View, CA 94043 BY FAX: 650-810-2897
2. THERE IS AT SAID PECTED PLACE AND PREMISES PROPERTY
CONCEALED AND KEPT IN VIOLATION OF THE LAWS OF TEXAS AND
DESCRIBED AS FOLLOWS; AND CONSTITUTES AS EVIDENCE OF THE
COMMISSION OF THE CRIME OF MURDER:
Any and all data and/or information regarding Linkedin ID"
https:/www.linkedin.com/in/casey121airborne", Casey Williams, to include
Member Content including: Messages; Invitations, and Connections; and Basic
Subsoriber Information including: Email address(es); Member identification number
(‘Member ID"); Date and time of account creation; Billing information; Snapshot of
Member Profile Page, which may include: Profile Summary; Experience; Education;
Page 20f7
EVIDENTIARY SEARCHISEIZURE WARRANT
LinkedIn Corporation, 2029 Stierlin Court, Mountain
ew, CA. 94043Recommendations; Groups; Network Update Stream; User profile photo regarding
Midlothian Police Department Case Number 16MP016585,
Affiant has reasonable grounds to believe that the contents of the electronic
communication, records or other information sought herein are relevant and material
to an ongoing criminal investigation
THIS IS IN CONNECTION WITH A MURDER (CASE NUMBER 16MP016585) THAT
MAY BE PART OF A CONTINUING CRIMINAL ACT IN PROGRESS. THE
EXIGENCY OF THIS SITUATION REQUIRES AN IMMEDIATE REPLY TO ASSIST
INVESTIGATORS IN LOCATING THE SUSPECT.
Terri "Missy" Leann Bevers was found murdered by Midlothian Police on Monday 18
April 2016 around 0500 AM, a crime under Texas Penal Code 19.02 MURDER (b)
(1), to wit: A person commits an offense if he: (1) intentionally or knowingly causes }
the death of an individual. An offense under this section is a felony of the first
degree.
In the course of investigating this crime Affiant has developed probable cause to
believe that Terri "Missy" Leann Bevers is the victim of this crime, and that the victim
has been using a computer to access the LinkedIn social media website and
engaged in message transactions with the above-named Casey Wiliams,
constituting evidence in this murder investigation and potentially further offenses.
3. SAID SUSPECTED PLACE AND PREMISES ARE IN CHARGE OF AND
CONTROLLED BY EACH OF THE FOLLOWING NAMED PARTIES
(HEREAFTER CALLED “SUSPECTED PARTY” WHETHER ONE OR MORE), TO-
WIT: IT IS THE BELIEF OF THE AFFIANT, AND AFFIANT HEREBY CHARGES.
AND ACCUSES, THAT:
Because of the nature of the accesses described above, and in furtherance of the
investigation described herein, Affiant believes that additional private messages,
image sharing, and communications between the above named account and others,
except from/through Linkedin itself. This request is specific, with respect to
requested account holder and related information from within the dates and i
approximate times listed above. |
Your Affiant is requesting this warrant authorized under Texas Code of Criminal
Procedure Article 18.21, Sec. 5A and a reciprocating statute of the State of
California: Pursuant to California Penal Code 1524.2(c), which reads "A California
corporation that provides electronic communication services or remote computing
services to the general public, when served with a warrant issued by another state to
produce records that would reveal the identity of the customers using those
services, data stored by, or on behalf of, the customer, the customer’ s usage of
those services, the recipient or destination of communications sent to or from those
customers, or the content of those communications, shall produce those records as
Page 3 of7
EVIDENTIARY SEARCH/SEIZURE WARRANT
Linkedin Corporation, 2029 Stierlin Court, Mountain View, CA 94043if that warrant had been issued by a California court." Your Affiant therefore
requests that LinkedIn honor this Affidavit for search warrant issued within the State
of Texas.
THE COURT HEREBY ORDERS THE ABOVE-LISTED PROVIDER NOT TO
DISCLOSE THE EXISTENCE OF THIS SEARCH WARRANT, BECAUSE THE
EVIDENCE BEING SOUGHT IS EASILY DELETED OR DESTROYED. IN
ADDITION, AFFIANT’S INVESTIGATION IS NOT KNOWN TO THE SUSPECT AND
DISCLOSURE OF THE INVESTIGATION WILL LIKELY CAUSE IMMEDIATE
DANGER TO WITNESSES, DESTRUCTION OF OTHER PHYSICAL EVIDENCE AND
FLIGHT FROM PROSECUTION.
BECAUSE OF THE EXIGENCY OF THIS INVESTIGATION AND THE BELIEF OF
AFFIANT THAT DELAY MAY POSE IMMEDIATE DANGER TO HUMAN LIFE
MAY RESULT DELAY, THIS COURT HEREBY ORDERS THAT LINKEDIN USE ALL
REASONABLE MEANS TO RESPOND TO THIS ORDER WITHIN THREE (3) DAYS
FROM THE DATE OF ISSUANCE.
4, AFFIANT HAS PROBABLE CAUSE FOR THE SAID BELIEF BY REASON OF THE
FOLLOWING FACTS, TO-WIT:
See attached Supporting Affidavit labeled “Exhibit A’. Exhibit A is attached hereto
and by this reference incorporated herein for all purposes.
WHEREFORE, Your Affiant respectfully requests this court to authorize this search/seizure
warrant
J Ween
AFFIANT /
INVESTIGATOR CODY MCKINNEY
MIDLOTHIAN POLICE DEPARTMENT
Subscribed and sworn to before me at YZ 7M by said Affiant on this the 227 day
ot_Aget .AD.20 £6
JUDGE BOB CARROLL
40™ JUDICIAL DISTRICT JUDGE
ELLIS COUNTY TEXAS
Page 4 of 7
EVIDENTIARY SEARCH/SEIZURE WARRANT
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043EXHIBIT “A”
AFFIDAVIT IN SUPPORT OF EVIDENTIARY SEARCH
WARRANT
{Article 18.02(10), Texas Code of Criminal Procedure}
YOUR’AFFIANT’S BACKGROUND, TRAINING AND EXPERIENCE
Your Affiant, Cody Mckinney, having been duly sworn, declare as follows:
| am a Sergeant with the Midlothian, Texas Police Department. | have been employed
by said department for a period of approximately eleven (11) years. | have served in
investigative capacities within the Midlothian Police Department for approximately nine
(9) years. | have received special deputation as a Deputy United States Marshall, and
swom as a Federal Task Force Officer (TFO) assigned to the North Texas High
Intensity Drug Trafficking Area (HIDTA), Southern Money Laundering Initiative. 1 am
currently assigned as a Task Force Officer (TFO) with the Drug Enforcement
Administration (DEA) Eastern Drug Squad Group One. | currently possess an
‘Advanced Peace Officer Certification as merited by and with the State of Texas
Commission on Law Enforcement (TCOLE).
Your Affiant has also participated in numerous narcotics and financial investigations
with the Internal Revenue Service-Criminal Investigations (IRS-Cl) relevant to violations
of State and Federal Money Laundering statutes. Your Affiant has also received
specialized training in narcotics investigations from the Drug Enforcement
Administration (DEA) and related Money-Laundering matters from the Internal Revenue
Service-Criminal Investigations (IRS-Cl)
Your affiant is also trained and cettified in the use of Cellebite/UFED electronic forensic
data extractions, and affiant has had substantial experience in extracting
electronic/digital data from various types, makes, and models of electronic/digital
devices including cell phones, tablets, and GPS devices. Additionally, affiant has spent
hundreds of hours on numerous cases analyzing such extracted data and information.
In addition, Your Affiant has experience in the execution of financial search warrants,
narcotics search warrants, debriefing defendants, informants, and other
witnesseslindividuals who have personal knowledge of the amassing, spending,
converting, transporting, distributing, laundering, and concealing of proceeds derived
from the distribution of illegal drugs.
Page Sof7
EVIDENTIARY SEARCH/SEIZURE WARRANT.
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043Your Affiant has used a variety of investigative techniques during his investigations
including, but not limited to, electronic surveillance, visual surveillance, the use of
confidential sources and the use of undercover agents. Information contained in this
Affidavit is derived from Your Affiant's knowledge of, and prior experiences in financial
and narcotics investigations; information obtained during interviews with drug traffickers
familiar with this drug trafficking organization, and review of reports prepared by special
agents with DEA as well as other federal, state and local law enforcement agencies
As a result of Your Affiant’s participation in this investigation, my conversations with,
and review of reports prepared by HIDTA Task Force Officers as well as other federal,
state and local law enforcement agencies, | am familiar with all aspects of this
investigation as articulated in this Affidavit. Information contained in this Affidavit
includes the results of review of property records and other information obtained from
public sources; physical surveillance; information from cooperating witnesses and law
enforcement personnel,
YOUR AFFIANT’S PROBABLE CAUSE
The recitation of facts contained in this Affidavit is not meant to be a complete narrative of all
information that is known to Your Affiant, but only a summary of facts to necessitate the
establishment of sufficient probable cause, in support of this affidavit, for an Evidentiary Search
Warrant
The decedent was murdered as she arrived to prepare for a physical fitness class she
was to teach on the morning of the 18" of April 2016 at the Creekside Church,
Midlothian, Ellis County, Texas 78065. The suspect in this case is currently unknown
and at large.
The unknown suspect dressed in police tactical/riot gear, obtained forcible entry to the
location of the murder, to-wit, the Creekside Church, and appears on the Creekside
Church surveillance videos. The unknown suspect is the only person detected within
the building during a period of approximately thirty (30) minutes when the victim and
decedent, Terri "Missy" Leann Bevers, was murdered, and it is reasonably believed that
the said unknown suspect is responsible in part or in full for murdering Ms, Bevers.
In the course of our investigation we have had multiplé references to the Decedent's
social media accounts, specifically her LinkedIn account. Linkedin is a social media
networking service used to make connections to others. In the course of our
investigation, we have received information from interviews conducted with persons of
interest and persons close to the victim that the decedent was a regular user of
Linkedin.
During one such interview a friend of the decedent told law enforcement that less than
three days before the murder, the victim showed this friend a private message from the
Page 6 of 7
EVIDENTIARY SEARCH/SEIZURE WARRANT
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043victim's Linkedin account. The message was from a male unknown to them both, and
they both agreed that the message was creepy and strange. This friend could not recall
the person's name on the account.
Additionally, law enforcement has conducted several interviews with persons of interest
and during one such interview learned that Casey Williams, had engaged in while on
the LinkedIn Social Media Service several correspondence with the decedent since
(January of 2016) until her death. These communications were described as flirtatious
and familiar.
An electronic forensic data extraction of the cell phones belonging to the decedent and
Mr. Williams confirms that the communications using Linkedin occurred. The content of
the recovered communications appears intimate in nature. The extracted information
also showed that these communications were deleted after the conversation ended and
were only able to be partially recovered.
Your Affiant has probable cause to believe that the decedent was in contact with
several such people through the Linkedin service who are of direct interest to this
investigation.
aU Cln
AFFIANT /
INVESTIGATOR CODY MCKINNEY
MIDLOTHIAN POLICE DEPARTMENT.
Subscribed and sworn to before me at 7 7S/ /M by said Affiant on this the day
of Ait. & Ap.20 LZ.
JUDGE BOB CARROLL
40" JUDICIAL DISTRICT COURT
ELLIS COUNTY, TEXAS
Page 7 of 7
EVIDENTIARY SEARCH/SEIZURE WARRANT
LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043MIDLOTHIAN POLICE DEPARTMENT
Criminal Investigation Division
1150 N. US Highway 67, Suite 300, Midlothian, TX 76065
(972) 775-3333
26 APRIL 2016
Linkedin Corporation
ATTN: Legal Department
2029 Stierlin Court
Mountain View, CA 94043
BY FAX: 650-810-2897
RE MPD CASE NUMBER 16MP016585
EMERGENCY DATA REQUEST
My name is Detective Nick Selby, badge number is #168, and I am a sworn police officer with
the Midlothian, Texas, Police Department, 1150 N. US Highway 67, Suite 300, Midlothian, TX
76065. Since July, 2014, I have been assigned to the Criminal Investigation Division. The
telephone number for Central Dispatch is (972) 775-3333. My mobile phone number is (817)
908-3171
In the course of my duties Ihave been assigned to the team working to investigate the murder of
‘Terri “Missy” Leann Bevers (“Decedent”), which occurred on the morning of 18 April 2016
sometime between 0400 and 0500 CST in the Creekside Church, Midlothian, Texas, a crime
under Texas Penal Code 19.02 MURDER (6) (1), to wit: a person commits an offense if he: (1)
intentionally or knowingly causes the death of an individual. An offense under this section is a
felony of the first degree.
‘The case number for this investigation is 16MPO16S85.
The LinkedIn account of Decedent is accessible through the following URL:
https://www.linkedin.com/in/missy-bevers-5a18375a
During the course of this investigation, several references have been made to the Decedent's
LinkedIn account, We are preparing a full search warrant for the judge to sign. [hereby attest
that there are exigent circumstances that make it necessary for me to additionally request on an
emergency basis all information that was sent to the Decedent through the LinkedIn service
using private messages, chats or InMail between April 14, 2016 and April 16, 2016. We have
reasonable grounds to beliove that the killer, who is still at large and poses an immediate danger
to other human beings, communicated with the Decedent in this manner in that time period.Emergency Disclosure Request, Linkedin, MPD Case Number 16MPO16585,
Additionally we have reasonable grounds to believe, and request on an emergency basis the
content of any and all chat, private messages, InMail or other methods available to those with
access to the LinkedIn service were sent between the Decedent and Casey Williams
(attps://www.linkedin.com/in/easey12 airborne) in the month prior to 18 April 2016, We base
this exigency request on statements made by witnesses during the course of this investigation,
also hereby submit a Preservation Request for the data contained in the accounts of both
Decedent and Casey Williams (https:/www.linkedin.comv/in/easey12 airborne)
Please respond to these requests via email: nick.selby@midlothian.tx.us. If this is not possible,
then please provide the data in the form of an encrypted digital download accessible through the
Internet by emailing instructions on access to the file to nick.selby@midlothian.tx.us.
‘The above is true and correct to the best of my knowledge
Detéetive Nick Selby
Midlothian, TX Police Department
Criminal Investigation Division